Policies and Procedures
Kid Link Occupational Therapy complies with State and Federal Privacy requirements for confidentiality and privacy. We aim to ensure clients of Kid Link Occupational Therapy are comfortable in entrusting their health information to the Practice. This policy provides information to clients as to how their personal information (which includes their health information) is collected and used within the Practice, and the circumstances in which we may disclose it to third parties. The Australian Privacy Principles (APP) provide a privacy protection framework that supports the rights and obligations of collecting, holding, using, accessing and correcting personal information. This policy will guide staff in meeting these legal obligations. It also details to clients how the Practice uses their personal information.
Kid Link Occupational Therapy will:
• Provide a copy of this policy upon request and have it accessible on our website and in our clinic waiting room
• Ensure staff comply with the APP and deal appropriately with enquires or concerns
• Collect personal information for the primary purpose of managing a client’s healthcare and for financial claims and payments.
The Practice’s staff will take reasonable steps to ensure clients understand:
• What information has been and is being collected
• Why the information is being collected, and whether this is due to a legal requirement
• How the information will be used or disclosed
• Why and when their consent is necessary
• The Practice’s procedures for access and correction of information, and responding to complaints of information breaches, including by providing this policy.
Collection and storage of Information
To ensure we can offer the best service possible, we will need to collect personal information as a provision of clinical services to a client at the practice. We aim to always collect information that is necessary to provide this service while adhering to all guidelines. We keep health information for a minimum of 7 years from the date of last entry in the client record. Collected personal information will include clients’:
• Name, addresses and contact details
• Medicare number (where available) for identification and claiming purposes
• Medical information including medical history, medications, allergies, social history, family information
• Other professionals involved in the client’s care and/or treatment
• Educational setting information (e.g. school class teacher’s name and contact details)
A client’s personal information may be held at the Practice in various forms:
• As paper files
• As electronic records
• As visual –videos and photos
• As audio recordings
• As emails
Paper files are held within filing cabinets. Only staff at Kid Link Occupational Therapy have access to these files. Notes, assessments and other materials are held electronically at Kid Link Occupational Therapy on an internal server, Google GSuite Drive and/or our cloud based practice management software program, Cliniko. Kid Link Occupational Therapy also utilises the Google cloud platform (GSuite) for email, which is compliant with the ISO 270001 certification. We utilise an electronic signature platform, Docusign, for sending and completing forms electronically. We require families who access therapy offsite or on Saturdays to pay for therapy via a direct debit service, IntegraPay.
The Practice’s procedure for collecting personal information is set out below:
1. Practice staff collects clients’ personal and demographic information via registration when clients present to the Practice for the first time (by phone or in person). Clients are encouraged to pay attention to this policy so they are aware of all Kid Link Occupational Therapy policies and procedures prior to commencing services.
2. During the course of providing therapy services, the occupational therapists will consequently collect further personal information through an interview with the family.
3. Personal information may also be collected from other relevant stakeholders with permission (where practicable and necessary).
Use and disclosure of information
Personal information will only be used for the purpose of providing Occupational Therapy services and for claims and payments, unless otherwise consented to. The Practice evaluates all unsolicited information it receives to decide if it should be kept, acted on or destroyed.
The Practice will not disclose personal information to any third party other than in the course of providing Occupational Therapy services. Please note that parents and/or primary caregivers are entitled to ask for copies of their child’s records and/or notes. Please be aware of this in relation to your individual family circumstances, and provide us with any court orders that may impact on what parties are entitled to access. Summary reports or feedback sessions can be provided at a cost to the requesting parent as needed. Exceptions to disclose without client consent are where the information is: Required by law, Necessary to lessen or prevent a serious threat to a client’s life, health or safety or public health or safety, or it is impractical to obtain the client’s consent.
Primary caregiver email addresses are used to communicate information about the clinic in the form of a termly newsletter. Email addresses and/or mobile numbers are used to send appointment reminders. Clients may opt out of reminders at any time by notifying the Practice in a letter or email. Clients can opt out of newsletters by unsubscribing at the bottom the newsletter email.
Kid Link Occupational Therapy Pty Ltd is committed to being open and responsive to any complaints offered by our clients, supporters, our people or by members of the community. Kid Link Occupational Therapy Pty Ltd will at all times seek an outcome to a complaint which is satisfactory to all parties.
The purpose of this policy is to:
• Ensure the existence of a procedure through which clients, supporters, members of the community and our people can communicate any complaints regarding Kid Link Occupational Therapy’s services, functioning or operations
• Enable Kid Link Occupational Therapy to benefit from all complaints through ensuring that they are recorded, considered, resolved and monitored
• Establish the principles that are to govern Kid Link Occupational Therapy’s response to complaints
• Ensure that our people and our clients are aware of the content of this policy and relevant procedure
1. Kid Link Occupational Therapy will maintain a formal complaints procedure when requested to ensure that all complaints are responded to in a timely and impartial fashion.
2. Kid Link Occupational Therapy will ensure that all suggestions for improvement and complaints are recorded, considered and retained for process improvement purposes.
3. Kid Link Occupational Therapy encourages clients, supporters, their advocates, members of the community and any of our people who have a complaint in relation to services or to the actions of one of its staff members or volunteers to express this through the formal complaints procedure.
4. Kid Link Occupational Therapy will ensure that the complainant is informed of his or her right to have a support person or advocate present to assist or represent them during the formal complaints procedure. Formal complaints can be written or verbal. If verbal, the assisting staff member will document the complaint and either the complainant or assisting staff member must sign the document.
5. Kid Link Occupational Therapy will address all complaints in a confidential manner. Action to resolve the complaint will commence within 2 working days of the complaint being made (this includes contacting the complainant). Only the people directly involved in making, investigating or resolving a complaint will have access to information about it. Where the complainant is a client, no information will be documented in the individual’s client file without his/her consent.
6. Kid Link Occupational Therapy will ensure that the complaint investigation process is impartial. No assumptions will be made nor any action taken until all relevant information has been collected and considered.
7. Kid Link Occupational Therapy will ensure that any complaint is free of repercussions for the complainant. Management will take all necessary steps to ensure that no victimisation occurs against anyone who makes a complaint.
8. The Director is the main point to which complaints should be directed. The Director is then responsible for completing the complaints form. Kid Link Occupational Therapy will ensure that our people and our clients are aware of how to contact the Director.
9. Kid Link Occupational Therapy management will ensure that all our people are aware of this policy and relevant procedures.
10. Kid Link Occupational Therapy will ensure that all clients are informed of the existence of this policy and procedure at the commencement of receiving services as well as providing relevant information on the Kid Link Occupational Therapy website.
11. Kid Link Occupational Therapy recognises the right of individuals to approach an external agency if the formal complaints procedure has not resolved the issue to their satisfaction.
12. The Director has overall responsibility for this policy.
This procedure provides guidelines for responding to any complaints originating from clients, supporters, volunteers or by members of the community. This procedure supports the Complaints Policy.
This procedure applies to all members of the community, including clients, supporters and volunteers of Kid Link Occupational Therapy.
The Director has overall responsibility for this procedure. However, all staff are responsible for recording complaints when required, in accordance with this procedure.
1. Recording and Responding to Complaints
1.1 Kid Link Occupational Therapy invites individuals to submit complaints regarding any aspect of the organisation’s operations.
1.2 It is anticipated that most complaints raised by clients will be resolved informally between the client and staff involved. If a satisfactory resolution fails to be reached, the following procedure applies.
1.3 The Director is the main point to which complaints should be directed, however, complaints may be received by any staff member of Kid Link Occupational Therapy.
1.4 As soon as possible after the receipt of a complaint, the staff member who has been informed of the complaint should forward the complaint to the director, complete a Complaint Form or provide a copy to the person making a complaint.
1.5 If a member of staff other than the Director receives a formal complaint, this form should be forwarded electronically to the Director. The Director will log the complaint on the Complaint Register (located within ‘Kid Link OT’ on the internal server).
1.6 The Director will nominate an appropriate person to address the complaint. Action to resolve the complaint will commence within 2 working days of the complaint being made (this includes contacting the complainant). A satisfactory course of action will be decided upon between the staff member and the complainant within 5 working days of the complaint being made.
1.7 The complainant should be informed of his or her right to have a support person or advocate present to assist or represent them during this process.
1.8 Once action has been taken, the staff member responsible for the action will return the Complaint Form, electronically, to the Director. This form should detail the action taken and its outcome.
1.9 If a satisfactory course of action cannot be agreed upon between the staff member and the complainant within 5 working days, the staff member should refer back to their Director. The Director will convene a discussion between the relevant parties and will recommend a course of action.
1.10 If the complainant is not satisfied with the resolution proposed by the Director, the individual may wish to approach an external agency.
2. Monitoring Complaints for Process Improvement
2.1 The Director will analyse all Complaint Forms quarterly. A report indicating the nature of the complaints received and suggestions for systemic change to minimise future complaints will be discussed with the Director and team for consideration.
Kid Link Occupational Therapy aims to provide a reasonably priced and family centered practice. We love being able to provide families with their own regular appointment time where possible, which is reserved for them for the term. This appointment usually remains vacant in the event that you are unable to attend. Therefore, we charge for missed or cancelled appointment fees to contribute to our operating costs. We appreciate your understanding in the fact that our cancellation fee is essential to the sustainability of our practice.
The NDIA Price Guide suggests specific policies regarding cancellation depending on the notice given.
Kid Link aims:
• To reflect the requirements of the NDIS Terms of Business for Registered Providers and the most current NDIA Price Guide.
• To balance customer and organisational financial interests in relation to cancellations and no-shows, and
• To make all reasonable attempts to safeguard customers who no-show.
• Missed/cancelled Appointment with Notice: Cancellation of the scheduled delivery of supports outside of the notice period (3pm the day before), as required by the Service Agreement.
• Missed/cancelled Appointment without Notice: Where no notice or less than the notice period (3pm the day before) required by the Service Agreement has been given.
• No-show: When a customer does not attend the service, is not available, or is not at the agreed location to receive a scheduled support and does not notify the clinic via phone.
Where an appointment is cancelled without notice (after 3pm the day before the scheduled service begins) or there is a no show, 90% of the full session fee will be charged.
If a family cancels with notice (before 3pm the day before the scheduled service), no fee will be applied. Appointments are made on a term-by-term basis and while we try to give families/participants the same day/time, Kid Link Occupational Therapy reserves the right to void this privilege for families who repeatedly do not attend or cancel their appointment, regardless of the amount of notice provided. We will then discuss alternative booking options.
Home/Community based sessions: Please note that home/community-based sessions require a higher level of commitment due to travel and additional administration requirements. We therefore reserve the right to offer this service on an ongoing basis, depending on the capacity of the practice, the location of the visit, goals and the family circumstances.
Special Circumstances: Charges may be waived if the customer has experienced a catastrophe, e.g. emergency hospitalisation or a death in the family. The decision to waive the charge in extenuating and emergency circumstances will be made by the Director of Kid Link OT at their discretion. The decision not to charge does not apply in any other circumstances and is not exercisable by other staff.
Use of NDIS for missed/cancelled appointments:
• Up to and including 6 hours of billable cancelled appointments a year can be funded by NDIS: The National Disability Insurance Agency permits that cancellations with or without notice and no-shows for therapy can be charged the relevant fee up to (and including) 6 hours a year.
• 7th or more hours: an invoice will be provided to the family for the relevant fee. This fee is to be funded privately. No further service will be provided until fees have been paid. If a fee is not paid prior to the next scheduled appointment, an ongoing appointment time slot may be forfeited and the participant may be required to go back on a waiting list if no suitable appointments are available.
Use of Third Party funding (e.g. Anglicare, Care Connect) for missed/cancelled appointments:
For all families that have appointments paid by an outside organisation, Kid Link have a responsibility to all of these organisations to use the funds for therapy and be accountable to outcomes. For this reason, most of these organisations will not fund cancellation fees. In the event you are unable to pay the cancellation fee yourself, you will need to provide the third party with the invoice for the cancellation fee yourself and the fee will need to be paid by the next appointment (by either the third party or yourself).
Use of DSS funding for missed/cancelled appointments:
If you use DSS funding to pay for your child’s Occupational Therapy sessions, they do not cover any cancellations. Any missed appointment fees will need to be paid for out of pocket.
Use of Medicare Plans for missed/cancelled appointments:
Medicare plans can only be used for Occupational Therapy sessions when the child is present. Medicare Rebates are unable to be used towards missed or cancelled appointments. The cancellation fee will need to be funded privately in full.
CHILD SAFE POLICY
• Kid Link Occupational Therapy values and respects each and every child and is committed to providing them with high standard of therapy in a safe and welcoming environment.
• At Kid Link OT, we have a zero tolerance for child abuse and are committed to acting in children’s best interests and keeping them safe from harm. Kid Link OT is committed to supporting and upholding the Victorian Government’s Child Safety Standards.
• Child abuse includes sexual offences, grooming, physical violence, serious emotional or psychological harm, serious neglect and a child’s exposure to family violence. Kid Link OT is committed to the protection of all children from all forms of child abuse and demonstrates this commitment through the implementation of a Child Safety Policy designed to keep children safe.
• Kid Link acknowledges that it has a duty to protect its clients from foreseeable harm. This includes the provision of safeguards against mistreatment and prompt reporting of child abuse. (The definition of ‘child’ is any client of Kid Link OT)
• Preventative measures include careful screening and selection of staff, staff training, and the implementation of the Child Safety Staff Code of Conduct. This will ensure a high level of professional standards.
Child Safety Principles
Kid Link OT’s commitment to child safety is based on the following overarching principles that guide the development and regular review of our work systems, practices, policies and procedures to protect children from abuse:
• All children have the right to be safe
• The welfare and best interests of the child are paramount
• The views of the child and a child’s privacy must be respected
• Clear expectations for appropriate behaviour with children are established in our Child Safety Staff Code of Conduct
• The safety of children is dependent upon the existence of a child safe culture
• Child safety awareness is promoted and openly discussed within our community
• Procedures are in place to screen all staff, volunteers, contractors and external education providers who have direct contact with children
• Child safety and protection is everyone’s responsibility
• Child protection training is mandatory for all Kid Link OT staff.
• Procedures for responding to alleged or suspected incidents of child abuse are simple and accessible for all staff members.
• Children from culturally or linguistically diverse backgrounds have the right to special care and support including those who identify as Aboriginal or Torres Strait Islander.
• Children who have any kind of disability have the right to special care and support.
Kid Link OT has implemented a number of risk management policies and procedures to:
• provide a safe learning environment for its clients.
• identify risks of child abuse and mitigate those risks
• assist staff to detect child abuse
• care for a child who may be a victim of abuse
• report suspected or known child abuse to appropriate authorities
Additionally, Kid Link OT is committed to monitoring its practices and procedures to ensure the highest standard of care for its clients, and will seek to continually improve its practices and procedures.
Kid Link OT Child Safety Staff Code of Conduct:
Kid Link OT has a Child Safety Staff Code of Conduct which outlines expectations of professional conduct, and standards to which all staff must adhere. The overarching principle guiding all adult behaviours is that the safety of all children is paramount. All staff are required to sign a statement acknowledging that the Code of Conduct and this Policy have been read, understood, and that they will agree to abide by them.
• Kid Link OT conducts a rigorous screening and recruitment process that includes exacting reference checks.
• All successful applicants must complete an induction prior to working at the clinic, and must also sign an agreement indicating that they have read and will abide by the Kid Link OT Child Safety Policy and the Kid Link OT Codes of Conduct outlined in the Staff Handbook.
• All Occupational Therapists must be registered with the Occupational Therapy Board of Australia, supported by the Australian Health Practitioner Regulation Agency (AHPRA).
• All therapy and non-therapy staff must have a current Working With Children Check
Staff Induction and Training:
Kid Link OT is committed to providing ongoing training to its staff. All staff will be required to sign a statement that they have read, understood and will abide by the Kid Link OT Child Safety Policy and Team Handbook.
Roles and Responsibilities:
At Kid Link OT all staff members, as well as volunteers, have a shared responsibility for contributing to the safety and protection of children. All staff and volunteers at Kid Link OT are required to actively support the Child Safety Policy and be an integral part of ensuring a culture of child safety.
The Director of Kid Link OT oversees the implementation of child safety policies and practices.
Reporting Child Abuse or Child Safety Concerns:
Kid Link OT has developed and implemented the following procedures for reporting and responding to allegations of child abuse.
Child Safety Officer
Kid Link OT has appointed a Child Safety Officer, whose main role is to be the person who staff can turn to with child abuse or child safety concerns. The Child Safety Officer will also ensure the safety and wellbeing of any child who makes or is affected by an allegation of child abuse. They will also help ensure company compliance, best practice and Kid Link OTs ongoing commitment to improvement in child safety procedures.
The Child Safety Officer at Kid Link OT is: Jackie Sikic
The Business has implemented the following procedures:
• Staff are trained to report concerns regarding child safety to the Child Safety Officer. If the Child Safety Officer is not available, all staff are trained to respond and notify the Officer as soon as practically possible.
• All staff are trained in their obligation to report child abuse (sexual, physical, emotional or psychological), and their responsibility in keeping children and young people safe
• All suspected or known cases of abuse will be reported to Child Protection at the Department of Human Services or the Police (see end of this document for definition of ‘abuse’)
• Should an allegation of suspected abuse be made, Kid Link OT is committed to protecting the child and will:
• listen sensitively to the child
• inform appropriate authorities
• monitor the ongoing wellbeing of the child
• record, make secure and retain all documentation
Kid Link OT has policies and procedures in place to empower children through building:
• a clear understanding of appropriate and acceptable behaviours
• a strong sense of self
Policy and Program Review
Kid Link OT is committed to the continuous improvement of our Child Safety Policies. The Program is to be reviewed annually or as required to ensure compliance with all child protection related laws, regulations and standards.
The director oversees the development, implementation and review of child safety policies and practices.
At Kid Link, we aim to work with families to decide on resources that may be beneficial given the child’s Occupational Therapy goals. We aim to suggest evidence based and appropriate resources where possible that are based on the needs and reports of the family. We will always discuss possible benefits and risks of different resources however the purchase and use of the resource/equipment is then the responsibility of the family. The family is responsible for ensuring appropriate use of any items and providing adequate supervision and assistance during their use. I will not hold Kid Link Occupational Therapy Pty Ltd or the treating therapist responsible for any outcomes associated with the use of equipment or resources that may or may not have suggested in therapy.
DSS: Resources and Equipment:
Any equipment purchased through DSS funding needs to be discussed with the child’s therapist and deemed “reasonable and necessary” in supporting the child’s current Occupational Therapy goals, before the item is ordered. In most cases, Once approved, I will need to pay upfront and then provide my Occupational Therapy with the receipts at my next scheduled appointment and complete relevant paperwork. I will then be reimbursed within 14 business days unless otherwise notified.
NDIS Resources and Equipment:
Some equipment prescription and home modification is more specialised or requires customisation. There are also specific funding categories for equipment/modification that Kid Link may not be registered for. In this instance, you may be referred to a different service provider if this kind of prescription is required. Where Kid Link can recommend resources, Kid Link takes a client centred approach to all assessment and equipment prescription and will work with families to identify resources which may benefit the child given their individual needs.
• ‘Child’ means any child who is an active client of Kid Link Occupational Therapy.
• ‘Business’ means Kid Link Occupational Therapy Pty Ltd.
• ‘Kid Link OT staff’ means an individual working at or volunteering for Kid Link Occupational Therapy.
• ‘Client’ means any child or family member/guardian receiving a service from Kid Link Occupational Therapy
• ‘Supporters’ means any person who provides support to Kid Link Occupational Therapy e.g. doctors, teachers, other therapists
• ‘Complaint’ is an issue or concern which is formally brought to the notice of Kid Link Occupational Therapy in order to bring about change or resolution (This may include any act, omission, situation or decision that is considered unfair, discriminatory or unjustified)
• ‘our People’ means all paid and unpaid staff, including volunteers, individuals on work experience, and student placements
• ‘Child abuse’ includes
1. Any act committed against a child involving:
◦ sexual offence
◦ grooming of a child (grooming a child for sexual purposes under the age of 16 years)
2. Infliction on a child of
◦ physical violence
◦ serious emotional or psychological harm
3. Serious neglect of a child
CHANGES TO POLICIES AND PROCEDURE STATEMENT
We may amend these Policies and Procedures as our business requirements or the law changes. Any changes to this will be updated on our website and in the clinic, so please re-visit the Statement at least quarterly to ensure that you are aware of our most current privacy statement. The date of the last update will be at the top of the page.
FURTHER INFORMATION ABOUT PRIVACY
For further information about the protection of your privacy, please visit the Australian Federal Privacy Commissioner’s website at www.privacy.gov.au