16 November 2023

The NHMRC Complaints Policy sets out how NHMRC manages complaints about its activities, policies and decision-making. 

1. Purpose

The purpose of this policy is to provide information to stakeholders about how the National Health and Medical Research Council (NHMRC) manages formal complaints.

The policy outlines how NHMRC manages:

  • general complaints about our policies, services, guidelines and advice
  • research funding complaints about NHMRC research funding processes and the administration of funding schemes delivered by NHMRC.

This policy has been developed with reference to the Commonwealth Ombudsman’s Better Practice Guide to Complaint Handling.

This policy does not cover:

2. Principles

The NHMRC Complaints Team facilitates the management of complaints, working across NHMRC as required. Members of this team, as with all NHMRC staff, are bound to conduct their duties in accordance with the Australian Public Service Values and Code of Conduct, as set out in in the Public Service Act 1999.

The following guiding principles apply to complaints handling in NHMRC:

  • visibility and accessibility: information about how to make a complaint will be readily available and the complaints process will be straightforward
  • responsiveness: receipt of each complaint will be acknowledged in a timely manner and complaints will be addressed promptly
  • objectivity: each complaint will be addressed in a fair, equitable and unbiased manner throughout the complaints process
  • confidentiality: personal information concerning a complaint will be available to NHMRC officers only where needed for the purposes of addressing the complaint and will be actively protected from disclosure outside the NHMRC, unless such disclosure is consented to or is required by law.

In addition to resolving individual complaints, NHMRC will use complaint investigations to consider whether there are quality improvements that could be applied to NHMRC activities.

3. General complaints

General complaints about NHMRC may relate to any aspect of our work, including our policies, services, guidelines or advice, other than complaints related to research funding processes, which are provided for under Section 4 of this policy.

3.1 How to make a complaint

If you have a concern about any aspect of NHMRC’s work, NHMRC encourages you to contact the NHMRC team involved by phone or email to discuss your concerns.

If this is not appropriate for your particular concern, or if you consider your concern has not been addressed, you can make a formal complaint in writing to NHMRC by:

  • using the online NHMRC complaints form via Contact us
  • emailing the Complaints Team at complaints@nhmrc.gov.au, or
  • writing to the Complaints Team at NHMRC, GPO Box 1421, Canberra, ACT, 2601.

Note:

  • Anonymous or pseudo-anonymous complaints can be made, but NHMRC may not be able to properly investigate (if we need further information) or respond to you.  
  • Complaints may not be investigated where a complainant re-raises an issue with NHMRC if that matter has already been considered and responded to by NHMRC and there is no new information to consider. 

3.2 How complaints are managed

The Complaints Team is the primary contact point for lodgement of and enquiries regarding general complaints about NHMRC.

Once a complaint is received, the Complaints Team will:

  • acknowledge receipt of your complaint, and
  • depending on the nature of the complaint or any critical timeframe for its resolution, either:
    • refer the complaint to the relevant area of NHMRC for a response, if this would result in the most effective and efficient handling of your concerns, or
    • respond to you about the matters raised, or
    • investigate the matters raised and then respond to you.

NHMRC aims to respond to complaints in writing within 30 days, however, this is not always possible and we will seek to keep you informed of progress if a matter will take longer to resolve.

Where the relevant area in NHMRC responds to the complaint – as noted in section 3.1 above, if the complainant is still dissatisfied with the response, they may ask the Complaints Team to re-consider the complaint.

Where the Complaints Team investigates the complaint –

  • information will be gathered from the relevant team at NHMRC and assessed against the details of the complaint
  • the merits of the complaint and potential resolutions will be determined, informed by the available information
  • you will be informed in writing of the outcome of the investigation.

3.3 Review rights

If you consider that your concerns have not been addressed, you may raise your complaint with a body outside the NHMRC, see section 5. External review for further information.

4. Research funding complaints

This section relates to complaints about any aspect of NHMRC’s research funding processes, including the administration of funding schemes delivered by NHMRC for third parties. This includes complaints that relate to the application and peer review processes and to grant administration.

4.1 Who can make a complaint

Any participant in the research funding grant application or peer review process may make a complaint, including:

  • Administering Institutions – this includes complaints made on behalf of Chief Investigators or Fellows
  • NHMRC peer reviewers
  • independent observers of NHMRC peer review
  • NHMRC staff.

If a research supervisor wishes to raise a complaint on behalf of another person, they must provide written permission from that person, noting that the complaint should be submitted to NHMRC through the Administering Institution’s RAO (see section 4.2).

4.2 How to make a complaint

Applicants who are concerned about NHMRC processes or funding outcomes are encouraged to talk to their Administering Institution’s RAO about their concerns before commencing the complaint process.

Complaints to the NHMRC about research funding will only be considered if they are submitted to NHMRC through your Administering Institution’s RAO. This step is to enable the RAO to advise the complainant whether the complaint is valid and provide the complainant with any information NHMRC has previously provided the institution in relation to the issue/s intended to be raised.

Ideally, research funding complaints should be made within 28 calendar days of any NHMRC decisions or action they relate to, noting that the longer the lapse of time before the complaint is made, the more difficult it may be to resolve.

The following information should be included: 

  • NHMRC funding scheme (or NHMRC-administered third party funding scheme)
  • application year
  • application or grant identification number
  • complainant’s name
  • complainant’s role on the application, grant, or in the peer review process
  • details of the complaint, including reasons/justification of position
  • how the complainant would like the complaint resolved
  • detail of any time-sensitive circumstances pertaining to the complaint.

4.3 Complaints about peer review

NHMRC assigns grant applications to independent peer reviewers based on the peer reviewers self-declared suitability, including consideration of any declared conflicts of interest.

In some NHMRC schemes, peer reviewers are asked to provide written feedback, highlighting their opinion of the strengths and weaknesses of an application. Written feedback is intended to support applicants when drafting future applications.

Complaints about the process of peer review can be considered under this policy. However, NHMRC will not:

  • investigate complaints about the merits of written feedback provided by independent peer reviewers or the subsequent application outcome
  • provide scores from an individual peer reviewer for an application except if explicitly permitted by the relevant grant guidelines
  • reveal the identities of peer reviewers through the complaints process.

4.4 How complaints are managed

On receipt of a research funding complaint, the NHMRC Complaints Team will:

  • acknowledge the complaint, and
  • depending on the nature of the complaint or any critical timeframe for its resolution, either:
    • refer the complaint to the relevant area of NHMRC for a response, if this would result in the most effective and efficient handling of your concerns, or
    • investigate the matters raised and then respond to you.

Where the relevant area in NHMRC responds to the complaint – If the complainant is still dissatisfied with this response, they may ask the Complaints Team to re-consider the complaint.

Where the Complaints Team investigates the complaint –

  • information will be gathered from the relevant team at NHMRC and assessed against the details of the complaint
  • the merits of the complaint (not the merits of the independent peer review assessment) and potential resolutions (if any) will be determined, informed by the available information
  • where relevant and feasible, grant applications will continue to progress through the assessment process while complaints are under investigation by the Complaints Team
  • we will aim to respond to the complainant in writing within 30 days, noting that the length of time taken to resolve a complaint will depend on the nature and complexity of the issues raised. We will seek to keep you informed of progress if a matter will take longer to resolve.

What happens if my complaint is upheld?

Complaint resolution will depend on the nature of the complaint and whether the application is in the assessment process when the complaint is received. As noted in section 4.2, ideally, research funding complaints should be made within 28 calendar days of any NHMRC decisions or action they relate to, noting that the longer the lapse of time before the complaint is made, the more difficult it may be to resolve.

As noted in section 4.4, where relevant and feasible, applications will continue to progress through the assessment process, including peer review, while complaints are under investigation by the Complaints Team.

If a complaint is upheld while the assessment process is ongoing, NHMRC will endeavour to resolve the matter in a way that minimises any adverse impact on the applicant and/or peer reviewers.

If a complaint is upheld after the assessment process has concluded, NHMRC will determine the likely impact of the process error on the application’s outcome and will assess if a remedial action can (or should) be applied.

Regardless of whether the complaint is upheld or not, NHMRC will write to you, via your Administering Institution’s RAO, advising of the decision and review rights.

4.7 Review rights 

If you consider that your research funding complaint has not been addressed, you may choose to raise your complaint with the NHMRC Commissioner of Complaints (the Commissioner). Alternatively, you may choose to make your complaint to an external review body, see section 5. External review.

The Commissioner is an independent position established under Part 8 of the NHMRC Act. The Commissioner may investigate complaints concerning action taken by the NHMRC CEO, their delegate or the NHMRC Research Committee in relation to a funding application.

Information on the steps, and the grounds, for making a complaint to the Commissioner can be found at NHMRC Commissioner of Complaints.

Notes

  • An application being considered by the Commissioner is not considered by NHMRC to be an ‘active’ application. Having an application under consideration by the Commissioner does not impact applicants’ eligibility to apply to future grant rounds.
  • The Commissioner cannot consider decisions taken in respect of Medical Research Future Fund (MRFF) applications. The Commonwealth Ombudsman is the appropriate external review body for concerns about MRFF applications. This is because the role of the Commissioner is established under the NHMRC Act to review actions taken by the NHMRC CEO, their delegate or by NHMRC’s Research Committee and neither NHMRC’s CEO nor Research Committee is the decision-maker for MRFF applications.

Can I complain directly to the Commissioner, without first approaching NHMRC?

Yes, but the Commissioner may choose not to investigate a complaint if the complainant has not approached NHMRC with the complaint in the first instance and the Commissioner is satisfied that it would be reasonable for the complainant to do so. Most complaints are resolved by NHMRC internally without the need to seek review by the Commissioner.

How can I lodge a complaint with the NHMRC Commissioner of Complaints?

Details on how to lodge a complaint with the Commissioner are available at NHMRC Commissioner of Complaints. Complainants are strongly encouraged to make any complaint to the Commissioner through their Administering Institution’s RAO. If this is not done, the complainant should notify their RAO that a complaint has been made to the Commissioner.

5. External review  

You may choose to make your complaint to a body outside the NHMRC, including if you consider that your research funding complaint has not been addressed by the response you have received from NHMRC or from the Commissioner of Complaints.

Depending on the type of complaint you are making, bodies which may be able to consider your concerns include:

Australian Information Commissioner and Privacy Commissioner

Website: https://www.oaic.gov.au/

Online enquiry form: https://www.oaic.gov.au/about-us/contact-us/

Telephone: 1300 363 992

Postal: GPO Box 5218 SYDNEY NSW 2001

Commonwealth Ombudsman

Website: https://www.ombudsman.gov.au/

Online enquiry form: https://www.ombudsman.gov.au/contact

Telephone: 1300 362 072

Scheme for Compensation for Detriment caused by Defective Administration

Applications under the Scheme for Compensation for Detriment caused by Defective Administration (the CDDA Scheme) should be made directly to the NHMRC. Further information about the CDDA Scheme is on the Commonwealth Department of Finance's website.

6. Contacting NHMRC

General enquiries and feedback

Feedback form: Contact us

Email: nhmrc@nhmrc.gov.au

Telephone: 13 000 NHMRC (13 000 64672) or +61 2 6217 9000 for international callers

Postal: GPO Box 1421 Canberra ACT 2601

Research funding enquiries (Research Help Centre)

Website page: Research Help Centre

Email: help@nhmrc.gov.au

Complaints Team

Email: complaints@nhmrc.gov.au or use the online complaints form

Telephone: 13 000 NHMRC (13 000 64672) or +61 2 6217 9000 international callers

Postal: GPO Box 1421 CANBERRA ACT 2601