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The Child Support Program's Management of Feedback
The objective of the audit was to examine the effectiveness of CSP’s feedback management system. CSP’s performance was assessed against the following criteria:
- CSP has appropriate channels to collect customer feedback;
- CSP effectively manages and resolves complaints; and
- CSP accurately reports on customer feedback, and analyses the information to improve aspects of child support administration.
1. The Child Support Agency was established in 1988, as part of the Australian Taxation Office, to administer the Child Support Scheme and assist separated parents to transfer child support payments. In 2004, the Child Support Agency became part of the Department of Human Services (DHS) and its services are now referred to as the Child Support Program (CSP).
2. The introduction of the Child Support Scheme was designed to address concerns about the poverty of women and children following separation and divorce; and the increasing government expenditure required to support children whose parents were not meeting their financial obligations.1 The Child Support Scheme provides an administrative avenue to determine and enforce the transfer of child support payments between separated parents, without the involvement of courts.
3. CSP can assist separated parents with the calculation, collection and transfer of child support (CSA collect), or can calculate the amount of child support payable and leave it to separated parents to directly transfer these payments (private collect). The objective of CSP is to:
ensure that both parents contribute to the cost of their children, according to their capacity.2
4. During 2010–11, the total amount of child support transferred between separated parents was $3.1 billion for 1.2 million children.3
5. The Child Support (Registration and Collection) Act 1988 and the Child Support (Assessment) Act 1989 govern the administration of the Child Support Scheme. The Department of Families, Housing, Community Services and Indigenous Affairs (FaHCSIA) is responsible for developing child support legislation and policy.4
6. DHS is responsible for the development, delivery and coordination of government services, and the development of service delivery policy. In July 2011, the Human Services Legislation Amendment Act 2011 integrated the services of Centrelink and Medicare into DHS. The integration formed part of the Service Delivery Reform program5 and is designed to provide a more efficient and effective service delivery model that gives customers convenient access to services. This includes co-locating a number of Centrelink, Medicare and CSP offices to provide one-stop-shop access to departmental services.
7. As part of a sound approach to public administration, agencies should actively seek to design and implement processes and systems that support efficient and effective service delivery. It is also important that agencies use customer and stakeholder experiences to inform a cycle of continuous improvement. One way of gathering these experiences is through a feedback system.
8. Feedback can be in the form of complaints, compliments and suggestions. Feedback, particularly complaints, can be a good indicator of the effectiveness of service delivery and customer confidence in an agency. By establishing robust mechanisms to collect and manage customer feedback, Australian Government service delivery agencies can address customer dissatisfaction and identify improvements to systems and processes.
9. An effective feedback management system is timely, objective and incorporates:
- accessible channels for customers to provide feedback, and referral and categorisation processes to manage feedback appropriately;
- training and guidance for staff that includes an emphasis on consistently recognising and recording feedback, investigating customers’ issues and communicating with customers at key points in the complaints management process;
- escalation and review processes, quality assurance checks and balanced performance indicators to ensure accuracy and consistency of outcomes; and
- relevant analysis and accurate reporting of feedback information so that business improvements can be identified.
CSP’s feedback management system
10. CSP encourages customers and stakeholders to provide feedback on the services it delivers. This is consistent with the broader DHS approach to feedback reflected in a publicly available service commitments document which promotes, among other things, ‘genuine consultation’. Genuine consultation represents a positive attitude that conveys to customers and stakeholders a commitment that:
We value your feedback and will work with you to understand how to improve our services.6
11. Customers can provide feedback to CSP directly or through third parties, such as the Minister for Human Services (the Minister), a Member of Parliament, the Commonwealth Ombudsman (the Ombudsman) or a stakeholder group.
12. CSP also receives feedback directly from stakeholder groups. One of the feedback avenues available to stakeholder groups is the Child Support National Stakeholder Engagement Group, which is a meeting held three times a year convened by DHS, in conjunction with FaHCSIA. During these meetings, issues specific to individual cases as well as emerging issues concerning service delivery, policy and legislation are raised and discussed.
13. While CSP receives compliments and suggestions, complaints represent the majority of feedback.
14. Complaints can be used to address customer dissatisfaction. Complaints can also be used to identify service delivery improvements as, collectively, they provide a measure of program and administrative effectiveness. That is, improvements to service delivery based on complaint information may lead to a corresponding reduction in complaint numbers as customer satisfaction increases.
15. Complaints can be lodged through a number of different channels:
- CSP’s general enquiries or dedicated complaints telephone lines;
- in writing;
- CSP’s web-based service portal, known as CSAOnline7; and/or
- in person at a CSP office.
16. In managing complaints, CSP uses a range of staff and teams, and has a framework based on a three-step model. How a complaint is classified within the three-step model can depend on a number of factors, including: the channel used to lodge the complaint; the party lodging the complaint (that is, either the customer or a third party on the customer’s behalf); the nature of the complaint; and whether the complaint has previously been investigated. Broadly, the three-step model comprises:
- Step 1: a customer makes a complaint directly to CSP and this is received and investigated by a customer service officer (CSO);
- Step 2: if a customer is dissatisfied with the outcome of a step 1 complaint, the complaint is escalated to a team leader for further consideration. However, step 2 is not simply an escalation point, and all complaints regarding staff behaviour are automatically referred to step 2 without the need to pass through step 1; and
- Step 3: if a customer remains dissatisfied with the outcome of a step 2 complaint, the complaint is further escalated to a Complaints Services team for consideration. In addition, certain complaints are referred directly to Complaints Services teams as step 3 complaints, including complaints received through the dedicated complaints telephone line8; step 1 complaints referred directly by a CSO9; and complaints received from third parties.10
17. Complaints to CSP relate to a range of issues, including service delivery, staff behaviour, and child support policy and legislation. While customers can complain about the decision-making process, for example, the level of consultation involved or the time taken to make a decision, CSP’s complaints management system does not involve reviewing decisions. Instead, customers who are seeking a review of a decision are referred to a separate process.11
18. In finalising a complaint, an officer must consider each of the issues and then decide if the complaint is upheld, partially upheld or disallowed.12 In 2010–11, 70 per cent of step 2 and 3 complaints were disallowed.
19. Finalising a complaint does not necessarily involve resolving the issue which generated the complaint. The work associated with addressing the issue underpinning the complaint can be followed-up or referred for action while investigating the complaint, or after it is finalised. Importantly, due to their nature, some complaints may never be resolved to a customer’s satisfaction. These could include complaints about threshold matters such as policy or legislation.
Compliments and suggestions
20. Compliments and suggestions can be made through the same channels as complaints. Compliments are managed on an individual basis and are provided to the relevant CSP staff member or their team leader.
21. Until recently, CSP managed suggestions through a number of electronic mailboxes where staff could lodge either customer suggestions or proposals of their own. In June 2011, CSP commenced trialling a new intranet-based recording and tracking system for suggestions called the iRegister. Staff can record all suggestions in the iRegister, which are then forwarded to the relevant business line for consideration and action. Based on the success of the trial, CSP advised that it intends to roll-out the iRegister functionality to all staff by June 2012. CSP also collects suggestions from customers through its phone based customer satisfaction survey—Customers Having a Say (CHAS).
22. The objective of the audit was to examine the effectiveness of CSP’s feedback management system. CSP’s performance was assessed against the following criteria:
- CSP has appropriate channels to collect customer feedback;
- CSP effectively manages and resolves complaints; and
- CSP accurately reports on customer feedback, and analyses the information to improve aspects of child support administration.
23. The audit scope did not include an examination of the process that customers are referred to when they request CSP to formally review a decision, such as a child support assessment.
24. The Child Support Scheme helps over 1.4 million separated parents provide ongoing financial support for their children’s wellbeing. In 2010–11, CSP assisted with the transfer of $3.1 billion between separated parents, to support 1.2 million children. The sensitivities of the policy area and the nature of the relationships mean the administration of the Scheme necessarily requires adherence to legislative and policy requirements, and an understanding of all parties’ circumstances.
25. Capturing and using feedback is consistent with the public expectation that the Australian Government deliver high quality services that are client-centric and developed in consultation with users.13 In March 2010, an advisory group to the Australian Government presented its plan for reforming government administration. The plan identifies better services as one of nine proposed major reforms, all of which were accepted by the Government in May 2010.
26. Consistent with these reforms, DHS has made a commitment to quality customer service, including delivering fair and transparent services that are easily accessible, and providing consistent and accurate advice to customers.14 CSP relies on complaints as one useful means of gauging customers’ satisfaction with its service delivery and has a range of performance indicators to inform this measure, including reducing the number of complaints as a percentage of the number of customer cases. Feedback, whether it is complaints, compliments or suggestions, can play a key role in promoting better services through addressing customer dissatisfaction and highlighting areas for business improvement.
27. CSP’s feedback management system is effective in that key characteristics of the system include: a range of channels for providing feedback; a framework for recording, managing and responding to feedback (including a three-step model for managing complaints, as previously mentioned); and a process of reporting and analysis of feedback information which is used to improve services. There are however, some areas where the framework and existing practices could be improved to assist CSP to build on the quality of child support services available to customers.
28. The majority of feedback received by CSP is in the form of complaints. In 2010–11, CSP finalised 17 110 complaints, consisting of 3077 step 1, 6318 step 2 and 7715 step 3 complaints. This result continued the trend of declining complaint numbers since 2008–09. In recent years, the issues that have generated the highest numbers of complaints are: allegations that CSP staff failed to action cases; customer concerns with CSP’s decision¬-making process; staff behaviour perceived as being unprofessional; and disagreements about the fairness or affordability of a child support assessment.
29. CSP classifies all complaints according to a three-step model. The three-step model provides customers with access to an internal review mechanism if they remain dissatisfied after a complaint has been investigated. Since September 2011, the model has also incorporated a prioritisation approach where staff are required to identify those complaints that would benefit from immediate attention and resolution.
30. Under the model, rather than categorising complaints based on complexity or sensitivity, categorisation depends on a number of factors such as the channel used to lodge a complaint and whether a complaint has been escalated through the complaints process. This adds to the overall complexity of the model and results in situations where complaints of the same character are classified differently and managed by different staff.
31. The three-step model has some factors which limit the conclusions that can be drawn about the number and nature of complaints at each of the steps. This reduces CSP’s ability to interrogate the data and identify potential training opportunities and process or systems changes, which could improve service delivery and address any systemic issues. Three key areas where the model could be improved to address the limitations identified are:
- Promoting the consistent recording of all step 1 complaints to provide a more complete information set.
- Classifying complaints based on their complexity or sensitivity rather than the channel through which they are lodged, so that complaints are appropriately managed or referred in the first instance.
- Understanding the number and nature of complaints that are escalated through steps 1 to 3 if a customer is dissatisfied with the outcome at the previous step; and those initially classified as step 2 or 3. This could assist to identify staff training requirements and improvements to the complaints management system.
32. CSP’s collection, investigation and resolution of complaints is supported by: training and guidance; the three-step model; a feedback mechanism for staff; and recently introduced quality assurance activities. CSP has demonstrated an increased focus in these areas in recent years and has also undertaken initiatives, such as complaints management workshops for staff, to reinforce the important and beneficial role feedback can play in improving services.
33. Ongoing and clear communication with parties who have lodged a complaint is an important part of achieving a successful outcome. Existing training and guidance material could be strengthened in this regard to more clearly outline the expected level and frequency of communication by staff with those people who have lodged a complaint.
34. In order to effectively use complaints information to improve overall service delivery, staff should receive feedback on the outcome of complaints, particularly those that are upheld. For those step 2 and 3 complaints that are upheld, CSP’s procedures outline that staff should receive feedback forms containing information about any issues identified by the investigation and subsequent areas for improvement. These forms are also expected to be used to provide feedback where staff have displayed excellent customer service. While this process provides a framework for effectively informing staff members about their performance, currently, CSP is unable to track if the process is being followed as intended. Through centrally recording, analysing and reporting on the information contained in the feedback forms, CSP could more effectively use the investigation insights to identify business-wide issues and better practice, which could be addressed or shared (for example, through training and guidance).
35. CSP uses two main performance indicators for feedback. The first relates to reducing the number of step 3 complaints. Through using a performance indicator based on complaint numbers, CSP is linking increased customer satisfaction with the Child Support Scheme and its administration, with lower levels of complaints. In 2010–11, CSP achieved three of its four performance targets relating to reducing the numbers of step 3 complaints. This included reducing the number of complaints as a percentage of the number of customer cases. The performance indicator not achieved related to reducing the number of complaints from Members of Parliament and the Ombudsman as a proportion of total complaints.
36. The second performance indicator relates to assessing the operation of the complaints management system, and measures the time taken to finalise complaints. In 2010–11, 77 per cent of customer complaints were resolved within the 14 day target. The focus on quantitative indicators such as volume and timeliness is important when managing complaints, however, other administrative characteristics, such as fairness and accuracy, are also important. Introducing complementary qualitative performance indicators for complaints management would help provide CSP assurance that the system is operating as intended and delivers accurate and consistent outcomes to customers.
37. CSP collects and internally reports a variety of information relating to the performance targets and other areas such as common issues underpinning complaints. CSP’s external reporting through the DHS Annual Report is limited to the number of step 3 complaints received. In order to improve transparency and provide greater information to external parties, CSP could draw on the existing data collected as part of internal reporting to expand the range of feedback information provided in annual reports.
38. Feedback information can be valuable to agencies if it is analysed and used to identify business improvements. CSP periodically uses feedback information to improve business systems and practices. This feedback is generally limited to step 3 complaints. By expanding the focus to include all complaints and comparing this information with the feedback received through other sources (including stakeholder groups and customer surveys), CSP could better identify and prioritise improvements based on factors such as commonality and urgency.
39. In administering the Child Support Scheme, CSP staff can be faced with many difficult circumstances, including making financial determinations and interpreting the care arrangements of parents. Capturing and learning from feedback can help to build on the current service delivery approach and provide lasting benefits to both customers and staff.
40. The ANAO has made five recommendations directed at supporting CSP’s capture, management, and use of feedback on the child support services administered by the department. In this context, the Service Delivery Reform program provides DHS with a timely opportunity to consider the role and effectiveness of CSP’s feedback system; in particular, through sharing and adopting better practice across the services delivered by the department.
Promotion, collection and categorisation of customer feedback (Chapter 2)
41. CSP collects feedback through a range of channels and promotes the complaints management system through the CSP website and an online publication—Objections, complaints and reviews – your rights following Child Support Agency decisions. While the feedback channels available are diverse, to prevent cost being a barrier to receiving feedback, CSP could investigate providing customers with cost-free options for lodging feedback, similar to those used by other services in DHS. Further, by expanding the level of information provided, and including information on feedback options in key publications (such as newsletters and high-volume letters), CSP could better promote its system and commitment to receiving feedback.
42. To support the recognition and collection of feedback, CSP has a high-level definition of a complaint and provides examples relating to the three-step model to staff. CSP’s three-step model enables customers to have their complaints reviewed if they remain dissatisfied after a complaint is investigated.
43. Generally, in a three-step model where customers are encouraged to follow a process, it would be reasonable to see a progressive decrease in the number of complaints at each level. In 2010–11, the number of complaints finalised increased with each step, which could indicate that complaints are not being resolved at the lower levels. However, there are a number of factors that limit the conclusions that can be drawn from the figures, including: step 1 complaints are not consistently recorded; complaints are not classified according to their complexity or sensitivity; and CSP is currently unable to track escalated complaints. These factors impact on the reliability and usefulness of complaints information to identify areas such as staff training requirements and business improvements.
44. Within the three-step model, CSP has recently introduced a prioritisation framework for complaints. CSP also applies two approaches to categorising complaints; one approach for step 1 complaints and another approach for step 2 and 3 complaints. Categories within these two approaches do not align and consequently, CSP cannot easily identify the issues that generate the most complaints. Adopting a uniform categorisation approach for all complaints could assist CSP to effectively analyse the information and identify complaint trends.
Feedback management and complaints resolution (Chapter 3)
45. CSP provides staff with a range of training and guidance to support feedback management and complaints resolution. Building on the work undertaken in recent years, including conducting complaints management workshops, CSP could identify other ways for staff to share experiences. For example, staff who manage step 1 and 2 complaints could benefit from engaging with those staff who manage step 3 complaints to identify how their experiences could translate to improving the resolution of step 1 and 2 complaints and so avoid their escalation to step 3.
46. Based on procedural instructions and processing guidelines, CSP has an established framework for investigating and resolving complaints. Staff are encouraged to resolve complaints at the first point of contact. Where complaints cannot be resolved at the first point, CSP could improve the efficiency of its system by assessing the complexity of a complaint and referring it to the most appropriate point of management, rather than escalating allcomplaints in a similar manner through the system.
47. CSP’s complaints management system incorporates a feedback mechanism to advise staff where improvement is required or where work was well done. This feedback process is targeted at the individual staff member. If centrally collated and analysed, the information collected could also assist CSP to identify and act on common staff development requirements and business-wide issues.
48. Prior to July 2011, CSP had limited quality assurance measures for complaints management activities. In July 2011, CSP introduced a new quality assurance framework across the business. Complaints management activities are subject to the new processes, which include the random and targeted selection and review of work—both upheld and disallowed complaints.
49. CSP does not directly measure customer satisfaction with the complaints management process. Implementation of a survey or other measures, such as focus groups, aimed specifically at customers who have lodged comlaints, could allow CSP to identify potential improvements to the complaints management system.
Reporting and business improvement (Chapter 4)
50. CSP assesses two main types of performance indicators using complaints information. The first relates to customer satisfaction with CSP’s administration of the Child Support Scheme and is measured by complaint numbers. For example, CSP aims to reduce the number of step 3 complaints, as a measure of increased customer satisfaction. The second group of performance indicators relate to the time taken to resolve a complaint, which is one measure of the effectiveness of the complaints management system.
51. The current performance indicators focus on quantitative measures. Developing complementary qualitative measures that consider issues such as the effective resolution of complaints and customer satisfaction with how a complaint is managed could improve the performance indicators and provide incentives for staff to investigate and resolve complaints consistent with these principles. A wider range of performance indicators would also help provide assurance to CSP that the complaints management system is providing accurate and consistent outcomes to customers.
52. CSP produces detailed internal reporting on the number and type of step 2 and 3 complaints. In 2011–12, CSP also commenced reporting on the number of step 1 complaints. However, the accompanying analysis of the complaints data focuses on step 3 complaints, which can limit the conclusions drawn. By analysing all complaints information (that is step 1, 2 and 3 issues) and comparing this information with feedback from other sources, CSP could better identify the underlying drivers of customer dissatisfaction, or weaknesses in systems and processes, and subsequently prioritise business improvements.
53. In contrast with the detail of CSP’s internal reporting on complaints, the level of information included in external reports is limited. For example, the only information included in the 2010–11 DHS Annual Report was the number of step 3 complaints finalised. CSP could improve its external reporting by incorporating information about all complaints, suggestions and compliments received; common areas of customer concern and any strategies being implemented to address them; and performance against the timeliness targets set to finalise complaints.
54. Stakeholder feedback can provide useful insights to CSP which reflect customer experiences and expectations. CSP uses the Child Support National Stakeholder Engagement Group meetings, which are held three times a year, as a means to gather this information. While there has been an improvement in stakeholders’ satisfaction with CSP’s use of feedback information, CSP could enhance its engagement with stakeholders to confirm that issues raised have been adequately addressed.
55. The Department of Human Services (the department) agrees with the recommendations of the audit of Child Support’s management of customer feedback. These recommendations will assist the department to further review and develop its procedures, particularly within the context of the integration of the Child Support, Centrelink and Medicare services. The department is pleased that the ANAO has acknowledged the overall effectiveness of the current feedback management system and that the department has already taken steps to address the issues raised in the report.
 Commonwealth of Australia, Human Services Portfolio: Portfolio Budget Statements 2011–12, Canberra, 2011, p. 39.
 Department of Human Services, Department of Human Services Annual Report 2010–11 [Internet]. DHS, Canberra, 2011, available from <http://www.humanservices.gov.au/spw/corporate/publications-and-resource…; [accessed 26 October 2011].
 Department of Families, Housing, Community Services and Indigenous Affairs, Child Support: Overview [Internet]. FaHCSIA, Canberra, 2010, available from <http://www.fahcsia.gov.au/sa/childsupport/overview/Pages/default.aspx>
[accessed 24 February 2012].
 Announced in December 2009, and running until 2021, the Service Delivery Reform program has three objectives: to make people’s dealings with government easier through better delivery and coordination of services; to achieve more effective service delivery outcomes for government; and to improve the efficiency of service delivery.
 Department of Human Services, Our Service Commitments [Internet]. DHS, Canberra, 2011, available from <http://www.humanservices.gov.au/corporate/about-us/service-commitments/> [accessed 3 April 2011].
 CSAOnline is a secure online service option available through CSP’s website where a customer can view their correspondence and payment summary, and lodge feedback.
 In contrast, complaints received from the general enquiries line are classified as step 1, without any clear rationale for the difference in approach.
 Complaints can be directly referred by a CSO when: the customer declines a call back from a team leader; the customer requests to talk to the Complaints Services officer; and the complaint is being managed by a team leader in a Regional Service Centre and the customer is dissatisfied with how the complaint is being managed or the team leader does not have access to the Cuba system.
 Complaints received from external parties are managed by Customer Review teams, which are separate from Complaints Services teams.
 This process is known as objections. An objection is a request to CSP to formally review a decision.
 Upheld: all issues relating to the complaint are upheld. Partially upheld: some but not all issues are upheld. Disallowed: no issues are upheld.
 Advisory Group on Reform of Australian Government Administration, Ahead of the Game [Internet]. Commonwealth of Australia, Canberra, 2010, available from <http://www.dpmc.gov.au/publications/aga_reform/aga_reform_blueprint/doc…; [accessed 18 January 2010].
 Department of Human Services, Our Service Commitments [Internet]. DHS, Canberra, 2012, available from <http://www.humanservices.gov.au/corporate/about-us/service-commitments/…; [accessed 16 April 2012].