How to complete a quality Code investigation?
1. Acknowledge the complaint and clarify with the client the issue/s they are asking to
be investigated under the Code.
2. Once you and the client have agreed on the issues for investigation provide the
client with a timeframe to which you aim to complete your investigation by. Set
clear expectations with the client around how they would like to be communicated
with throughout the process. Eg; does the client want regular updates?
3. Set up the ACC7407 – Complaints investigation summary (list each issue for
investigation separately)
4. Consider whether you need to seek advice/input from another department to help in
your investigation eg; summary from branch/unit, privacy team, technical advice.
5. Begin your investigation – look through the claim file/s, party record and all relevant
information you have been provided from other parties. Place any relevant
information in the 7407 (the 7407 needs to clearly show what you have considered
as part of your investigation).
6. Once you have completed your 7407 consider what you have found and determine
whether you believe the Code has been breached. (Remember we determine
breaches based on evidence you have found during your investigation). Feel free to
bounce off your colleagues if you are unsure.
7. Write your findings letter – use the COM01 findings template however remember to
make the letter your own.
8. Once you have completed your letter send your draft to the Senior RS or TM for
checking.
9. Once your letter is back from checking ensure a copy of forwarded to management
of the relevant business
prior to sending to the client.
10. If appropriate contact the client to discuss and inform them of your findings before
issuing.
11. Issue the findings letter
What makes a bad apology?
1. The qualified apology: “Sorry, but..” This can come across as empty, obligatory, disingenuous.
2. The incomplete apology: “I’m sorry you feel/think that way.” This shifts the focus, and the blame,
away from the issue.
3. The excessive apology. Long-winded, repetitive apologies draw attention to you, rather than
rectifying the issue. Apologising too early can undermine the restorative process. Customers want
you to respond to their feedback in a way that shows you’ve heard them. In a restorative process, it
is better to listen and hear, and then apologise authentically.
What makes a good apology?
Moore’s theory of needs focuses on the psychological need to be heard and acknowledged. Most
people need a sense of procedural justice, and to know there will be meaningful change.
The elements of a good apology can be defined by the 6 Rs.
* Recognition
* Reasons
* Responsibility
* Remorse
* Remedy
* Reassurance
1. Recognise, factually, what happened, and the reasons for it happening. People don’t just want a
resolution; they want to understand why a problem occurred. Switching energy companies is very
common, apparently there is a 40% annual market churn. If a company explains why a mistake
occurred, and the customer trusts it won’t happen again, this could be enough to keep a customer.
2. Be accountable and accept responsibility for the occurrence. Any expression of remorse should be
authentic. The essence of the apology addresses psychological needs. Often the customer wants
recognition for what they’ve been through. We’ve seen energy providers perplexed over why
customers don’t just accept their offer of more money and move on, when the customer wanted
that acknowledgment and some sign of remorse.
3. Propose a remedy. What might be done to address what happened?
4. Give reassurance about the remedy. Let the person know who will be doing it, and when. This
helps give peace of mind. By the time complaints reach us, customers tend to be wary of empty
promises. Concrete details give certainty and help win back trust.
More often than not, a ‘bad’ or incomplete apology won’t resolve the issue or complaint. If you want
to achieve resolution and closure, best to give it some thought and get it right the first time.
Responsibility for managing complaints Policy v1.0
Summary
Objective
Different ACC groups are responsible for managing different types of complaints. This policy outlines the roles, responsibilities and
expected outcomes for each group, and the rules about ownership of complaint information and assigning complaints.
Owner
Out of scope
Expert
Out of scope
Policy
1.0 Role
a ACC business units, Accredited Employers (AEs) and Third Party Administrators (TPAs).
2.0 Responsibility
a You must:
• listen to the client and seek to understand what their concerns are
• gather information and think about your approach to a resolution
• respond to the client in a timely manner
• escalate to the Customer Resolution team if multiple or complex issues are raised, or if the client has made a complaint
under the Code of ACC Claimants' Rights
• work with the Customer Resolution team to resolve client concerns.
3.0 Expectation
a You must:
• capture feedback information including complaints, and document it on Eos
• make contact with the client
• resolve concerns to the client's satisfaction within the parameters of the legislation, if possible
• consider resolution outcomes that do not strictly fall within the parameters of the legislation, but are realistic and will achieve
a meaningful resolution for ACC and the client
• consider any recommendations given by the Customer Resolution team.
4.0 Customer Resolution - Role
a Customer Resolution staff must assist clients, business units, Accredited Employers and Third Party Administrators achieve an
outcome for client issues.
5.0 Customer Resolution - Responsibility
a You must:
• work in partnership with clients and staff
• investigate complaint issues
• issue written outcomes or decisions under the Code of ACC Claimants' Rights
• approve services in line with delegations to resolve minor client concerns, such as one-off taxis or bank dishonour fees
• support business units to restore relationships with clients
• work in partnership with the Remote Claims Unit to resolve concerns and complaints raised by risky clients
• gather information from the client to clarify their concerns and identify the resolution/s they would like
• check information on Eos
• consider policy, procedures and legislation
• advise business units of the concerns and confirm the processes, expectations and timeframes for outcomes
• develop a planned approach for a resolution of concerns
• negotiate and recommend resolution outcomes with business units for complaints and review applications
• document all contact information, investigation and documents on Eos
• uphold the standards of the Code of ACC Claimants' Rights
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6.0 Expectation
a You must achieve an outcome when:
• the concern is straightforward, can be dealt with easily and resolved by making one or two phone calls
• the concern involves an urgent matter relating to entitlements or treatment
• it’s not clear which business unit or case owner should manage the issue.
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Working with the Code of ACC Claimants’ Rights Policy v2.0
Summary
Objective
ACC and its agents have a legislative responsibility to provide the highest practicable standard of service and fairness to clients. In
order to fulfil our responsibilities, especially about our service, communication and behaviour you must understand you obligations
and responsibilities under the Code of ACC Claimants’ Rights.
See also Rules for managing complaints and Responsibility for managing complaints.
Owner
Out of scope
Expert
Out of scope
Policy
1.0 Applying the Code of ACC Claimants’ rights
a When dealing with clients ACC must fulfil its obligations in the Code of ACC Claimants’ Rights (the Code).
Accredited employers and agents of ACC are subject to the Code and must provide the highest practicable standard of service
and fairness.
2.0 The Rights
a The Injury, Prevention, Rehabilitation, and Compensation (Code of ACC Claimants’ Rights) Notice 2002 specifies eight rights.
Clients have:
• the right to be treated with dignity and respect
• the right to be treated fairly and have their views considered
• the right to have their cultures, value and beliefs respected
• the right to a support person or persons
• the right to effective communication
• the right to be fully informed
• the right to have their privacy respected
• the right to complain.
See Behaviours to uphold the Code of ACC Claimants' Rights for a more in-depth guide to each right and staff obligations.
Behaviours to uphold the Code of ACC Claimants Rights
3.0 ACC philosophy
a You must comply with ACC's philosophy for dealing with client problems, concerns or complaints. This philosophy supports the
Code.
When a client raises a concern or complaint, you must:
• take the concern or complaint seriously
• commit to settling it in a fair, open and respectful manner
• resolve it as quickly as possible
• treat the client with courtesy
• keep the client informed at all stages
• take responsibility for working with the client until the issues are settled.
You must not discriminate against a client because they have raised a concern or complaint. Clients who raise a concern or file
a complaint must not be disadvantaged in any way.
Whenever possible, we should learn from feedback or complaints and find new ways of working if recurring issues or themes
are identified.
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4.0 The purpose of the Code
a The purpose of the Code of ACC Claimants' Rights is to meet clients' reasonable expectations about how ACC should deal
with them. The Code provides a framework that enables us to deliver a high standard of service and fairness to clients. The
Code achieves these objectives by conferring rights on clients and imposing obligations on ACC.
5.0 The spirit of the Code
a The Code encourages positive relationships between ACC and clients. For ACC to assist clients, a partnership based on
mutual trust, respect, understanding and participation is critical. Clients and ACC need to work together, especially in the
rehabilitation process. The Code is about how ACC will work with clients to make sure they receive the highest practicable
standard of service and fairness.
6.0 Exceptions
a The ACC Code of Claimants’ Rights does not apply to:
• dealings with clients before 1 February 2003
• disputes about cover and entitlements, including treatment and compensation, which are addressed through the independent
review and appeal processes
• the provision of treatment services. Treatment services are covered by the Code of Health and Disability Services Con-
sumers’ Rights
• treatment and disability services purchased by ACC. Services purchased by ACC are covered by the Health and Disability
Sector Standards and the Health and Disability Services (Safety) Act 2001
• employee performance issues
• a person who is not a claimant, or who does not have an actively managed claim
The client has the right to review a decision made about their complaint under the Code of ACC Claimants’ Rights. However,
AC Act 2001, Section 149(3) prohibits any further appeal to the District Court against that review decision.
Customer Resolution can investigate matters that do not fall within the scope of the Code. In these cases we will issue a writ-
ten outcome which will not have review rights. However, if the client is dissatisfied with how we have handled their feedback
they can raise a further complaint with the Office of the Ombudsman.
Resolution Services
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Receive and Assess Complaint v5.0
Summary
Objective
To ensure any concerns or complaints shared by a client,
their authorised representative, business customer or provider are captured
and addressed.
Background
All ACC clients, their authorised representatives, business customers or providers can share their concerns about a decision we've
made or the service we've provided. They can make a complaint or discuss their concerns with us. These are managed at local level
(by staff receiving the complaint), or by the Customer Resolution team.
Customer Resolutions work with clients and ACC to resolve issues that have been escalated to them. They will also investigate and
respond to complaints made under the Code of ACC Claimants Rights.
Owner
Out of scope
Expert
Out of scope
Procedure
1.0 Receive and Forward Feedback / Complaint
ACC Staff Member, Resolution Specialist
a Receive complaint or feedback sharing concern.
NOTE What if it was received via phone call and you are a Resolution Specialist?
Go to 3.0g.
NOTE What if it was received via phone call and you are not a Resolution Specialist?
Complaints can be addressed at local level (by the person receiving the complaint of local management.
If the issue cannot be resolved with the client or the client specifically requests, transfer the call to the Customer Reso-
lutions Team via their hunt line 80583 or advise caller to ring 0800 650 222.
This process ends.
NOTE What if it was received via other channels? (Ie Email, heartbeat, letters, social media, etc.)
Complaints can be addressed at local level (by the person receiving the complaint of local management.
Email feedback, concern or complaint to [email address]. This process ends.
2.0 Triage and Allocate Complaint
Resolution Specialist
a Open the allocations spreadsheet and check capacity of Resolution Specialists to ensure equal allocation.
NOTE How do you access the allocations spreadsheet?
The allocations spreadsheet is located in the Customer Resolution Team's shared folder found here: \\ACCFILES\Data
\Branch Servers\Customer Resolution/Triage and Allocations/Resolution Services Triage Allocations 2.xls
NOTE What do you need to consider when allocating?
Consider the current workload of the Resolution Specialist (Ie Do they have complex / code investigations?)
NOTE What time do you need to complete allocations by?
Allocations must be done in the morning by 9am. However, the mailbox must be monitored intermittently throughout
the day as new complaints could come in during the course of the day.
b Check the 'customer feedback' mailbox in Outlook and open the oldest email.
c Review email to determine the rating of the complaint.
NOTE What is a rating?
A rating is used to add weighting to complaints, to ensure an even distribution of work.
NOTE What do you need to consider?
• Is there already an open or recent complaint?
• Has the client made any previous complaints?
• What type of complaint is it? (Ie Chief Executive, Ministerial, Business, Provider, Remote Claims Unit, etc)
• Is the client on a management plan?
• Does the client have a care indicator?
• Is there an advocate involved?
• Will the complaint involve extensive work? (Ie Looking through a large file)
• Is the complaint high risk? (Ie Has it been escalated? Is there media risk?)
• Is the client asking for an investigation under the Code of Claimants' Rights?
• Could this be a potential Code of Claimants' Rights investigation?
Working with the Code of ACC Claimants’ Rights Policy
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NOTE What if there is uncertainty of complaint received and you require additional support?
If there is any uncertainty or complaint requires immediate escalation, advise the Senior Resolution Specialist or Team
Manager.
d Assign a rating to the complaint. Refer to Customer Resolutions Allocation Rating Guide.
Allocation Rating Guide - Customer Resolutions
e In Eos, locate the party record and create a feedback case (for all complaints rated 2-7).
NOTE What if the person making the complaint cannot be located in Eos?
This is called an anonymous complaint. Use the Eos Party record 'Mr ACC Customer Resolutions'.
NOTE What if it is a Remote Claims Unit complaint?
Do not create a feedback case, forward the complaint in an email to Sally Baker or Maureen James (Pseudonym
Resolutions Specialists).
NOTE What if it was rated as a Level 1?
• Do not create a feedback case as it is likely that there will not be multiple actions/interactions on the complaint
• Forward the email to a Resolution Specialist advising 'no feedback case required'.
• Update the allocations spreadsheet
• Go to 2.0k
NOTE What if it is a complaint/concern received by a Business Customer?
In Juno, create a feedback case (for complaints rated 2-7).
f Assign the feedback case to the most appropriate Resolution Specialist and update the allocations spreadsheet.
g Complete all fields in the Task Template.
NOTE Where is the Task Template located?
The Task Template is located in a shared folder and can be found here: \\ACCFILES\Data\Branch Servers\Customer
Resolution/Triage and Allocations/TASK TEMPLATE.docx
h Copy the Task Template information into the email and forward to a Resolution Specialist.
i Copy the Task Template information into the [feedback case]task that has been assigned to the Resolution Specialist.
j Access the Resolution Specialist's task queue and take the task off hold. This will ensure the task is not 'hidden'.
k Move the email from the 'customer feedback' mailbox to the relevant Resolution Specialist's email folder.
NOTE What if it was a Chief Executive complaint?
Add this to the report located in \\ACCFILES\Data\Branch Servers\Customer Resolution/Reports/CE report
NOTE What if it was a Provider Complaint?
Add this to the report located in \\ACCFILES\Data\Branch Servers\Customer Resolution/Reports/Provider report
3.0 Listen, Gather info and Clarify
Resolution Specialist
a Upload the original email received (with complaint information) into Eos using the filing away process. Refer to Inbound Filing
Away of Emails and Email attachments - System Steps.
Inbound Filing Away of Emails and Email attachments - System Steps
b Link the relevant claim to the feedback case.
c Review the complaint information in the email to understand the issue.
NOTE What if it is a Ministerial or Chief Executive complaint?
Notify the Ministerial team or Executive office that you are managing this complaint.
NOTE What if it is an Accredited Employer or Third Party Administrator complaint?
Send an email to [email address] to inform them that you have received a complaint and keep them updated
with the outcome.
If the complaint is a work related claim, please also make the Employer aware of the complaint. The list of employer
contacts can be found on the Accredited Employer Te Whariki page under prime contact.
For all non-work claim complaints – please email [email address]
Accredited Employer Te Whariki Page
d Review claim in Eos or Juno (if it is a Business Customer Complaint) to obtain greater understanding of history and situation.
NOTE What do you need to review?
Familiarise yourself with the claim by reviewing contacts, documents and tasks in Eos; or Interactions and documen-
tation in Juno.
e Contact relevant business unit to advise that a complaint has been received.
f Acknowledge complaint has been received by making contact with the person who made the complaint (within 48 hours where
possible) and save contact/interaction note including any documents in Eos or Juno.
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NOTE What do you do to acknowledge the receipt of a complaint?
You can acknowledge the receipt of the complaint via:
• Phone call
• Email or
• In writing, using the COM03 letter in Eos.
COM03 Acknowledgment of your complaint
g Discuss the issue/complaint with the person who is making the complaint (to understand from their point of view), what is the
issue/concern and what outcome is being sought.
NOTE What if complaint resolution is achieved on the call?
Go to 7.0g.
h Advise them of the next steps to be taken, including expected timeframes. Set clear expectations with the client around how
they would like to be communicated with throughout the process. (Ie Does the client want regular updates?)
i Record details of the conversation in Eos or Juno and create a feedback case or dissatisfaction contact, if required (Ie a feed-
back case may not have initially been created).
4.0 Investigate complaint
Resolution Specialist
a Determine what type of complaint it is (Ie Is it code or non-code?). Refer to Working with the Code of ACC Claimants' Rights
Policy.
Working with the Code of ACC Claimants’ Rights Policy
NOTE What if it is a code complaint?
• Create the ACC7407 Complaints investigation issue history form.
• Ensure each of the issues for investigation are recorded separately on this form as well as in the Eos feedback case.
ACC7407 Complaint investigation issue history
NOTE What information do you need to add to the ACC7407 Complaints investigation issue history form?
The form needs to clearly show the information you have gathered and considered as part of your investigation that
will determine the outcome decision you make.
NOTE What if it is a service complaint that can be resolved by another unit?
• Forward to the appropriate Team Manager in the relevant business unit
• Advise client of next steps
• Go to 7.0g.
b Consider whether you need to seek advice/input from another business unit to help in your investigation.
NOTE What are other business units or teams that you may consider?
• Branch/Sites/Hubs
• Privacy team
• Technical services
• Clinical services
• Legal Services
• Government Services
• Accredited Employers
• Third Party Administrators
NOTE What if you need input from a business unit?
Call or send task as appropriate.
NOTE What if it is a complex complaint or code investigation relating to a privacy issue?
Send an email to [email address] with the following information:
For Resolution Services to complete
Resolution Specialist/Review Specialist:
Customer name:
Claim number:
Relevant ministerial, government services or review identifier:
Date complaint/review received:
Factual summary and timeline
Please include relevant privacy history including previous privacy advice.
Privacy advice required:
Privacy Team to complete
Privacy Advisor:
Privacy advice:
Any other comments/considerations:
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c Complete a full review of the claim file(s), party record and all other relevant information you have been provided from other
parties.
d Document all steps of the investigation in Eos or Juno.
NOTE What if it is a code complaint?
• Update the ACC7407 Complaints investigation issue history form
• Upload the ACC7407 form to the feedback case in Eos.
5.0 Identify Outcome
Resolution Specialist
a Determine the outcome of the investigation.
Working with the Code of ACC Claimants’ Rights Policy
NOTE What if there was a breach?
Discuss best approach and course of action (Ie apology or remedy) with Team Manager in the relevant business unit
and record in Eos.
NOTE What if it is a Ministerial or Chief Executive complaint?
Email the Ministerial team or Executive office to advise the outcome.
NOTE What if it was a dissatisfaction or non-code complaint?
• Go to 5.0c if it was a complex complaint and a letter needs to be sent
• Go to 7.0d if it was a non-complex complaint and a letter is not required
NOTE What if you are unsure or would like further input on the outcome determined?
Check with a colleague, a Senior Resolution Specialist or Resolution Team Manager.
b Finalise the ACC7407 Complaints investigation issue history form and consider all the evidence you have found in your inves-
tigation.
c Create the COM01 Findings letter.
COM01 Your complaint - Findings
d Email draft COM01 Findings letter to the Senior Resolution Specialist or Team Manager for checking.
6.0 Review Outcome
Resolutions Services Team Manager, Senior Resolution Specialist
a Review the COM01 Findings letter and provide feedback, if any.
NOTE What do you need to check?
Check rationale and findings, as well as spelling and grammar.
b Email the COM01 Findings letter back to the Resolution Specialist with feedback.
7.0 Advise Outcome and Close Complaint
Resolution Specialist
a Receive COM01 Findings letter back and make any updates/changes, or re-investigate complaint as required.
b Upload the COM01 Findings letter to the feedback case in Eos.
c Email a copy of the COM01 Findings letter to the Team Manager of the relevant business unit.
NOTE What if it was a Ministerial or Chief Executive complaint?
Email the Ministerial team or Executive office to advise the outcome.
d Contact the person who made the complaint to discuss and inform them of findings and/or outcome decision.
e Record details of the conversation in Eos or Juno.
f Send COM01 Findings letter (if it is a code complaint) to the person who made the complaint.
g Complete the feedback case e-forms and close task to ensure complaint is closed.
NOTE What if there was no feedback case created?
Ensure contacts and any outgoing documents are captured in Eos or Juno.
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Document Outline
