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A JacksonRyan Partners Challenge Paper

A Critique

Disability Service Commissioner, Victoria, 2014 Annual Report

  1. The Purpose of this Paper

Annual Reports stand as significant public documents.  The Disability Services Commissioner’s Annual Report is critical in assessing his impact in addressing complaints and fulfilling the 17 functions assigned to him under the Disability Act 2006 (the Act).  Therefore, the significance of the Commissioner’s Annual Report cannot be understated.  Not only is it a public document to Parliament, but it must also be assumed to be a document that through its reporting, seeks to detail the Commissioners’ achievements, or otherwise, for the reporting year. 

This paper is a critique of the Disability Services Commissioner’s 2014 Annual Report.  The writers submit the report demands to be evaluated given the Commissioner’s functions.  This assessment also addresses any obvious omissions from the report.

  1. A Relationship Comment

In July 2014 the writers published an analysis of the six Annual Reports  2008 - 2013 of Victoria’s Disability Services Commissioner.  This analysis was recorded in a public document entitled - An Analysis of Complaints Management and Resolution Undertaken by Victoria's Disability Services Commissioner – A Snapshot from the Annual Reports 2008 – 2013.

As the title of that paper suggests, its purpose was to cast an analytical eye over the contents of the six annual reports produced by the Commissioner up until that date.  Given the significance of that paper, this critique of the 2014 Annual Report provides an extension of the original analysis.  

  1. The Disability Act 2006 (the Act) and the Commissioner’s Statutory Functions

In his opening remarks to the 2014 report the Disability Services Commissioner notes that, "We must be uncompromising about putting people's rights at the centre, and about organisations delivering on undertakings they make in relation to the matters we deal with.”  This is a significant statement.  Therefore, the writers seek to test how "uncompromising" the Commissioner has actually been in undertaking his functions as mandated by the Act and reporting on that work in his 2014 Annual Report.

As an initial comment, the writers suggest the most critical requirement in being uncompromising is for the Commissioner to ensure that he complies with his legislative responsibilities.  The second consideration is to ensure that where the Commissioner determines service providers, including the Department of Human Services, have been in breach of the Disability Act 2006, that such breaches are reported as such in his Annual Report.  This critique will assess whether or not the Commissioner has reported in an uncompromising way where service providers failed to adhere to the law and where they failed to meet their duty of care obligations.  In other words, has the Commissioner been prepared to name those organisations that have broken the law? 

  1. Addressing the Contents of the Report

Rather than go through the Annual Report on a page-by-page basis and specifically address the contents under every heading in the report, the writers have chosen to provide particular comment on those aspects of the report they believe require a more critical analysis.  Thus, while not being dismissive of the other content in the report, the writers argue that because an annual report is a significant document, it is important that a critique such as this paper addresses those aspects of the report’s comment or data that lack transparency.  Further, where it might have been expected comment or data may have been provided but has been omitted.

Therefore, whether the contents of this Annual Report reflect a transparent and critical analysis of the Disability Services Commissioner’s performance cannot be ignored.  As such, the writers have chosen to address particular contents of the Annual Report under the following headings.

  1. The Concept of Leadership

In commenting on leadership the Commissioner used the word ‘uncompromising’. While the writers of this paper applaud the Commissioner for raising the matter of leadership, they note the Commissioner’s comment was somewhat tangential in that he failed to identify what he meant by ‘uncompromising’. 

The Commissioner suggested, “Leadership across the sector continues to be challenged by an array of competing priorities”.   Yet, he failed to detail the nature of the competing priorities and how they necessarily compromised service providers and watchdog entities meeting their legislative obligations.  Indeed, it can be argued that competing priorities have always existed in human service areas of endeavour.  Therefore, regardless of so-called priorities, the writers submit the first responsibility of service providers and watchdogs entities alike, including the Commissioner, is to ensure they each meet their legislative obligations.  The question must therefore be asked - Why didn’t the Commissioner in his reference to "leadership" make any comment regarding the relationship between leadership and legislative obligations?

The writers also note the Commissioner’s failure to identify the nature of leadership issues in the disability sector.  He made no mention of core strengths and weaknesses.  The writers argue that despite the legislation and despite the myriad of principles and documents attesting to the importance of the rights of people with disabilities, leadership has been and is sadly lacking at all levels of the sector.  Given the Commissioner’s reference to leadership, the writers therefore query why he showed such timidity in his comments.  He failed to provide any specific detail as to the nature of the failure of leadership, whether at the political, protective or service provision level. 

Given leadership is a demonstrative action in that it should actively demonstrate a “Do as I do” practice, excellence in leadership, at all levels, must therefore set the platform for ensuring legislation and excellence in service inputs and outcomes operate hand-in-hand.

As this paper will address further below, the matter of whether the Disability Service Commissioner has demonstrated leadership in fulfilling his legislative obligations is very much open to question.

  1. The Data Sets

Although the 2014 Annual Report made some changes to the data sets included in the report when contrasted to previous reporting years, nonetheless, as for previous annual reports, the current report also failed to provide adequate sets of data.  The inadequacy is defined in three ways. 

Some data sets lead to confusion in terms of what is exactly meant.  An example of this is the presentation of data in terms of resolution being “resolved fully or substantially” – What does substantially mean?  Then there are those complaints that are defined as being “partially resolved” – What does partially mean?  The writers contend that a complaint is either fully resolved or not resolved.  Therefore, by categorising resolution as he does, the Commissioner is in effect inflating the actual resolution numbers. 

Secondly, some data sets mix and match inquiries and complaints. The writers acknowledge that inquiries are made to the Commissioner’s office.  However, by failing to separate inquiries from actual in-scope complaints in particular data sets, the Commissioner is in effect inflating the actual work undertaken by his office in relation to complaints management and resolution.  This is after all a function assigned to the Commissioner.  Indeed, the writers note that in line with previous years the actual number of in-scope complaints addressed by the Commissioner’s office equates to no more than three to four a week.  By any assessment this can hardly be considered a significant workload.

Thirdly, by omission, there is particular data the writers assume ought to be included but has not been provided.  An example of such an omission is the failure of the report to include the number of investigations undertaken, or whether indeed any were undertaken, noting the significance of investigations as referenced further below. 

Therefore, by continuing to present the data and information in the 2014 report as in previous years, the Commissioner has again failed to present to the Parliament and the public of Victoria a cohesive, comprehensive and fully transparent overview of his performance against his legislated functions with particular reference to complaints management and resolution.

The following tables have been taken from the previous paper in relation to annual reports, but are updated to include data from the 2014 Annual Report.

Table 1:          

Outcomes of In-scope complaints accepted by the Commissioner

Annual Report

Number of

In-scope Complaints

Number of Complaints Referred for

Number of Complaints Referred for Conciliation

Number of Complaints only Partially Resolved

Number of Complaints Not Resolved

Not evident

Not evident

Not evident

Not evident

Not reported

Table 2:

            Separating Enquiries, Complaints and In-scope Complaints

Annual Report

Total No: Enquiries & Complaints

Total No: Enquiries

Total No: Complaints

In-scope Complaints


  1. Hypocrisy and Investigations

Given the Annual Report did not disclose whether any investigations were conducted during the reporting period, it seems reasonable to assume none were conducted.  The writers note the Commissioner also failed to conduct any investigations in the reporting periods 2010 - 2013 inclusive.  Consequently, the writers must be excused for thinking the Commissioner was auditioning for a gig at the Comedy Festival when he questioned service providers "about the rigour of their investigations, and whether they are giving as much weight and attention to the well being of the person with a disability as they do to the administrative processes.”  The reason for this hint of sarcasm is because while the Commissioner is obviously prepared to criticise service providers as to the quality of their investigations, he refuses to investigate when clearly he should do so.  Thus, if his refusal were not so serious it might be seen as a joke. 

The Commissioner’s criticism is brought into even sharper relief when considered in the context of advice provided in his 2013 Annual Report.  In that report he advised that regarding some complaints made to him about individual service providers, he refers the complaint back to the service provider for the provider to then undertake the investigation.

Further, when considered in the context of the Commissioner’s statement on leadership and the absence of particular key data applicable to investigations, it is clear that by his refusal to meet his legislative obligations to conduct investigations, the Commissioner has failed to demonstrate leadership.  Additionally he has also failed to place himself in a credible position by being critical of service providers and the way in which they conduct investigations.

When investigations are considered in light of the above comments, the Commissioner’s failure to investigate brings to the fore his legislative breach.   Unlike previous annual reports, the 2014 Annual Report makes no mention of the word “investigation” as applicable to the Commissioner’s activities.  

Significantly, as was the case for previous annual reports, the current report also fails to report on:

  • How many matters referred for conciliation were fully resolved to the satisfaction of the complainant.  Again noting the Commissioner’s use of the words “substantially” and “partially” in the number of complaints allegedly resolved.  
  • How many matters referred for conciliation failed to reach an agreed outcome. 
  • How many matters referred for conciliation where an agreed outcome was not reached were then investigated.
  • How many matters referred for conciliation, where conciliation failed and investigations were not established, were determined by the Commissioner not to be justified.

The significance of the above data sets, and their failure to be addressed in the Annual Report, is directly tied to section 118 of the Disability Act – Investigation of Complaints.  As stated in this section of the Act, the Commissioner “must” investigate a complaint which has either not been considered as suitable for conciliation or where conciliation has failed and further action is required.  The only out for the Commissioner is if he decides under section 118 (b) of the Act that the complaint was not justified.  If however, the Commissioner does determine a complaint not to be justified, as is his authority under section 118 (1) (b), it seems reasonable to conclude that the number of these complaints would be detailed in his report.   His only other alternative in stopping to deal with a complaint is if he decides that no further action is warranted, as per section 117 (1) (b) of the Act.   The Commissioner has failed to provide any information associated with either section 117 or 118 of the Act in terms of dealing with complaints and his determination not to proceed with any investigations.

The writers submit that the provision of data and information associated with section 118 of the Act could easily be facilitated by the inclusion of a simple table along the lines of the example below.

Decision Point

Number of in-scope complaints

Number of in-scope complaints resolved without the need to go to conciliation

Number of in-scope complaints referred to conciliation

Number of in-scope complaints resolved through conciliation

Number of in-scope complaints not resolved through conciliation

Number of in-scope complaints not resolved through conciliation but determined to be justified

Number of in-scope complaints not resolved through conciliation but referred for investigation

Number of in-scope complaints not resolved through conciliation but determined not to be justified

By the non-reporting of such information as illustrated in the sample table above it is impossible for the reader of the Annual Report to determine how many complaints should have been investigated.  The reasonable conclusion must be there were some.  In any event, the Commissioner should have reported on such matters.  By the Commissioner not reporting on investigations, it brings into stark contrast his pontificating statement that service providers need to question the rigour of the investigations as undertaken by them.

 Given the Act Provides the Commissioner significant power to stop dealing with a complaint that has been initially accepted by him, the writers argue that the Commissioner must not only report the number of complaints determined by him as not justified or no further action is warranted, but to also detail the reasons for such decisions.  To be given this power, noting that the Act does not make provision for an appeal to the Victorian Civil and Administrative Tribunal (VCAT), the Commissioner must provide information on such decisions.  Apart from what might be considered good reporting it also seems reasonable to suggest that for those complainants whose complaints are terminated by the Commissioner under section 117 bracket 1) (b) or section 118 (1) (b) of the Act, a moral obligation should prevail.

The writers contend that by not reporting on investigations and complaints determined as not being justified, the Commissioner demonstrates what can only be described as hypocrisy.

  1. Incident reports and concerns about investigations

The Commissioner also now reports on his role in reviewing incident reports involving allegations of staff-to-client assault and unexplained injury. This new function has been established through the Minister asking for advice.  It is a considerable irony that the DSC has published an investigations good practice guide, given he has not conducted any investigations over the past five years.  This suggests his ‘expertise’ must only come from theory and is not enlightened by practical experience. 

Of the 309 incidents reviewed by the Commissioner in 2013-14 he identified six key themes (p.12).  He noted “the common thread through all these themes” included the right of people with a disability to be heard.  Yet, he ignores this right through his failure to conduct investigations when conciliation has failed.

In terms of an annual report, the writers submit it is unsatisfactory for the Commissioner to simply give one column to his review of 309 incidents.  As an example, the report provides no information as to how many, if indeed any, of the incidents reported might be related to similar types of complaints received by the Commissioner.  Additionally, it may have been expected the Commissioner would have emphasised how he and his staff may be more proactive in pursuing the matter of staff-to-client assault and unexplained injury.  The writers note the significant concerns expressed in the Community Visitors Board Annual Report regarding abuse and neglect in care.  As such, it seems reasonable to conclude that the DSC would do more than identify six key themes and make comment on “a lack of clarity and shared understanding of the definition of ‘assault’ and ‘poor quality of care’” without identifying how he might address these serious issues.

The information contained in the Annual Report relating to the incident reports referred to the Commissioner can hardly be concluded as meeting his obligations under 16(c) of the Act to provide advice on matters referred by the Minister.  Further, the information can be concluded to be lacking in terms of the type of advice provided to disability service providers.  Given the nature of the incidents referred to the Commissioner as in staff-to-client assaults and unexplained injury, it might have been expected that some comment might have been made in relation to actions that should be taken in relation to allegations of staff assault of clients. 

Further in relation to the 309 incidents referred to the Commissioner, again it is noted he has not provided any breakdown of these incidents in terms of staff-to-client assaults and unexplained injury.  Nor has he identified the breakdown of the incident reports in terms of whether they occurred in the Department of Human Services or funded sector organisations.  Further, he has not provided figures to separate the number of incidents related to residential services versus day services or other types of services.

It would be hoped that the above deficits will be rectified in the 2015 report whereby a far more detailed set of data and information regarding incidents as referred to the Commissioner will be provided. 

  1. Vignettes

The writers note the inclusion of thirteen vignettes, or stories, which on first reading could reasonably be assumed to represent an individual.  Not so however.  Page 1 of the report advises the stories are “de-identified composites of complaints and other experiences people have brought” to the Commissioner and to service providers.  Therefore, apart from what the writers consider is a questionable, albeit current trendy approach, in using stories or case vignettes to try and illustrate a particular activity or success, they note that none of the stories detail complaints that were not resolved.  

For the report to create a composite of cases and then present them as though they represent particular individual cases is at worst dishonest and at best represent works of fiction.

Therefore, apart from challenging the efficacy of the vignettes included in the report, the writers submit the stories must also be challenged on the basis of their questionable usefulness in illustrating the work of the Commissioner. 

10.       The Fours A’s of Successful Complaint Resolution

Sometime ago the Commissioner established what he defines as “The four A’s of Successful Complaint Resolution”.  Page 20 of the current report addresses the question of how complaints were resolved by using the “Four A’s” approach.

Figure 8 on page 20 reports and characterises the percentage of resolutions attributed against each of the elements of the “A’s” assessment model - acknowledgement, answer, action, apology.  However, the explanation provided for figure 8 also notes that the percentages provided under each of the assessment elements “may not add up to 100 per cent”, presumably this being because some complaints were resolved through a combination of approaches.

The writers suggest the real issue is not about whether or not the figures add up to 100.  But, it is about the notion of what constitutes resolution to a complaint.  They argue that while it is all very well to talk about acknowledgement, answers and apology, of themselves these responses have the potential to minimise the significance of the complaint.  Worse still, it can be considered to present a sugar coated response to the complaint.  It is reasonable to suggest most complainants require more than an apology.  After all, apologies alone do not fix the problem.  The writers contend it is simplistic, naïve or an avoidance of responsibility to promote a slogan-like catchcry as “The Four A’s” represent.

If a person goes to the extent of lodging a complaint to the Commissioner then it seems reasonable to conclude the issues underlying the complaint are significant to the individual.  Therefore, although a complaint may be acknowledged, an answer given, or an apology provided, and this may go some way to satisfying the complainant, these are soft responses.  It is reasonable to assume that what complainants really want is action.  That is action to actually rectify the issues that led to the complaint and to be assured similar issues will not occur in the future.

It is also of concern that when Figure 8 - “Most common ways complaints were resolved” is considered in concert with Figure 6 - “Issues raised in enquiries and complaints”, on page 19 of the report, there is no relationship between the two tables.  The writers contend greater use could have been made of the figures provided in Figure 8 if the resolution actions had been matched with the issues that comprised the enquiries and complaints.

Many of the deficits of the annual report, including the Commissioner’s failure to provide an in-depth analysis of the data provided, seem to arise from no real thought being given to the primary purpose of the data, the relationship of data sets and how the data may be used to inform enhanced future actions and reporting.

  1. Learning from Complaints

The writers note that as with previous annual reports the current annual report includes particular sections associated with learning from complaints.  One such section on page 13 of the report is entitled Learning from complaints: trends and issues, another on page 14 is entitled - Learning from complaints:  reflections of disability service providers, while another on page 16 is entitled Learning from complaints: feedback from people involved in the complaints process.

The writers acknowledge the importance of using the outcomes of previous activities to inform future practice.  Nonetheless, they note that with the publication of the 2014 Annual Report the Commissioner has been operating for a period of seven years.  Therefore, by association, service providers had been subject to the complaints process for the same period.  Given this, the question must be posed - How much more has to be learnt before the complaints process is refined to the degree that people with disabilities, their families and members of the general public can have confidence it is working the way the legislation requires it to work?  

Indeed, in terms of the information provided on page 13, the writers question why any of the four trends as recorded reflect anything new and why these should not have been known for years.  The real issue is about actions taken, not words spoken by the Commissioner and those responsible for the provision of services.  Therefore, for the writers the real learning in terms of the comments on page 13 is the failure of the system to do what it ought to be doing.

In terms of page 14 and the reflections of disability service providers, the writers note another four themes.  Again it is of concern the four themes - communication, management of staff and information resources, respecting the person’s choice, and increased timeliness in the resolution of complaints - can hardly be described as new or recent issues.

In relation to feedback from people involved in the complaints process, the comments on page 16 of the report generally provide positive information as to the DSC processes, and the writers do not question this.  The percentages as provided, nonetheless, are derived from only 66 respondents to the evaluation survey.  Given that figure 1 on page 17 of the report advises that there were 975 enquiries and complaints submitted to the Commissioner then the figure 66 represents something less than seven per cent.  However, of even greater significance is that no advice was provided in the report as to who was surveyed.  Of equal import - Who made up the response numbers?  

Apart from this however, the writers contend that while it is useful to receive feedback of a positive nature, the real issue, in terms of improving service provision, is to pinpoint those responses where dissatisfaction was recorded.  There was no evidence to suggest that this occurred, other than 14 per cent reported being dissatisfied with the outcome of their complaint, 25 per cent not indicating satisfaction or dissatisfaction and 61 per cent were satisfied.  Effectively 39 percent were not satisfied - around four in ten, which must be considered a cause for concern.

  1. Naming Organisations

As the writers previously commented in relation to the 2008-2013 annual reports they again note the Commissioner’s failure to name organisations in the 2014 Annual Report.  There is nothing in the Disability Act to inhibit him from doing this. The writers submit that if the Commissioner named organisations in his annual reports, then two significant objectives would be met - the first objective being a greater level of transparency and the second being that a comparative analysis could be undertaken. 

Additionally, if organisation were aware of the potential to be named in an annual report it is reasonable to conclude they would be more inclined to work harder to minimise the potential for complaints to be made about their service.  As previously noted, by not naming organisations the Commissioner is in effect casting potentially negative reflections on those registered service providers who report no complaints. 

  1. The National Disability Insurance Scheme (NDIS) and the Commissioner’s Annual Report

Although the 2014 Annual Report makes brief reference (p 17 and p 23) to the introduction of the NDIS, the report provides no definitive information as to the number of complaints made to the Commissioner from the Barwon trial site.  While the writers acknowledge the report’s comment that the NDIS was phased in throughout the 2013-14 reporting period, and a detailed analysis will be provided in the 2014-15 reporting period, they contend the report should have provided the number and types of complaints received by the Commissioner from that site.  Indeed, the writers reject the Commissioner’s rationale for not having provided an analysis on the basis the NDIS was phased in over the 12 months reporting period.  They argue that this is a total red herring, and there is no reason why the Commissioner could not and should not have reported on the number and types of complaints received.

Given the NDIS is to be phased in over the next five to six years, and also given it is yet to be determined as to what type of complaints mechanism will prevail under the NDIS, then the writers would have assumed that the Commissioner may have taken some space in his report to make comment as to how the introduction of the NDIS in Barwon was impacting on his role. 

In addition to the above, and as relating to the number of complaints reported by service providers, the figure of 43 complaints as representing only 2 per cent of all complaints is suggested as being pointless.  After all, regardless of whether the NDIS was staggered or not staggered, unless the number of complaints made to agencies in the Barwon trial site, both prior to the introduction of the NDIS and during its phasing in period is known, then the 43 actual complaints and the translation of that into 2 per cent are meaningless figures.

  1. Breaches of the Disability Act 2006

The Commissioner is very clear in stating that one of his key objectives is "safeguarding the rights of people with a disability."  The writers note this laudable objective is one that in effect underpins the purpose of the Disability Act 2006.  It of course goes without saying that the Disability Services Commissioner also operates under the Act.   As commented on above, particularly in relation to the matter of investigations, the writers have been critical of the Commissioner’s failure to meet his statutory obligations as defined by the Act and as relating to investigations.

The significance of the Act in directing the work of the Commissioner and in specifying the platform of principles and rights by which services must be delivered, and services must be judged, cannot be ignored.  Given this, it is unbelievable the Commissioner does not provide an analytical expose of complaints against breaches of client rights and the legislation.  By contrast, although the Commissioner allocated three pages in his report to "learnings", he fails to provide any analysis of learnings in terms of breaches of the Act and what might be done to uphold people’s rights in the future.

If the Commissioner is genuine in his objective of "safeguarding the rights of people with a disability", it is reasonable to suggest he must be far more proactive and detailed in his analysis of complaints by measuring them against rights and breaches of the Act.  As argued by the writers in their opening paragraph under 1 above, "the significance of the Commissioner’s Annual Report cannot be understated."   They further argue that annual reports must be considered as more than simply a vehicle for reporting.  Indeed, the writers hold a very strong view the Commissioner’s Annual Report has the potential to dramatically influence the way in which services are provided.  However, this is largely dependent on whether or not rights and the legislation are at the forefront of service provision.  Or, whether rights are simply high-sounding sentiments without genuine action.

As noted throughout this paper the writers have commented on the failure of the Commissioner to report on matters that could reasonably be concluded to be important enough to include in his annual report.  They have also been critical of the Commissioner’s failure to provide a probing analysis of those figures and information that he has provided.

The matter of the legislation and its significance in providing the report base by which the Disability Services Commissioner’s annual reports should be written must not be ignored.  Yet, despite the significance of the Act, the Commissioner has not in any definitive way reported against the Act.  This must be considered a significant failure. However, more importantly, it is a dereliction of the Commissioner’s responsibilities.  If the Commissioner is serious about the need for leadership, then he must take the lead and demonstrate leadership in action.

  1. A Concluding Comment

The DSC’s 2014 Annual Report must be deemed to fail when critiqued against a number of critical tests by which annual reports should be measured.  The 2014 Annual Report fails the transparency test, it fails the readability test in terms of the way data is presented, it fails the inclusionary test in that key information and data is absent from the report, and it fails the factual test by the use of composite “stories”. 

Above all else, it fails the compliance test, in that the Commissioner fails to report on his legislative obligation to undertake investigations and fails to report on breaches of the legislation. 

It may be that the casual reader could be lulled into believing the Commissioner’s 2014 Annual Report is a document that provides significant useful information.  The writers argue, however, the report does not serve the Minister and the public well.  They further argue that if as reported by the Disability Services Board, an objective over the next three years is “to enhance the position and reputation of Disability Services Commissioner in all board activities”, and then it is necessary the Board casts a critical eye over the Commissioner’s 2014 Annual Report.

Appendix 1:

Sources of information in Tables in the Paper

Table 1:           Outcomes of In-scope complaints accepted by the Commissioner

Annual Report

Number of

In-scope Complaints

Number of Complaints Referred for

Number of Complaints Referred for Conciliation

Number of Complaints only Partially Resolved

Number of Complaints Not Resolved

Not evident

Not evident

Not evident

Not evident

Not reported

Notes re: source of figures for 2014

  1. In scope complaints – p 17, Figure 1
  2. Number referred for investigation – no reporting of information
  3. Number referred for conciliation – page 17 – Figure 1, Open complaints Conciliation 4 and Closed complaints Conciliation 9
  4. Number partially resolved – page 19 – Figure 7 and text 
  5. Number not resolved – page 19 – Figure 7 and text 

Table 2:

            Separating Enquiries, Complaints and In-scope Complaints

Annual Report

Total No: Enquiries & Complaints

Total No: Enquiries

Total No: Complaints

In-scope Complaints



Source fNote re: source of figures for 2104

Figure 1, page 17 of the 2014 Annual Report

Appendix 2

Complaints made to service providers for those years only

when all providers reported as required by the Disability Act 2006






Total Number of Providers





Total Complaints Reported





Distribution of complaints

Providers reporting Zero complaints

134 providers (45% of total number

123 providers (42% of total number)

129 providers (41% of total number)

140 providers (42% of total number

Providers reporting 1+ complaints

167 (55%) providers

173 (58%)providers

184 (59%) providers

180 providers (58%  of total number)

A Breakdown of the reported complaints

Providers reporting 1-49 complaints

163 providers reported a combined total of 957 complaints.  This equates to 77% of total number of complaints

169 providers reported a combined total of 1089 complaints.  This equates to 62% of total number of complaints

181 providers reported a combined total of 1089 complaints.  This equates to 65% of total number of complaints

177 providers reported a combined total of 1243 complaints.

This equates to 67% of total number of complaints

Average number of complaints per provider in the 1 to 49 category





Providers reporting 50+ complaints

4 providers (1.33%) reported a combined total of 471 complaints.  This equates to 33% of total number of complaints

4 providers (1.35%) reported a combined total of 667 complaints.  This equates to 38% of total number of complaints

3 providers (0.96%) reported a combined total of 609 complaints.  This equates to 35% of total number of complaints

3 providers (0.96%) reported a combined total of 612 complaints.  This equates to 33% of total number of complaints

Average number of complaints per provider in the 50+ category





Average number of complaints per provider as per Combined DSC Annual Reports





Not reported


  1. The above provides the figures as reported in the Annual Reports, and as associated with providers.
  2. Where appropriate, there has been some extrapolation from the figures.
  3. The 2014 Annual Report states that 45 service providers reporting 10 or more complaints accounted for 78 per cent of complaints, with 33 per cent of complaints accounted for by the three service providers that recorded over 50 complaints each.

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