Why SIL providers need a complaints management policy
Under the NDIS Act and the NDIS Practice Standards, every registered provider — including those delivering Supported Independent Living — must have a clearly documented complaints management policy. This is not optional: the policy is a mandatory document that quality auditors assess when your organisation applies for or renews registration, or when the NDIS Quality and Safeguards Commission investigates a complaint about your service.
The strengthened Practice Standards framework reinforces that complaints handling must be genuinely participant-centred. That means making it easy for participants, their families, informal supports, and advocates to raise concerns, and ensuring that everyone who does so is free from retaliation or disadvantage. A policy that exists only on paper — without staff training, accessible formats, or consistent practice — will not satisfy an auditor.
What a complaints management policy must cover
While the Commission does not prescribe a single mandatory template, the NDIS Practice Standards (Core Module: Rights and Responsibilities; and the supplementary SIL standards) make clear that your policy must address all of the following elements:
- Scope — which services and locations the policy applies to
- How complaints can be lodged — verbally, in writing, via email, through a third party or advocate
- Who is responsible — named roles (not just position titles) with clear accountability
- Timeframes — acknowledgement, investigation, and resolution timeframes
- Record-keeping — how and where complaints are logged and retained
- Escalation — when and how matters are escalated to the NDIS Commission or other bodies
- No disadvantage principle — explicit statement that complainants will not be victimised
- Review and continuous improvement — how the organisation learns from complaints data
- Accessible formats — Easy Read, translated versions, or other formats on request
Filled-in sample: NDIS complaints management policy excerpt
The excerpt below is a realistic example showing what a completed policy looks like. Adapt it to your organisation's structure, location, and service types before use.
| Field | Example content |
|---|---|
| Policy name | Complaints Management Policy |
| Policy number | GOV-004 |
| Version | 3.1 |
| Review date | July 2027 |
| Approved by | Chief Executive Officer |
| Applies to | All staff, contractors and volunteers delivering NDIS supports under registration groups 0115 (Daily Activities) and 0106 (Group/Centre Activities) |
Purpose
Brightfield Support Services recognises that feedback and complaints are a valuable tool for improving the quality and safety of supports delivered to NDIS participants. This policy establishes a transparent, accessible and fair process for receiving, recording, investigating and resolving complaints in accordance with the NDIS Practice Standards and the requirements of the NDIS Quality and Safeguards Commission.
Definitions
- Complaint: Any expression of dissatisfaction about a support, a staff member, or the conduct of the organisation, where a response or resolution is expected.
- Complainant: A participant, their family member, carer, advocate, or any other person raising a complaint.
- Complaints Officer: The designated staff member responsible for managing the complaints process (currently: Operations Manager, Jordan Halverson, [email protected], (03) XXXX XXXX).
How to make a complaint
Complaints may be made by any person at any time using any of the following channels:
- Verbally — to any staff member, house supervisor, or Complaints Officer
- In writing — by completing a Complaint Form (available at each SIL site and on our website)
- By email — to [email protected]
- By phone — (03) XXXX XXXX (9 am–5 pm, Monday–Friday); an after-hours answering service is available
- Through an advocate or representative
- Directly to the NDIS Commission — 1800 035 544 or www.ndiscommission.gov.au at any time
Staff who receive a verbal complaint must record it in the complaints register on the same day. Participants will never be discouraged from making a complaint or escalating to the Commission.
Timeframes
| Step | Timeframe |
|---|---|
| Acknowledge receipt of complaint | Within 2 business days of receipt |
| Advise complainant of investigation plan | Within 5 business days |
| Resolve or provide substantive response | Within 30 calendar days (complex matters: written notice of extension provided) |
| Close complaint and notify complainant of outcome | Within 5 business days of resolution |
Escalation
If a complaint cannot be resolved internally, or where the matter involves potential abuse, neglect, exploitation or an unlawful restrictive practice, the Complaints Officer will escalate as follows:
- Notify the NDIS Commission in accordance with incident reporting obligations under the NDIS (Incident Management and Reportable Incidents) Rules 2018
- Advise the complainant of their right to contact the Commission, the relevant state or territory disability complaint body, or the Office of the Australian Information Commissioner (for privacy matters)
- Escalate internally to the CEO and Board within 24 hours for serious safety issues
No disadvantage principle
Brightfield Support Services will not discriminate against, disadvantage, or in any way harm a person for making, or intending to make, a complaint. Any staff member found to have victimised a complainant will be subject to disciplinary action up to and including termination of employment.
Record-keeping
All complaints are recorded in the Complaints Register (maintained in the case management system). Each entry includes: the date received, the nature of the complaint, the name and contact details of the complainant (where provided), the outcome, and any corrective actions taken. Records are retained for a minimum of seven years in accordance with applicable privacy legislation.
Continuous improvement
The Complaints Officer prepares a quarterly complaints summary for the Quality and Safety Committee, identifying themes, systemic issues and corrective actions. Findings are reported to the Board annually and used to update policies, procedures and staff training.
Step-by-step: implementing your policy
- Draft or update the policy using the elements above, tailored to your organisation's size and service types.
- Have it reviewed and approved by your governing body (board, directors, or senior management).
- Train all staff — including support workers, house supervisors and administrative staff — on how to receive and record complaints.
- Make it accessible — display the process in plain English at each SIL site, provide Easy Read versions, and make translated copies available on request.
- Set up your complaints register and test it before your next audit cycle.
- Review annually at minimum, and after any significant complaint or Commission contact.
- Document your reviews — auditors will ask to see evidence that the policy is a living document, not a file-and-forget exercise.
What auditors look for
Quality auditors assessing your complaints management system under the NDIS Practice Standards will look for evidence that:
- The policy exists and has been reviewed within the stated timeframe
- Staff can describe the process accurately without referring to a document
- Complaints register entries are complete and show follow-through
- Participants know how to make a complaint and are not afraid to do so
- Escalation pathways to the Commission are clearly documented and understood
- Complaints data has actually influenced practice or policy improvements
Common non-conformances include: no designated Complaints Officer, no accessible format versions, timeframes not met or not documented, and complaints registers with incomplete outcome entries.
Getting your full document suite audit-ready
A complaints management policy does not sit in isolation — auditors will cross-reference it against your incident management procedure, participant rights policy, and worker screening records. If you need a complete, pre-written and cross-referenced policy set, the 74-document SIL compliance kit at ndiscompliant.com.au covers every mandatory policy, procedure and form required for NDIS SIL registration and renewal under the strengthened 2026 framework.
Important: This article provides general guidance about NDIS compliance requirements. It is not legal or professional advice. Requirements may change as the NDIS Commission updates its policies and Practice Standards. Always verify current requirements with the NDIS Quality and Safeguards Commission or a registered NDIS consultant before making compliance decisions.