Patient Complaint Handling in General Practice: RACGP Requirements and the Three Escalation Pathways

Key Takeaways

• Under Criterion QI1.2 of the RACGP Standards for General Practices (5th Edition), every accredited practice must have a documented system for receiving and responding to patient feedback and complaints, including a maintained complaints register and evidence that complaints have driven quality improvement.
• Complaints should be acknowledged within 5 business days of receipt, and a full written response should follow within 30 days. The acknowledgement does not need to resolve the complaint; it confirms receipt and outlines the next steps.
• Three escalation pathways exist: internal practice resolution, state or territory Health Complaints Commissioner, and AHPRA. Internal resolution is the only pathway the practice controls. Patients can escalate externally without the practice's agreement.
• AHPRA is not a general complaints body. A notification to AHPRA is only warranted when a complaint raises notifiable conduct under section 140 of the Health Practitioner Regulation National Law: practising while intoxicated, sexual misconduct, a health impairment placing the public at risk of substantial harm, or a significant departure from accepted professional standards. Most complaints do not meet this threshold.
• Complaint records must be stored separately from the patient's clinical file, retained for a minimum of 7 years from the date of last service, and protected in accordance with APP 11 security safeguards under the Privacy Act 1988 (Cth).
• Conditional accreditation for a QI1.2 finding is avoidable. Surveyors require a written policy, an operational register, and meeting notes showing at least one complaint led to a documented improvement action.

Every GP practice receives patient complaints. Most can be resolved with a prompt, direct response. The practices that end up before a state Health Complaints Commissioner are rarely those with the most serious clinical problems. They are usually the ones that failed to respond at all.

Under Criterion QI1.2 of the RACGP Standards for General Practices (5th Edition), every accredited practice must have a documented system for receiving, managing, and responding to patient feedback and complaints. The RACGP 6th Edition, available for assessment from 2026, maintains equivalent requirements. Surveyors assess whether the system is operational, not merely written. This guide covers what a compliant system must include, how the three external escalation pathways work, and what the complaints register must contain.

What RACGP Accreditation Requires

Criterion QI1.2 requires practices to have a system for receiving and responding to patient feedback and complaints. In practice, surveyors check four things.

A written complaints handling policy. The policy should name the person responsible for receiving complaints, the acknowledgement and response timeframes, the investigation process, and how patients can escalate if dissatisfied with the practice's response. The ClinicComply complaints handling policy template is built to the QI1.2 standard.

Multiple complaint channels. Patients must be able to raise concerns verbally, in writing, by email, or anonymously. Signage in the waiting area telling patients how to complain is a routine requirement that surveyors commonly note as absent.

A maintained complaints register. The register must be a continuous record, not assembled in the weeks before a survey visit. A register with no entries, if accurate, is acceptable. One last updated two years ago is not.

Evidence of quality improvement from complaints. At least one example of a complaint informing a change to a policy or process, documented in meeting notes with a named responsible person, satisfies this requirement. This connects directly to the broader CQI obligations described in the clinical audit guide for RACGP accreditation.

For a rapid gap assessment across QI1.2 and all other accreditation criteria before your next survey visit, use the RACGP Accreditation Quiz.

The Internal Resolution Process

Internal resolution is the first and preferred pathway. A patient who receives a prompt, genuine response is far less likely to escalate. Most complaints involve communication failures, wait times, or billing disagreements and are solvable at the practice level.

When a complaint arrives, the practice should:

1. Record it in the complaints register immediately, regardless of whether it was verbal or written
2. Acknowledge receipt to the patient within 5 business days, stating what will happen next and by when
3. Investigate: review the clinical record, speak with the relevant practitioner, and check any applicable policies
4. Provide a written response within 30 days covering what was found and what the practice is doing as a result
5. Inform the patient of external complaint options if they remain dissatisfied

An apology, where appropriate, is part of good medical practice. In most Australian states and territories, civil liability legislation protects good-faith expressions of regret from being used as admissions of liability. Withholding an apology to avoid legal exposure frequently makes complaints worse.

Complaint records must be stored separately from the patient's clinical file. They contain sensitive health information and are subject to APP 11 security safeguards. Keep them in a restricted folder that the complaints register cross-references but the clinical record does not.

When Complaints Go to State Commissioners

A patient who is not satisfied with the practice's response, or who chooses not to raise the matter internally, can take their complaint to the relevant state or territory body. They do not need the practice's agreement. Each jurisdiction operates a distinct body:

• New South Wales: Health Care Complaints Commission (HCCC), established under the Health Care Complaints Act 1993 (NSW)
• Queensland: Office of the Health Ombudsman (OHO), which is the single entry point for all health complaints in Queensland and coordinates directly with AHPRA
• Victoria: Health Complaints Commissioner (HCC)
• South Australia: Health and Community Services Complaints Commissioner (HCSCC)
• Western Australia: Health and Disability Services Complaints Office (HaDSCO)
• Tasmania, Northern Territory, ACT: Each jurisdiction has a dedicated health complaints body; contact details are available through healthdirect.gov.au

When a state commissioner receives a complaint about a registered practitioner, the commissioner notifies the relevant AHPRA National Board. Both bodies then decide which is better placed to manage the matter. Queensland is distinct: the OHO receives all notifications first and determines whether the matter is a registration concern or a service quality issue.

A practice contacted by a state commissioner must respond promptly and cooperate fully with any request for documentation. In most jurisdictions, non-cooperation with a commissioner investigation can be referred to AHPRA as a separate concern. Involve your medical defence organisation before responding to a formal investigation.

When a Complaint Involves AHPRA

AHPRA regulates practitioner registration, not service quality. A patient can lodge a notification directly with AHPRA, but most patient complaints fall outside AHPRA's jurisdiction.

A notification to AHPRA becomes relevant when a complaint raises notifiable conduct under section 140 of the Health Practitioner Regulation National Law. Notifiable conduct is defined as: practising while intoxicated by alcohol or drugs; engaging in sexual misconduct in connection with practice; placing the public at risk of substantial harm due to an impairment; or practising in a way that constitutes a significant departure from accepted professional standards.

A dispute about a referral, a billing disagreement, or dissatisfaction with communication does not constitute notifiable conduct. The employer notification obligations and the distinction between mandatory notifications and general complaints are covered in detail in the AHPRA registration and mandatory notification guide.

Where a complaint may meet the notifiable conduct threshold, document the assessment, involve your medical defence organisation, and decide whether to notify. Failing to notify when the threshold is met is an offence under the National Law.

The Complaints Register: What It Must Contain

The complaints register is the primary QI1.2 evidence document. A compliant entry for each complaint records:

1. The date received and the method (verbal, written, email, anonymous)
2. A brief description of the issue raised
3. The practitioner or service area involved, if identified
4. The date acknowledgement was sent to the patient
5. A summary of the investigation steps taken
6. The date and content of the formal response
7. The outcome and any quality improvement action taken

Entries should be completed at each stage, not retrospectively. Retain complaint records for a minimum of 7 years from the date of last service for adult patients, and until the patient's 25th birthday for records created when the patient was a minor. Restrict register access to the practice manager and clinical leadership.

The compliance calendar tool lets you map your next accreditation survey date, policy review deadlines, and record retention milestones alongside your other regulatory obligations.

How ClinicComply Helps

A compliant complaint system requires a written policy, an operational register, and documented evidence linking complaints to improvement actions. Most practices have the policy. The register goes unmaintained, and the improvement action never gets written down.

ClinicComply's complaint management module lets you log each complaint at the time it arrives, record acknowledgement and response dates against the practice's committed timeframes, assign the investigation as a task to the responsible team member, and link the quality improvement outcome directly to the complaint record. Every complaint from the accreditation period is in one auditable place when the surveyor asks.

For broader accreditation preparation, the guide to common RACGP accreditation failures covers the other criteria where practices most often receive conditional findings. The RACGP 6th Edition standards guide explains what changes between editions and how to prepare for assessment.

Start a free 30-day trial at cliniccomply.com.au/signup to manage your complaints register and QI1.2 evidence in one system.

Frequently Asked Questions

What does RACGP Criterion QI1.2 require for patient complaint handling?

Criterion QI1.2 of the RACGP 5th Edition Standards requires every accredited practice to have a documented system for receiving and responding to patient feedback and complaints. The system must include multiple complaint channels, a written policy with defined timeframes and escalation pathways, a maintained complaints register, and evidence that at least one complaint has informed a quality improvement action. The RACGP 6th Edition, available for assessment from 2026, maintains equivalent requirements.

How quickly must a GP practice respond to a patient complaint?

Best practice is acknowledgement within 5 business days of receiving the complaint. The acknowledgement does not need to resolve the matter; it confirms receipt and outlines what the practice will do next. A full written response should follow within 30 days. If the investigation will take longer, inform the patient of the revised timeframe in the acknowledgement rather than letting the 30-day mark pass without contact.

What must the complaints register contain?

The register must record for each complaint: the date received, the method of lodgement, a description of the issue, the practitioner or service area involved, the acknowledgement date, a summary of the investigation, the date and content of the formal response, the outcome, and any quality improvement action taken. Entries should be completed at each stage as the complaint progresses. A register assembled retrospectively before a survey visit is recognisable to experienced surveyors.

Can complaint records be stored in the patient's medical record?

No. Complaint records must be stored separately from the patient's clinical file. They contain sensitive health information subject to the Australian Privacy Principles, and access should be restricted to the practice manager and clinical leadership. The patient's right to access their own health information does not automatically extend to the practice's internal investigation records, though the substantive findings of a complaint response may overlap with both.

When should a complaint be reported to AHPRA?

Only when the complaint raises notifiable conduct under section 140 of the Health Practitioner Regulation National Law. Notifiable conduct is defined as: practising while intoxicated, engaging in sexual misconduct in connection with practice, having an impairment placing the public at risk of substantial harm, or practising in a way constituting a significant departure from accepted professional standards. Most patient complaints, including disputes about referrals, wait times, billing, or communication, do not meet this definition. Where the threshold may be met, involve your medical defence organisation before deciding whether to notify.

Is an apology an admission of liability in Australian healthcare?

No. Most Australian states and territories have civil liability legislation protecting good-faith expressions of regret from being used as admissions of liability. In Victoria, section 14J of the Civil Liability Act 2002 (Vic) provides this protection. Similar provisions exist in New South Wales under the Civil Liability Act 2002 (NSW) and in South Australia under the Civil Liability Act 1936 (SA). A timely apology frequently de-escalates a complaint. Withholding one to avoid legal exposure is a strategy that often produces the opposite result.

What is the difference between a state Health Complaints Commissioner and AHPRA?

State Health Complaints Commissioners handle complaints about the quality of health services and focus on whether a service was delivered appropriately and how concerns can be resolved. AHPRA regulates practitioner registration and focuses on conduct, fitness to practise, and registration status. When a state commissioner receives a complaint about a registered practitioner, it notifies the relevant AHPRA National Board and both bodies decide which is better placed to manage the matter. In Queensland, the OHO is the single entry point for all complaints and notifications.

Does RACGP accreditation require a practice to resolve every complaint to the patient's satisfaction?

No. Accreditation under QI1.2 requires that the practice has a system, operates it consistently, documents the steps taken for each complaint, and demonstrates that complaints have informed quality improvement. A complaint investigated thoroughly, responded to in writing, and used as the basis for a documented process improvement satisfies the criterion even if the patient remained dissatisfied with the outcome. The obligation is to handle complaints properly, not to resolve every dispute in the patient's favour.