How to Write an NDIS Complaints and Feedback Policy: Requirements and Template Guide

The Legislative Framework for NDIS Complaints

Complaints management for NDIS providers is governed by multiple intersecting pieces of legislation. Your policy should reference all of them to demonstrate a thorough understanding of the regulatory environment:

• National Disability Insurance Scheme Act 2013 (Cth) — Establishes the NDIS Quality and Safeguards Commission and its complaints functions (Part 3A, Division 5)
• NDIS (Complaints Management and Resolution) Rules 2018 — The primary instrument governing how registered providers must handle complaints. Requires providers to have an accessible complaints management and resolution system
• NDIS (Provider Registration and Practice Standards) Rules 2018 — Sets out the Practice Standards, with Outcome 1.5 covering feedback and complaints as part of the participant safeguarding framework
• NDIS Code of Conduct (Section 73V, NDIS Act 2013) — Requires workers and providers to promptly take steps to raise and act on concerns about matters that may impact the quality and safety of supports
• Privacy Act 1988 (Cth) — Governs how personal information collected during the complaints process must be handled

The NDIS Commission has a dual role in complaints: it is both the regulator that sets the standards and the external complaints body that receives complaints from participants who are unsatisfied with a provider’s internal response. This dual role means your policy must explicitly inform participants that they can complain directly to the Commission at any time.

Mandatory Elements Your Policy Must Include

Based on the Complaints Management Rules 2018 and the Practice Standards quality indicators for Outcome 1.5, your complaints and feedback policy must include the following elements:

1. Policy Statement and Commitment

Open with a clear statement that your organisation welcomes feedback and complaints as an opportunity to improve services. This is not just a formality — auditors assess the “tone” of the policy. A policy that frames complaints as problems to be managed will be viewed less favourably than one that positions complaints as valuable information.

2. Definitions

Define the key terms used throughout the policy:

3. Who Can Make a Complaint

Your policy must state that complaints can be made by anyone, including: participants, family members, carers, nominees, guardians, advocates (including independent advocates), staff members, volunteers, other service providers, and members of the public. Complaints can be made on behalf of another person. Anonymous complaints must also be accepted and investigated.

4. How Complaints Can Be Made

List multiple accessible channels through which complaints can be lodged:

• Verbally (in person or by telephone)
• In writing (letter, email, complaints form)
• Through a nominee, advocate, or family member
• Through the NDIS Commission (1800 035 544)
• Via an interpreter or communication support where needed

5. Complaints Resolution Process

Include the step-by-step process for handling complaints (detailed in the next section).

6. Timeframes

Specify the timeframes for acknowledging and resolving complaints.

7. External Pathway Disclosure

Include a standalone section informing complainants of their right to complain directly to the NDIS Commission at any time. This is not optional — it is a specific requirement under the Complaints Management Rules.

8. Protections Against Retaliation

State clearly that no person will be subject to retaliation, disadvantage, or reduction in service quality as a result of making a complaint or providing feedback. This protection extends to participants, families, and staff members.

9. Privacy and Confidentiality

Explain how personal information collected during the complaints process will be handled, stored, and protected in accordance with the Privacy Act 1988 and your organisation’s privacy policy.

10. Continuous Improvement Link

Describe how complaints data is analysed and used to drive service improvements. Auditors look for evidence that complaints inform your continuous improvement register.

The 7-Step Complaints Resolution Process

Your policy must describe a clear, step-by-step process for handling complaints from receipt to resolution. The following 7-step process is consistent with NDIS Commission expectations:

Step 1: Receive and Record

Record every complaint in the complaints register immediately upon receipt. Assign a unique complaint ID. Record the date, the method of receipt, the complainant’s details (or “anonymous”), and a description of the complaint. Assess whether the complaint involves an immediate safety concern that requires urgent action.

Step 2: Acknowledge

Acknowledge the complaint to the complainant within 2 business days of receipt. The acknowledgement should confirm that the complaint has been received, provide the complaint reference number, name the person responsible for managing the complaint, outline the expected process and timeframe, and provide the NDIS Commission contact details as an alternative pathway.

Step 3: Assess and Triage

Assess the nature and severity of the complaint. Determine whether the complaint relates to a potential reportable incident (which triggers separate reporting obligations to the NDIS Commission). Assign the complaint to an appropriate person for investigation — this should not be the person who is the subject of the complaint.

Step 4: Investigate

Gather relevant information: interview the complainant, the staff member(s) involved, any witnesses, and the participant (if not the complainant). Review relevant records, policies, and procedures. Document the investigation findings. Where the complaint involves a potential breach of the NDIS Code of Conduct, follow your organisation’s Code of Conduct breach process.

Step 5: Resolve

Determine the appropriate resolution. Resolutions may include: an apology, an explanation, a change in practice or procedure, additional staff training, disciplinary action, a referral to an external body, or compensation where appropriate. Communicate the outcome to the complainant in writing.

Step 6: Follow Up

Contact the complainant after resolution to confirm they are satisfied with the outcome. If the complainant is not satisfied, advise them of their right to escalate the complaint internally (e.g., to the CEO or Board) or externally to the NDIS Commission. Record the complainant’s satisfaction or dissatisfaction in the register.

Step 7: Review and Improve

Analyse the complaint for systemic issues. If the complaint reveals a gap in policy, procedure, training, or practice, record a corrective action in the continuous improvement register. Report complaint trends to governance meetings at least quarterly.

Timeframes for Acknowledgement and Resolution

Record all dates in the complaints register so you can demonstrate compliance with your stated timeframes during an audit. If you consistently fail to meet these timeframes, auditors will raise this as a non-conformance.

---

---

Complaints Register Fields and Maintenance

The complaints register is the evidence that your complaints system works. A policy without a maintained register will not satisfy the audit requirements. Your register should contain the following fields:

Maintain the register as a living document. Review it at governance meetings at least quarterly to identify trends, systemic issues, and areas for improvement. The register should show evidence of active management — open complaints being progressed, resolved complaints showing outcomes, and continuous improvement actions flowing from complaint themes.

Participant Accessibility Requirements

The Complaints Management Rules require that the complaints system is accessible to all participants. This is an area where many small providers fall short. Accessibility means:

Communication Accessibility

• Complaints information is available in Easy Read format for participants with intellectual disability
• Large print versions are available for participants with vision impairment
• Information is provided in the participant’s preferred language, with access to interpreting services (Translating and Interpreting Service: 131 450)
• Staff are trained to support participants who use augmentative and alternative communication (AAC)
• Visual aids and social stories are available where appropriate

Procedural Accessibility

• Participants are informed about the complaints process at the commencement of service (during intake/onboarding)
• Complaints information is displayed in accessible locations within SIL houses
• Participants can be supported by an advocate, family member, or nominee to make a complaint
• Verbal complaints are accepted and recorded by staff — a written form is not required from the participant
• Participants are regularly asked for feedback, not only when they initiate a complaint

For guidance on writing accessible participant-facing documents, our free NDIS Notes Rewriter can help translate complex language into clear, participant-friendly communication.

Cultural Safety

Complaints processes must be culturally safe for Aboriginal and Torres Strait Islander participants, participants from culturally and linguistically diverse (CALD) backgrounds, and participants from LGBTQIA+ communities. This means recognising that some cultural groups may find the formal complaints process intimidating or culturally inappropriate, and providing alternative ways to raise concerns.

Managing Unreasonable Complainant Conduct

Your policy should include a clause addressing how the organisation manages unreasonable complainant conduct (UCC). This is not about discouraging complaints — it is about managing behaviour that is aggressive, threatening, or makes unreasonable demands on the organisation’s resources.

The NSW Ombudsman’s Managing Unreasonable Complainant Conduct framework is widely referenced as best practice. Key principles include:

• The right to complain is absolute. You cannot deny a person the right to make a complaint. You can only manage how the complaint interaction is conducted.
• Graduated response. Start with verbal communication about acceptable conduct expectations. If conduct continues, move to written communication setting boundaries. As a last resort, restrict contact to written channels only.
• Document everything. Record each instance of UCC and each step of the graduated response.
• Always advise of the external pathway. If you restrict how a complainant can interact with your organisation, you must advise them that they can complain directly to the NDIS Commission.
• Protect staff. Workers have the right to be safe from aggressive, threatening, or abusive behaviour. The policy should state that threats of violence will not be tolerated and may be reported to police.

What Auditors Check and Common Failures

During a certification audit, the NDIS Approved Quality Auditor will assess your complaints system through document review, staff interviews, and participant interviews.

Auditor Checklist

• Complaints policy is current, version-controlled, and reviewed within the past 12 months
• Policy includes all mandatory elements listed in the Complaints Management Rules
• External NDIS Commission pathway is disclosed in the policy, service agreement, and complaint responses
• Multiple accessible complaint channels are available and promoted to participants
• Complaints register exists and shows evidence of active management
• Acknowledgement and resolution timeframes in the register are consistent with the policy
• Complaints data is reported to governance meetings and feeds into continuous improvement
• Staff can describe the complaints process when interviewed
• Participants confirm they know how to make a complaint and feel safe doing so
• Complaints information is available in accessible formats

Common Audit Failures

Failure 1: No external pathway disclosure. The most common finding. The complaints policy does not mention the NDIS Commission, or the service agreement does not include the Commission’s contact details. This is a straightforward non-conformance.

Failure 2: Complaints register is empty. An empty complaints register does not mean there are no complaints — it suggests complaints are not being recorded. Auditors are sceptical of providers who claim to have received zero complaints over an extended period.

Failure 3: No evidence of resolution. The register shows complaints received but no outcomes, actions, or resolution dates. This indicates complaints are received but not managed through to completion.

Failure 4: No accessibility measures. The complaints policy and information are only available in standard English text with no Easy Read version, no alternative formats, and no evidence that participants with communication barriers are supported to give feedback.

Failure 5: No continuous improvement link. Complaints are resolved individually but there is no evidence that complaint trends are analysed or that systemic issues are addressed through the continuous improvement register.