Part 3: Accessibility of the complaints system
A complaints-handling process should be easily accessible to all complainants. Information should be made available on the details of making and resolving complaints. The complaints-handling process and supporting information should be easy to understand and use.
International Organization for Standardization
3.1
In this Part, we discuss:
- the lack of a widely understood definition of a complaint;
- how ACC should ask people how they want to complain;
- how access to the complaints system needs to be improved;
- how people miss out on assistance because services are under-used; and
- how ACC does not know why dissatisfied people do not complain.
Summary
3.2
Within ACC, there is no common and widely understood definition of a complaint. This lack is a barrier to improvement.
3.3
People can complain in several ways, but ACC does not know whether these are the methods that people want to use because it has not asked them. ACC knows that its more than 2500 forms, leaflets, and information sheets use too much jargon and have problems with tone, style, and readability.
3.4
ACC's telephone technology is modern and capable but not used to its full potential, and many complainants' calls are diverted to answerphones. Webpages dealing with complaints are difficult to find and poorly laid out. There is no way to complain using text messages, social media, or web-based channels.
3.5
ACC pays for some independent advocacy services to help complainants. Complainants who use these services find them effective, but many frontline staff are unaware of the services so cannot refer people to them. Likewise, use of ACC's cultural services team varies.
3.6
Many dissatisfied people do not complain. ACC does not know why dissatisfied people do not complain because it has not asked them.
There is no clear and widely understood definition of a complaint
Lacking a clear and widely understood definition of a complaint makes it difficult for ACC to treat complainants consistently and for staff to effectively communicate with each other about complainants' dissatisfaction.
We were told that ACC wanted only short-term claimants and long-term claimants have to “fight for everything”.
3.7
ACC lacks a standard definition of a complaint. ACC staff use several terms to describe complaints including "issue", "concern" and "service failure". In general, but not always, ACC staff use the word "complaint" to refer to an expression of dissatisfaction that has been referred formally to a corporate department such as CSS or OCI. When we spoke with some staff, their definition of a complaint changed without them noticing during the course of the same conversation.
3.8
The main purpose of a definition is to achieve clarity and consistent understanding. ACC's use of inconsistent terms for complaints:
- has generated overlapping processes;
- means that ACC staff communicate with each other inconsistently;
- makes it difficult for ACC to treat complainants consistently;
- could misrepresent the severity of a person's problem; and
- makes accurate recording of complaints difficult.
People have not been asked how they want to complain
There are several ways to complain, but ACC does not know whether these are the methods that people want because it has not asked them.
3.9
Figure 10 presents our assessment of how good ACC is at providing people with different ways to complain. ACC has several channels through which to complain, including a free to use telephone line. However, ACC has not asked complainants, since about 2006, whether these channels are what they want. People cannot complain using text messages, social media, or web-based channels.
Figure 10
The availability of different ways to complain to ACC
| Does ACC provide… | Our findings |
|---|---|
| A range of complaint channels? | ACC offers several ways to make a complaint including:
|
| A complaint hotline or free phone number? | Customer Support Service manages a free telephone number for complaints. |
| A survey of claimants to ask for their channel preferences? | ACC has not surveyed people to obtain their preferences since the service recovery project in about 2006. This means that ACC does not have an up-to-date understanding of their service users' wishes and preferences on how to complain. |
| A separate channel for MPs to complain (on behalf of their constituents)? | Sometimes, members of Parliament complain through the Minister's office. When ACC receives complaints from the Minister's office, they are directed to the government services team. There is a 10-day response standard and the complaints are recorded and logged by the government services team. These complainants are unlikely to feature in the complaints statistics. Sometimes, members of Parliament go straight to the local ACC office. The complaint is then dealt with using the service recovery approach. If it is resolved at the local office, it will not be recorded as a complaint. If it progresses to CSS or OCI, it will be recorded as a complaint. The response standard could vary between one working day and eight weeks or more. ACC told us that members of Parliament are given guidelines from the Minister for ACC on how to complain. ACC also encourages a relationship with the local offices of members of Parliament. |
Source: Office of the Auditor-General.
3.10
Our survey of complainants showed that the four most common ways to make a complaint were:
- to call the free-phone number (34%);
- to call the local office (21%);
- to email (17%); and
- to write a letter (7%).
| Recommendation 1 We recommend that the Accident Compensation Corporation periodically seek suggestions and implement solutions that would make it easier for people to complain. |
There is room to make it easier to complain
Important documents are provided in a range of languages, and ACC is working to improve its written communications to improve accessibility. In our view, ACC's telephone performance has not received enough attention from managers and relevant webpages also need to be improved.
3.11
The people who rely on ACC after an accident include some of the most vulnerable people in society – they include people with severe injuries or mental health conditions, and victims of assault. ACC claimants also include people with diverse cultural, linguistic, and educational backgrounds.
3.12
An attitude that welcomes complaints is important. That means making it easy to complain. Good practice in handling complaints gives people the best opportunity to make a complaint and does not necessarily mean minimising the number of complaints. People appreciate knowing that someone is listening to them and that they can influence how ACC delivers services to the public.
3.13
Proactively managing complaints allows an organisation to counteract negative experiences and turn dissatisfied customers into satisfied customers. The alternative is for complainants to remain dissatisfied and spread negative opinions about an organisation.
3.14
Some of our interviewees received correspondence from ACC that included a factsheet or booklet about making complaints. They felt that the information in the documents was misleading.
3.15
Many of our interviewees told us that, before making a complaint, they did not know how to do so.
3.16
About half of the people we surveyed had tried to find information during the complaints process. Of these, just over a quarter could not find what they were looking for. Figure 11 shows the results from our survey about information availability and quality from the people who did find the information they were looking for. This shows that ACC needs to make information easier to find. ACC could also make improvements to make its information more helpful, and easier to understand.
Figure 11
Complainants' perception of information availability and quality
| Statement | Percentage of respondents who agreed or strongly agreed |
|---|---|
| The information was easy to understand | 69% |
| The information was helpful | 64% |
| The information was easy to find | 57% |
Source: Office of the Auditor-General.
3.17
Because people rely increasingly on the Internet, ACC needs to improve its complaint web pages, which are poor. In our survey, about half of complainants told us they looked on the Internet for information during the complaints process.
3.18
Some of the complainants we interviewed told us that they felt that ACC did not communicate openly and used language that was not plain English. There was frustration with being told "I hear what you say" and what sounded like scripted language.
3.19
ACC knows that it can improve how it communicates with potential complainants. It is also aware of weaknesses in its written communications and is working to improve them.
3.20
ACC offers versions of its main documents, such as information sheets, in a range of New Zealand's most commonly spoken languages, such as English, Māori, Samoan, Tongan, Chinese, Korean, and Hindi. There is a process to ensure that these are appropriately translated. Telephone-based translation services are available, covering 39 languages.
3.21
ACC's telephone technology is modern and capable but is not used to its full potential. There is a freephone complaint telephone number, which is also free for people calling on cellphones. However, advocates have told us that they sometimes find it difficult to get through on the 0800 complaints telephone line. Our analysis shows that there may be capacity problems, because ACC's data shows that almost half of all calls to the 0800 complaints telephone line are diverted to answerphone.
3.22
We recognise that there are weaknesses in this data. This is partly because, before our audit, ACC did not routinely analyse complaint telephone service performance and requesting this sort of data is new. ACC is working to address these weaknesses.
3.23
Figure 12 shows our assessment of how good ACC is at helping people to make a complaint.
Figure 12 How ACC helps people who want to make a complaint
| Does ACC provide… | Our findings |
|---|---|
| Accessible language in its communications? | ACC accepts that it must improve how it communicates with people. It has problems with jargon, accessibility, tone, and style. The forms, leaflets, and information sheets (FLIS) project started in June 2013 and is tasked with identifying improvements. |
| Written information on the complaints system, such as a brochure or handout? | ACC's brochure Working together to resolve issues (ACC2393) is given to all people when they first make a claim. We assessed its readability using a sample SMOG test.* Most people will understand a document if it scores about 10 on the SMOG test. ACC's brochure scored 16 (a graduate level), which means that not everyone will fully understand the information in ACC's brochure. We visited five local offices and found only two displaying any corporate literature about complaints in public areas. |
| Hard copy complaint forms? | People have the option to lodge a complaint using a hard copy form (ACC709). |
| Access to the 0800 complaints telephone line? | Our analysis of ACC complaint call data between October 2013 and January 2014 shows that about 10% of calls were abandoned by the caller before being answered. The World Bank recommends reducing this percentage to between 5% and 8%. (See International Finance Corporation, Measuring call center performance, available at www.ifc.org.) |
| Free telephone calls, including from cellphones? | The 0800 number is free to use, including from cellphones. |
| Access through telephone service features, such as interactive voice response and a virtual queue? | The telephone system is capable of interactive voice response but it is not used. Interactive voice response allows the caller to interact with the telephone system by choosing options. Virtual queue facilities guarantee the caller's position in the queue without having to wait on hold and automatically call back when a representative is available to speak to the caller. Virtual queue facilities are expensive and ACC's analysis of the telephone system as a whole shows there is little queuing that would justify such an investment. The 0800 complaints telephone line has a voicemail service where callers can leave a message with their contact details. Our analysis of call data between October 2013 and March 2014 shows that about 48% of calls were directed to voicemail. This restricts access and could suggest capacity problems in CSS. People are unlikely to view being diverted to voicemail as good customer service. |
| Easily accessible complaint information on its website? | ACC's website does not make it easy to complain. There is:
|
| Information about how ACC handles complaints in other languages? | ACC provides versions of its brochure Working together to resolve issues (ACC2393) in several languages. For documents such as information sheets, ACC use a translation agency. The translated document is then checked by a member of ACC's cultural services team. Telephone-based translation services are also available, covering 39 languages. |
| Information about how ACC handles complaints in other formats? | ACC does not provide formats, such as braille, electronic audio, and large print, for the visually impaired. ACC provides a Deaf Community Fax facility and a dedicated email for the hearing impaired. These are not complaint-specific channels but are managed by CSS. |
Source: Office of the Auditor-General.
* A SMOG test is a measure of readability that estimates the years of education needed to understand a piece of writing.
People miss out on assistance because services are under-used
Complainants who use ACC's free advocacy services like the services and find them effective. However, many ACC staff are unaware of these services, so do not refer people to them. ACC's cultural services team provides language, cultural, and facilitation support for frontline staff working with people of Māori, Pacific, and Asian descent. Local office staff's awareness and engagement with the cultural services team varies.
Advocacy services
Only about one-third of the people we surveyed felt that their complaint had made a difference.
3.24
Some people need help to lodge a complaint. Advocacy services are non-legal services that can help people who want to complain. They can help people to understand information about their ACC entitlements and ACC's decisions. Complainants can get private sector advocates to help them or act on their behalf and might have to pay for these services. ACC pays organisations to provide complainants with advocacy services for free.
3.25
Providing complainants access to free advocacy services makes sense. Advocates better understand ACC processes and terminology and can easily access ACC staff. Therefore, complaints are more likely to be resolved earlier, shortening the long and costly process if complaints are escalated.
3.26
We looked at three organisations that provide free advocacy services to people relying on ACC. All these advocacy services are external and independent of ACC, but ACC funds them. The three we looked at are:
- Linkage Trust (Linkage);
- Workplace Injury Advocacy Service (WIAS), part of the New Zealand Council of Trade Unions; and
- Brain Injury Association of New Zealand (BIANZ).
3.27
In 2010, the three organisations started to offer free advocacy services to people with ACC claims, funded by ACC contracts worth $400,000. By May 2011, BIANZ was no longer able to continue with the service and the contract was ended by mutual consent. The advocacy services have proved effective and popular with people who used them.
3.28
Advocacy reduces by one-third the number of complaints that end up being reviewed. Only about 10% of people involved with these advocacy services advance to a formal review of their complaint, compared with about 15% of those who did not use the advocacy services.
3.29
In 2011, surveys showed that 99% of respondents who had used WIAS's services rated the advocacy service provided as good or better, and 91% of Linkage respondents would definitely recommend the advocacy service to others.
3.30
These advocacy services could be used more widely. In total, the two services had about 860 contacts from ACC in 2013, not all of which were related to complaints. WIAS and Linkage think that people's access to advocacy services could be improved.
3.31
One reason that advocacy services are not used more widely may be that ACC staff have little awareness of them, so are unlikely to refer complainants to them. Figure 13 shows how well frontline staff are aware of and understand advocacy services.
Figure 13
Frontline staff's awareness and understanding of advocacy services
Source: Office of the Auditor-General (2014), survey of ACC staff.
3.32
We looked at how people who did access these advocacy services found out about them. Figure 14 shows that only about one in 10 of WIAS' service users were referred from ACC.
Figure 14
Source of referral for complainants accessing WIAS' advocacy services, 2011
Source: Office of the Auditor-General.
3.33
Figure 15 shows that only about one-third of Linkage's service users were referred from ACC.
Figure 15
Source of referral for complainants accessing Linkage's advocacy services, 2011
Source: Office of the Auditor-General.
3.34
After the BIANZ contract was ended, most of the BIANZ contract funding was reallocated to other uses. Figure 16 shows recent ACC funding of advocacy services. Not reallocating the BIANZ funding to a different organisation and/or among the remaining two organisations has led, in effect, to a 30% cut in funding from that originally envisaged.
Figure 16
ACC funding for advocacy services, 2010/11 to 2013/14
| Advocacy service | Funding $000 | |||
|---|---|---|---|---|
| 2010/11 | 2011/12 | 2012/13 | 2013/14 | |
| Workplace Injury Advocacy Service | 150 | 150 | 150 | 154 |
| Linkage Trust | 125 | 125 | 125 | 126 |
| Brain Injury Association of New Zealand | 125 | 0 | 0 | 0 |
| Total | 400 | 275 | 275 | 280 |
Source: Office of the Auditor-General.
3.35
ACC's support of advocacy services such as WIAS and Linkage is worthwhile and in line with the service recovery approach of resolving complaints at the earliest possible opportunity. However, ACC could get better value for money from its investment in advocacy services by increasing the awareness of the advocacy services it funds.
3.36
ACC is missing opportunities to resolve complaints earlier in the process. Resolving complaints early would be a more effective and efficient use of resources and increase the chances of restoring the ACC-claimant relationship.
Cultural services
3.37
The Code specifies that people have the right to effective communication, including access to an interpreter when necessary and reasonably practicable. ACC has a cultural services team that provides language, cultural, and facilitation support for frontline staff working with Māori, Pacific, and Asian claimants.
3.38
Our staff survey showed that frontline staff know about the cultural services team, with 49% of respondents saying that they had a good knowledge of what the team did. However, awareness varies widely between local offices and is not always higher in areas with higher populations of ethnic minorities.
3.39
The cultural services team told us that:
- the team has excellent relationships with some local offices;
- younger and/or newer staff are more willing to use the cultural services team; and
- some local offices protect what they see as their "patch" and resist help from outside.
3.40
We did not test these matters in detail, but did see that the local office's manager heavily influences the atmosphere and culture of each local office.
3.41
The method for seeking the cultural services team's help is reactive, which may prevent some people from getting help. The system depends on the person showing a need for help and the ACC staff member recognising this and making a request. These represent two potential failure points in the system that may prevent some people getting the help they need.
3.42
CSS can make referrals to the cultural services team as part of resolving a complaint. In our view, getting the cultural services team involved earlier in complaints, including for complaints at the local office, might be better. This would be consistent with the service recovery approach of resolving complaints at the lowest possible level. However, the cultural services team relies on being asked for help and often finds that the complaint has progressed before they can get involved.
Reasons why dissatisfied people do not complain are not looked into
Many dissatisfied people do not complain. An organisation that focuses on customers must understand them, especially unhappy customers. ACC does not know why dissatisfied people do not complain, and has not carried out any recent research to find out why.
3.43
ACC lacks understanding of why some people do not complain. It is important for all public entities to understand why some dissatisfied people do not complain so that the relationship with them can be rebuilt.
3.44
In 2012/13, 16% of people who had a claim accepted by ACC said they were dissatisfied or very dissatisfied with their service experience. In those 12 months, ACC dealt with about 1.3 million people. Therefore, potentially, about 200,000 people were dissatisfied with their ACC experience. However, ACC recorded only about 1600 complaints in 2012/13.
3.45
Research on the behaviour of customers and complainants suggests that this difference is typical. In society in general, most dissatisfied customers do not complain. One estimate is that about one in 10 dissatisfied customers formally complain about service, with others suggesting that, as a general rule, for every complaint an organisation receives there are between 25 and 50 unreported problems.13
3.46
Several factors can influence whether dissatisfied people complain. Income, education, skills, confidence, and age, and, sometimes, gender are all factors that can affect whether someone will complain. It varies by service and customer group, which is why it is important for organisations to understand their unhappy customers and complainants.
3.47
Sometimes people's views about complaints processes, especially feeling that nobody will listen and nothing will change, leads them not to complain. These feelings are more significant for certain groups of people, such as those from different cultures, people who do not speak English as a first language, young people, and people with disabilities.
3.48
Our survey of ACC complainants shows that the organisation faces significant strategic challenges in complaint handling:
- About half did not think that ACC did what it said it would do.
- Only about one-third felt that their complaint had made a difference.
3.49
If people see little value in complaining, then the number of complaints might fall because of people's confidence in the system and processes is weakened.
3.50
If people have a positive experience of an organisation's complaints system, this will lead to increased satisfaction. A benefit to the organisation when complaints are solved and complainants are satisfied is that people tell others about their positive experience with the organisation.
3.51
ACC does not know why dissatisfied people do not complain, and has not carried out any recent research or surveys to find out why. The wider research detailed in paragraphs 3.45-3.47 shows that there could be many reasons dissatisfied people do not complain. If ACC is to become an organisation that focuses more on people, it needs to understand what those reasons are and try to address them.
| Recommendation 2 We recommend that the Accident Compensation Corporation periodically look into, understand, and remove any barriers that prevent or discourage people from complaining. |
13: George, M., Graham, Prof. C., and Lennard, L (2007), Complaint handling: Principles and Best Practice, Centre for Utility Consumer Law, University of Leicester.