Act and Code Review – Supporting timely, people-centred
resolution
Notes
Date / Time /
21 November 2023
Location
Attendees
Tui Taurua (NAMHSCA and HDC’s Consumer Advisory Group);
Sue Claridge (AWHC and Health Consumer Advocacy Al iance);
David Dunbar (Medical Council NZ); Louise Grant (Advocacy
Service); Bronwen Scott (Advocacy Service); Edna Havea (Phd
Candidate / lecturer and Te Tāhū Hauora Kōtuinga kiritaki); Sam
Powel (Aged Care Association); Danae (InsideOUT); Tristram
Ingham (Te Ao Mārama); Ann Buckley (HQSC); Alison Eddy (NZ
Col ege of Midwives); Martin Thomas (HQSC); Dianne Black
(NAMHSCA); Rebekah Graham (PVINZ); Gabriel Lau (Royal
Australasian Col ege of Radiologists)
HDC Attendees
Catherine McCul ough; Deborah James; Charmaine Pene;
Vanessa Lin; Kylie Arihi; Jane Carpenter; Ikimoke Tamaki-
Takerei
Introduction
Catherine welcomed everyone and thanked people for their time. Kylie opened with mihi
and karakia.
As part whakawhaungatanga attendees were asked to share what was most important to
them to improve complaints processes:
- Length and Māori voice
- Lack of right to appeal HDC decisions (important for both consumers and providers)
- Human-centric process that is visible and continuous for the consumer and
practitioner and provider. Seamless journey that is safe for al participants
- For consumers to feel empowered and have a voice. Looking at how can we make a
complaints process / raising concerns safer for consumers and providers. How can
draw people into a process that is daunting, particularly consumers who are too
afraid to have a voice and for providers
- Process that is accessible, have no fear, and engagement by providers to not feel
and/or the Privacy Act 2020
like a victim and can engage with the resolution process.
- Keen to understand restorative processes and how can be used better
- Balance of safety and care of providers and the impact of adverse comments on
providers
- Easier and less stressful for rainbow and takatāpui whānau
Information released under the Official Information Act 1982
- Paradigm shift away from deficit and adversarial processes to learning opportunities
and languaging
- Increase in clarity and accessibility for consumers to engage with the Code and
know where and when to go to HDC compared to providers
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- Mana-enhancing process for al – see downstream effect of losing members of
profession because processes of complaints can be denigrating
- Would like to see improvement in communication and timing
- Need to improve learnings from complaints when things go wrong and embed across
system
- Want to see complaints heard and feel respected even if complaints are declined
- Shift away from the burden on the individual to make formal complaints to a system.
Explore other ways to explore complaints at a system level
- Chal enges with bias in smal cohort of oversight and the benefit of hindsight.
Principles of complaints resolution
Questions:
Are the four principles for complaints resolution “fair, simple, speedy and
efficient” stil fit for purpose? Why / Why not?
Should a requirement to ‘enhance mana’ be included as a principle for
complaints resolution? Why / why not?
Are there any other principles we should consider? Why?
- Like the four principles. Clear. But on reflection, are also transactional. Love making
more person and whānau-centred through mana-enhancing. Would also like to see
addition of learning opportunity. How can they influence systemic change.
- Simple and speedy important, but have to keep people at the centre, and don’t want
to compromise natural justice.
- How do you legislate for how people conduct themselves in a mana-enhancing way
- Four principles are important, but fair has often been sacrificed for speedy and
efficient. Inherent power imbalance
- Complainant doesn’t have the right of response to cross examine the provider –
comes back to how articulate the complainant is to lay out the issue. Power
imbalance. Another principle should be that complainants should have the right to
respond to and cross-examine the response of the provider
- Agree list sounds transactional. Element of learning.
- Appreciate that mana not a zero-sum gain
- If list becomes longer than four could become muddled – maybe separate out human
component and procedural aspects
- Fairness could be tightened in terms of learning
and/or the Privacy Act 2020
- Tautoko mana-enhancing and advocate of hohou te rongo and the review of adverse
events policy
- Essence of the principles fine but the way that communicated and described not
person-centred – speedy could be seen as rapid and without due care. Important
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that language is meaningful in and of itself
- Is very process focused – missing human element. Don’t see
safety in there.
Cultural y safe. Not just ethnicity. Holistic approach in process and reflect that
whānau focused and about people. Definition of ‘fair’ is not fair.
- Safety supported as a necessary principle. Eg boundary violations.
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- If paradigmatic change of how complaints are seen is that there needs to be a
change in language and expectation. Eg raising / reporting issues
- Feedback rather than complaints would change the wairua
- Where is it that al in it together and shows Te Tiriti? Mana Motuhake – how do we
get to determine ourselves in this process. Manaaki – how is everyone in the
process looked after, including staff. Missing those types of concepts in this kōrero.
Legislation is words and not the process.
Right to complain (Right 10)
Questions:
What is your experience of how wel provider complaint processes (as set
out in the Code) are working?
What options should we consider to improve provider complaint processes?
- Within advocacy service having a clear understanding that should they go directly to
provider wil be dealt with in faith. That Advocacy is taken seriously by the provider
when dealing with the consumer’s issue(s).
- Maintain consumer’s feeling that they wil be respected when going to a provider.
How do we encourage them to have faith in the provider/process.
- Risk of retaliation to the consumer. E.g limited number of providers for the
consumer.
- Consumer experience their complaint has been put on their medical records, and
labeled “difficult”, and could fol ow them to another provider.
- Need to explicitly prevent provider retaliation. Some providers deny the person the
right to give permission or informed consent. Retaliation can take a wide variety of
form.
- Yes to less prescriptive and more principled based.
- Some consumers are traumatised when taking a complaint. Some expectations for
consumer when raising a complaint wil be different - so principle based rather
prescriptive.
- Professionals ‘ / provider have a duty of care. Who is taking responsibility for
providing duty of care for the consumer who is going through a complaint process.
This should be spelt out.
- The process is not transparent / user friendly and puts the complainer at a
disadvantage.
and/or the Privacy Act 2020
- (Provider) Duty of care is to ensure complainants have an empowering experience
and not disempowered and its not a tick off process.
- Provider induction needs to include the ‘complaint’ process face to face and not just
hand out a brochure or show a poster. Face to face korero is much more available to
the consumer and it stays with them and is whanau focussed. It is friendlier.
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- What is retaliation? And who monitors, what do you do if a breach? Stil doesn’t deal
with power imbalance. Right not to do something is more difficult to enforce. Should
be able to complain
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- How do we support people to make complaints. Having a navigator to rebalance
power.
- Group think and different paradigm - sense here that don’t trust the provider to think
differently to the individual who makes the complaint - complaints process (and
assessors) is biomedical. Involvement of the complainant in determining who are
‘experts’ - i.e. who would be good to be an assessor of the process. Who’s voice is
to be valued here. Eg disability rights. Assessors may be thinking from a medical
rather than a multidisciplinary approach. Especially if a systems issue, determinants
of health, policy, UNCRPD, consideration of tikanga etc.
- Real need to consider right for protection against retaliation. Have felt unsupported
by HDC when retaliation has occurred.
- While Code says that a person should not be adversely affected by making a
complaint, does not happen in practice
- Not just in the Code, but in the approach, raising support
- Making a complaint is a lonely process and needs to be done in different ways
around the individual’s needs. Feeling supported al through the process. Dejected
when turned down, but if someone touches base then can be supported
- Navigation can extend to providers - need to support and understand how wil unfold
- Yes, should be protection against retaliation. Needs to be very clear and very explicit
provision. Needs to spel out what retaliation looks like and what you can do if that
happens. Sometimes there is an implied threat - needs to be clear that this is just as
bad.
- How do we define retaliation?
- Sometimes ending therapeutic relationship is in the best interests of al
- There is no screening for clearly vindictive claims
- What can we do to protect everyone’s mana
- When people make a complaint - often there is a lot of information / but the key issue
is just one part of it but they include a lot of their own experience and it can be very
damaging for the provider
- There isn’t an alternative process for a consumer to just vent and relay their
experience
- When providers are reading the complaint letter - there is a significant personal
impact on the individual provider
- Have we lost a bit of balance?
- Providers are also vulnerable and want to correct what has happened / learn from
complaints
- Preference is for consumers to go to providers with their concerns first. But reality is
and/or the Privacy Act 2020
that people often won’t
- Can HDC have a more restorative process -have kaumatua supporting both sides in
a process. Swap stories about how each side is feeling. Finding a way forward for al
parties.
- Would hate to see more time added for the consumer. Need to keep the system
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moving
- Keep timeframes in Right10
- What processes do we have for supporting people when we aren’t taking action on
their complaint?
- The hui a whanau process should be available to al consumers
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- Should there be an opportunity throughout the entire process for hui a whanau to be
included
- Current process is very narrow/procedures - assessment→ complaint Y/N
-
Consumer experience (particularly women), get frightened when approaching a
provider about a concern e.g., medical injury with a particular medical advice and
procedure, adverse event. They can be advised, its in their head, they are fobbed
off, its mental health and its their problem (not the provider). This traumatises the
consumer. And the idea for them to resolve the issue with the provider. But they
would back off from this. So it should be an idea but not required for them to go to
the provider.
-
Advocacy service wil provide support to consumer and where the complainant’s
concern has been minimised or notes made about them they can go to an advocate
to resolve.
-
Advocacy isn’t always able to resolve the issue but wil work with the consumer in
writing a complaint and identifying the issues (usual y listed). Provider must respond.
-
Safeguards; structure provided by advocacy.
-
How can you complain to the very people that have wronged you. What would help,
they should have someone neutral, to lodge the complaint with the provider. They
feel disempowered / discriminate and already on the backfoot.
-
Sensitive case - need to be aware of process, be able to have information to provide
safety
-
No - shouldn’t be required. But recognising that attempting resolution is likely to be a
better outcome but may not be a realistic process for people
-
-
No, don’t think there should be a requirement to go to providers first. Most people
have tried to resolve things without making a formal complaint. Just lengthens
process. Very disheartening for people
-
Should have easier process for lodging a complaint
-
People often think they’ve made a complaint because they’ve had a conversation
with an employee of the service - but then there is no record of it
-
Lack of clarity around what a formal complaint looks like
-
Just having a conversation with a support worker is not a formal complaint
-
Very unfair to expect this of consumers
-
People need to be an assigned an advocate to support them to know where they can
take their complaint and distil their complaint to issues that can be addressed
-
Should have a central point of contact across the whole system
-
Hard no for trans and gender diverse community - having that as a requirement is
and/or the Privacy Act 2020
not feasible
-
Very personal and intimate situation
-
Would be a barrier for consumers if they were required to lodge a complaint first with
providers
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-
Greater clarity about process overal is needed.
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Advocacy services
Questions:
What is your experience of how wel the advocacy service is working for
people and providers to resolve complaints?
What do you think are the most important changes that could be made to
strengthen advocacy services? Why?
- PVI - Most have never heard of Advocacy Service before. A lot parents don’t know
that they are entitled to access this service
- Aged Care - aware of Advocacy service. Often direction of HDC to utilise Advocacy
service
- Many people are not aware of Advocacy Service.
- Parents/other whanau member making complaint on behalf of child
- Midwifery - mixed level of knowledge of Advocacy Service. The way the service is
understood - some people don’t want the same thing to happen to other people. The
way the service is described is quite important. Many complaints HDC receives
might be better managed by Advocacy Service. Public perception might have a
different view of Advocacy and what they do.
- HDC wil sometimes refer matters into Midwifery resolution process. We need to
socialise these processes more and make them more accessible to people. HDC ful
investigation is long and time consuming /within a legal framework / not satisfactory
outcome for consumer or provider - as it does not result in an outcome where people
feel validated.
- Would be good to see what people understand about the Advocacy Service.
- HQSC - Advocacy can be more whanau centric and whanau accommodating.
- Māori don’t have a lot of trust in the process. Many Māori when things are not going
good- vote with feet and walk away
- I have had a personal experience in making a complaint and did not feel supported
in the process. First contact by provider with patient to talk about the complaint
process and advise on who can advocate for them.
- People would want to make the complaint in person (face to face) rather in writing.
Wanting someone to listen but not react to emotions
- Some people who have a negative experience (or less than satisfactory) with HDC,
rightly or wrongly the person feels that the advocacy service is not independent. And
don’t have confidence of independence in the process. They see the advocacy
and/or the Privacy Act 2020
service as part of HDC and under its umbrel a. Compounded by HDC decision such
as NFA, or lack of outcome.
- Its a view through word of mouth, that advocacy services is ‘just part of HDC’.
- Get providers through their lawyers delaying the process
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- How wel do providers understand the role of the advocates so that they know how
can best work together - socialise the advocacy service with providers.
- Have had good experiences with advocacy, an ideal opportunity to strengthen
advocacy service to address some of the issues raise - re-thinking how use
advocacy services a good opportunity
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- Previous advocate used to present to staff orientation. Consumer rights not
compulsory training in hospital. Not just rights, but how to respond when rights are
breached. This might prevent issues before they start. NB Health and Disability
Standards require some training (audited against) - role for greater education /
embedding and reinforcing - could the Act be strengthened in this regard?
- Advocacy service includes networking and engaging with communities and
providers.
- Alternative dispute resolution HPPCA reforms
- Peer support resources to grow a greater diversity of peer support frameworks that
can grow advocacy capability within marginalised communities and use advocacy
services as training the trainers within diverse groups, to support breaking down the
barriers and whakamā that goes with needing to rely on professionals to support - is
a framing thing. In Māori and disability communities would rely more on whānau.
Being able to funnel resources
- Formal data sharing between quality agencies - is that being used effectively? EG if
a complainant went to a provider, does that translate as an adequate resolution of
complaints / shared record.
- Go into the community and advise them - this wil empower the community
concerned. And not just wait for the community to receive the information from the
provider. How do we get the information to the community, so they are ful y aware?
- Advocacy services give presentations to the community and to health providers.
Anybody can request advice/information on how to resolve issues with health
provider. How do we identify and who do we need to go to and put ourselves
(advocacy services) out more? The problem is if groups don’t know we exist.
- Lived experience - there is a sense they are alone so when going to advocacy
connecting with someone who has been the same situation or is of the same culture
and are talking to someone who understands their context. Feeling not alone that
they are not the only person going through this.
- How can we get the word out about advocacy services. Other community
groups/agencies could promote more on media platforms e.g. website.
- When support by advocacy is offered, fol ow up would be important. You’re feeling
isolated and alone, the advocacy can endeavor to link the person to a support
group. Be great to get to more groups but constrained by numbers of advocates
(reach / time).
- Advocate means (for nationwide advocacy services) is walking alongside and being
supportive of the process, making it timely and how the person is doing.
- Does the term advocacy need strengthening to enable people to engage with the
and/or the Privacy Act 2020
service. Health literacy is an advantage and if you don’t have it (or the privilege) how
do you get through this and how do you get support.
- Advocates have contacts with providers and can provide immediate support but only
works if the person knows to reach out. Should have advocacy number showing.
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- Funding - with increased funding comes increased coverage and increased
communication that the service exists for everybody
- AgedCare - with growing vulnerability and cognitive impairment - having better
working understanding of these factors. Developing better relationships and what
Advocacy can offer. Building knowledge around their service.
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- Are there currently people with lived experience who can provide cultural y
responsive service?
- Skil s and expertise need to be responsive no matter who is accessing it.
- Rainbow whanau - just won’t engage / not worth the hassle / would rather just walk
away / barriers to access
- The options for strengthening service in the paper - making sure that needs of Maori
are met is essential to meet Te Tiriti obligations
- Need to look at promotional mahi and what that looks like. WE need to prove that we
can be trusted and welcoming. That consumers wil be safe when they come to us.
Need to do better in marketing. HDC/Advocacy needs to be more visible / better PR.
Nobody wants to come to HDC/Advocacy at the moment.
- Something has to be done so that people feel like they can come to us.
- When you start looking at pieces of legislation - we are not looking at it and
specifical y add Rainbow community. Everyone should already be included. Shifting
perspective of whole framework.
- How is Advocacy integrated into the system - hasn’t been offered to anyone am
aware of. Seems like a paral el process rather than being offered off the bat. How
wel is it resourced, how wel is it responding to tāngata whaikaha Māori / tāngata
whaiora May need some or a lot of support and if haven’t started with Advocacy then
won’t have that support. And can feel like haven’t had resolution if haven’t had
advocacy support from the beginning.
HDC decision-making processes
Questions
What is your experience of how wel HDC’s complaints resolution processes
support timely and people-centred resolution?
What legislative and non-legislative changes do you think are most important
to support timely, people-centred complaints resolution? What impact
(positive and negative) do you think these changes would have?
- Personal experience was that the process wasn’t people centred and felt double
traumatised by the process. The HDC report when it came out, it felt judgmental.
E.g. the complainant is a snr lecturer (and RN) but was described as a big Pacific
person (this person was pregnant). This experience was traumatising. Motivated
complainant to take this experience and turn it into a learning exp
and/or the Privacy Act 2020 erience for the
sector focussing on Pacific peoples experiences (through PHD study). Need people
to understand what the complainant is going through. Why would you have a male
for example talking to a woman who has lost their baby? It wasn’t human centred, it
didn’t give relief. Wants to make it a safe journey and empowering for the person
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(complainant).
- Processes: face to face always has value over written process (e.g letters, reports).
- HDC process is paper based. You don’t get a sense through written words and can
trivialise and demean the experience(s) of the complainant.
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- There is inconsistency for serious complaints with decisions (of HDC). The process
does take too long.
- A perception that the HDC is more likely to accept the provider’s version over the
complaint. And is exacerbated by the inability for the complainant to respond to the
provider’s response.
- Is there ability in the current system/process for HDC to check in with the
complainant to make sure they are okay?
- (Kylie noted the hui a whānau process recently adopted within HDC - enabling
connection with the consumer)
- It doesn’t matter what the complainant has gone through but if they are looked after
and their questions have been answered (this is better).
- Had some good experiences of the advocacy service and support whānau
- Timeliness and people-centric not necessarily the same thing
- An observation is that is invisibility in the initial stages of investigation. Initial inquiry
and decision not visible - when does the clock start ticking. Includes how the HDC
and medical council interact
- Experience of supporting people through the process is that may have addressed
the nuts and bolts issue of the complaint but haven’t real y addressed the systemic
issues behind that. The nature of the complaint process is about specific errors
directed at a particular clinician or service rather than systemic. Eg acts of omission
where noone provides service, or practice that has become normalised. Unfair to
peg on one.
- Only 5 trilingual sign interpreters in country. What are the changes of someone
getting access to the service / communication they need. Address issue not solve
the problem
- Provider perspective - timeliness is a big issue. Very difficult on whanau and
providers. Some have dated back 3.5/4 years ago. Prolonged trauma for everyone.
Anything we can do to improve that - whether it is mediation/advocacy - it is not
helpful at the moment for anyone. Acknowledge that there are a lot of reasons for
this - but strongly advocate for better communication during the process for each
party.
- Cleansweep of the whole process and start again. Just feels that we are
regurgitating a system that is already there. Many Māori do not like the process. It
takes years. What are we going to do about it? Legislation does not move very fast.
- Multiple forms of investigation - Coroners/Acc/HDC/Internal investigations/Mortality
and morbidity reviews. People are often traumatised by going through multiple
and/or the Privacy Act 2020
processes - they al work in siloes and feels like it prolongs things. Everyone comes
from their own perspective - needs a more cohesive system / single point of contact?
People get caught up in going round and round in circles. Not productive - and very
resource intensive. Each process can find a slightly different outcome. Different
views - things can hang off the expert opinion - sometimes these are inconsistent.
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Every process has a slightly different focus.
- A factor in HDC decision on no further action (NFA) or when making a decision is the
‘time’ from when the incident/issue occurred. Example. Had a complaint about a
provider (included ACC) about reconstruction surgery. But was exhausted, and 3.5
9
yrs of lack of physical function and didn’t have the emotional resilience and head
space to make a complaint at the time nor did the person want to put at risk the
medical treatment they were receiving by making a complaint during this.. 2nd
example of whānau member who passed and the person’s whānau realised
something occurred to their whānau member that resulted in them wanting to
complain but this was over a year (so time had passed). The process needs to be
cognizant of this.
- Face to face engagement in legislation.
- Some people realise retrospectively they should of made a complaint at the time or
shortly after but for various reason’s make the complaint down the track.
- Confusion over the term complaint resolution. May not be resolved. Perhaps some
thought is needed around the title.
- No-further action - always actions that can be done. Not people-centred language.
Related to that is jurisdictional boundaries. Can be a human rights issue and then
drop. If took an interdependent approach / no-wrong door approach could run
paral el or join
- As a rule would be useful for HDC to find ways to work together with other agencies
in a more seamless way. Somewhat binary. Potential to review. Gives impression
that agency not interested, when just waiting.
- Greater opportunity to address complaints at a local level. Perhaps people are
bypassing providers. Embedding a more restorative approach within providers could
support this.
- Accessibility is important with complaints management. Especial y in rural areas
where no internet or computer access. Support idea that arbitrated locally -
continuum of where can escalate complaint. Should have consistency across
advocacy for supporting direct to provider complaints. Advocacy supported
resolution is much more people-centred, whereas the process at other levels are
much to paper-centric
- Timeliness and people-centric can be enabled by enabling and empowering
consumer with good information to understand the process
- Assume maximal wrap-around support is the starting position. Notification approach
with assumption that need an advocate to help frame and form and decide whether
could be made local y or needs to be escalated and that support stays through that
process. A lot of people don’t want to make a formal complaint but want something
on record. May be Te Tāhū Hauora notification processes.
- At the moment - the only family member that can do something on behalf of
and/or the Privacy Act 2020
someone else needs to have legal standing to do so. Can exclude whanau. It’s not
always the parent / depending on family might be the older sibling etc. There is no
current process that recognises that it could be any family member that is speaking
on behalf of a loved.
- No process for just letting HDC know - you have to make a formal complaint.
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- Needs to have a process that is not so over the top formal
- Process is real y onerous and takes years
- Legislation - changing can be a long process. HDC process all feels too hard at the
moment.
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- Setting expectations at the beginning about what could happen. How much time at
HDC is spent preparing whanau about how long/how complicated the process might
be?
- Natural justice applies to both provider and complainant
- Consumers need a lot of support to go through the process - it is very draining and
needs to be looked at very careful y.
- Using people centred language - expand application of mediation conference. Feels
like replacing it with facilitated resolution/conciliation is just changing
language/tinkering - not meaningful change/tweaks around the edges / not actual y
changing the substance of the process. This is not a fundamental shift.
- Introducing provider/consumer surveys - one of the problems with this is people wil
rate the service real y highly but it wil not have anything to do with whether the
service is any good. There is value in these - but would recommend caution as it
depends what the person’s bar is.
- Māori whanau wil often rate a service very highly even though comparatively they
have received a poor service
Additional reflections on complaint resolution processes
- HDC provider and consumer feedback surveys. They dropped off in 2016.
An
experience survey has been introduced that asks questions to support quality
improvement, including communication
- When go through HDC website, there is no definition of complaint – could set out for
lay people to understand
Options for a right of appeal of HDC decisions
Questions:
Do you think the current pathways to chal enge an HDC decision are
adequate? Why? / Why not?
What options to chal enge should we consider?
- Position set out clearly in the submission of the Cartwright Col ective. Believe need
the right to appeal. Is a matter of natural justice. Understand difficulties and
- Not in favour of the courts because people who don’t have financial ability /
resources wil not
o Support Internal review, but would need an independent body who was not
involved in the original complaint
and/or the Privacy Act 2020
o ACC no fault system means that consumers seeking remedy can’t get it. This
a robust reason why need appeal.
o An appeals process would not just be for complainants, but for providers
o Not in favour of the HHRT just being about just investigations because there
are no further action decisions that, certainly in the past, have been seen to
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be unfair where serious harm has been done to a consumer, in some cases,
involving death or long term disability. If to lower the threshold then should
include NFA
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- I strongly agree that appeals should not be a court based approach as it wil be
inequitably available and resource intensive. It could include an independent
assessment of the finding which includes legal, professional and consumer advocacy
perspectives
- If complaint is declined needs to be for a good reason. Needs to be a process for
review or appeal. Not everyone puts down al the information necessary in a
complaint. Was an issue with staffing at the time, but not revisited.
- In experience of Court appeals process, tend to refer back to decision-maker. Merit
in considering a robust internal review process with timeframes and criteria, with an
independent person identifying grounds and redirecting to HDC or having potential to
make decisions themselves.
- Should be an internal audit process over decisions to see if met objectives and
whether things that can be improved. First review should be internal and then other
opportunities for escalation to Ombudsman, HRRT. Don’t like linking to court
processes. Either the Code has been breached or not.
- Internal review processes would need to have an independent consumer advocate
and independent supporter to be part of that review who knows noting about the
complaint and process that has been through who can bring a set of fresh eyes and
consider whether the decision was fair.
- Processes are hard enough if educated, know the system, can stand up for
themselves.
- Consumer voice in a review process important – eg consumer advisory group to
support/review process. Wil need to think about privacy.
- Offer of mediation could be used to help support maintaining the relationship and
also al owing the perspective of the provider
- For those who have been ‘successful’ – what is the outcome for people? Can stil be
traumatic for people
- Kaiāwhina navigation service walking alongside consumers and whānau through any
of the process, whether directly with provider, with HDC, and could include a review
and/or appeal process.
and/or the Privacy Act 2020
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