In Reconnecting The Customer ACMA comments (better late than never) that -
consumer complaint levels in the Australian telecommunications industry are far too high and ... poor customer care (both directly and indirectly) drives many consumers to complain. Poor performance in these areas imposes real and significant costs on consumers. It also imposes unnecessary costs on industry.ACMA goes on to ask -
why is the quality of customer care being provided by telecommunications companies failing to meet consumers’ expectations when the services they provide generally do?It notes that -
While it is evident that complexity, convergence and the rapid growth in both new services and demand have had a profound impact on the industry and, in turn, on consumers, these matters alone cannot entirely explain or excuse the level of consumer dissatisfaction in the sector.Stirring words, albeit used by ACMA in the past.
Australia is not alone in dealing with these challenges — regulators and service providers in other jurisdictions are also grappling with such changes. In some overseas jurisdictions, however — where the number of services in operation is significantly higher than in Australia — the comparable number of consumer complaints is considerably smaller. This suggests that telecommunications companies in those jurisdictions may be offering a level of customer care that meets their customers’ expectations. The evidence before the inquiry suggests that in Australia they are not.
The way in which the telecommunications industry in Australia deals with its customers must change, and change immediately.
What is ACMA going to do? It's going to consider! It's heartened by -
some encouraging signs that at least some industry providers recognise that they have a problem with customer care, and have enacted certain measures and announced plans to improve their performance. These individual initiatives are hopefully a springboard for changes to occur right across the industry.Hope springs eternal in every ACMA breast. The regulator announces (I won't be churlish and say announces proudly) that -
It is evident to the ACMA from its observer status in the Telecommunications Consumer Protection Code review that industry has committed to improving consumer outcomes in this review and the ACMA is encouraged by this.It is apparently prepared to do more, given that "neither action by individual service providers nor enhanced code rules are of themselves likely to be sufficient to drive the necessary change to regain consumers’ trust and confidence, and to encourage competition and innovation in customer care in the Australian market". It won't however do much more. The solution to market failure is apparently -
When industry submits the revised draft TCP Code for registration, the ACMA will carefully consider those measures that are intended to improve consumer outcomes, as well as the likelihood of them being successful in immediately delivering the necessary improvements. The Authority will also consider industry’s proposals for the code against the proposals in this report for effecting lasting behavioural change.
the imposition of some regulatory buttressing of industry-initiated actions and the articulation of minimum expectations.ACMA will focus on two key areas -
• identifying and addressing the key underlying drivers of complaintsThat focus reflects perceptions that -
• identifying and addressing the customer care matters that consumers rank as most important to being satisfied with the quality of service received.
many consumers have incorrect (but not unreasonable) expectations about key features of their products. Many also have insufficient information to be able to make an informed choice that will suit their needs. By improving the information available, it is expected that one of the key drivers of complaints — the lack of clear and comparable information—will be addressed, and consumers will be able to more effectively assess and choose products that meet their needs.It also reflects an assessment that -
consumers receiving unexpectedly high bills — colloquially known as 'bill shock', which probably causes the most consumer harm. Addressing the underlying causes of bill shock is likely to lead to significantly fewer complaints.Attention to dispute resolution mechanism is also important -
Consumers value most highly being able to have issues resolved satisfactorily in a timely way. Many told of making requests that were not acted on; receiving inaccurate, inconsistent or incorrect advice; and being unable to rely on promises or undertakings from their service provider. Often these matters start as straightforward enquiries or requests but escalate as the matter remains unresolved.Those revelations are hardly new and ACMA's inattention or regulatory incapacity over several years raises questions about the effectiveness of the regime.
Many consumers also find it difficult to have a complaint they have made escalated to the service provider’s formal complaints-handling processes. For most consumers, complaints-handling is simply a part of good customer care. If matters are identified
and handled formally in the first instance, it is more likely that they will be resolved satisfactorily. If not, then they are more likely to be escalated to the industry’s dispute resolution scheme, the TIO.
It is essential that complaints-handling processes meet certain benchmarks. Improving the way in which complaints are identified, handled and recorded will not only improve consumer outcomes, but help service providers to identify and address problems that cause consumers to complain. It should also significantly reduce the number of complaints escalated to the TIO.