The principles

They must be satisfied that their complaint will be investigated thoroughly and impartially and that there will be a result

The thrust of the Regulations is to encourage a culture in which feedback from patients is actively invited and facilitates service improvements. Frontline staff should be trained and empowered to deal with verbal complaints on the spot if possible.

1 – Accessible

To be accessible, your complaints procedure must be visible, but it is not enough merely to display notices and leaflets pointing to one avenue for complaining. To be truly accessible, potential complainants need multiple access points and, more importantly, a perception that they will be heard, that their views will be respected and they will not be discriminated against for raising their concerns. They must also trust that it is worth doing – ie, they must be satisfied that their complaint will be investigated thoroughly and impartially and that there will be a result.

Here is an example of a notice that reflects the spirit of the legislation.

Compliments, Comments, Concerns and Complaints

We aim to provide patients with the best care we can, but we will sometimes fall short of the mark. If you have any compliments, comments, concerns or complaints about our service, we want to hear about it.

We would encourage you to speak to whoever you feel most comfortable with – your doctor, a nurse, a receptionist or manager – but if you would prefer to give your feedback in writing, please send it to the Practice Manager, Peter Brown, at the address below. You can also send us a message via the practice website or by filling in one of the forms in the waiting room and putting it in the box marked “Feedback”.

If you have a complaint to make, please don’t be afraid to say how you feel. We welcome feedback to help us improve our standards and you will not be treated any differently because you have complained. We will just do our best to put right anything that has gone wrong. Alternatively, you have the right to approach the Primary Care Trust and raise your complaint directly with them.

  

It helps if your leaflets and website contain some guidance about information to include in a complaint

Access should be simple, whether it be by talking to a member of staff directly, sending an email or letter, or by filling in an online or paper form. It helps if your leaflets and website contain some guidance about information to include in a complaint – what happened, when, where, who was involved, what was the outcome, what the complainant would like you to do, etc. You should also outline what they can expect to happen next, including issues of confidentiality and consent to share information.

Thought must also be given to accessibility for people with language or learning difficulties. Written material should be in the main languages used by your local population and you should also have easy read and larger print versions for patients who have difficulty reading. On a more subtle level, an atmosphere of openness and courtesy, with staff who are trained to respond to signs of annoyance or dissatisfaction and who convey a willingness to listen, are important aspects of accessibility.

2 – Flexible and responsive

The amount of time and effort you spend on investigating and resolving the complaint should be proportionate to its seriousness

Tailor your complaint handling to suit the particular circumstances. The amount of time and effort you spend on investigating and resolving the complaint should be proportionate to its seriousness.

Conducting a risk assessment using the matrix in Appendix 3 will help you evaluate the seriousness of a complaint. Some complaints will take longer to resolve than others and the timescale should be discussed and agreed with the complainant at the outset if possible. The sign-off letter should cover all the issues raised and contain a full explanation written in a clear, jargon-free style. An apology should be given, along with an explanation of what you are doing to put things right.

Even if the investigation shows that the complaint was groundless, the complainant should still be thanked for giving you the opportunity to look into the matter and to clear up any misunderstandings. The letter should also provide details about the Ombudsman and advocacy (eg ICAS).

3 – Lessons learned

Review your complaints log periodically to see if trends and themes have emerged

Compliments, comments, concerns or complaints – whether they are minor issues dealt with on the spot or more serious complaints requiring investigation and a formal response – should be recorded and used to inform service improvements. It is good practice to review your complaints log periodically to see if trends and themes have emerged over time that indicate a recurring or persistent problem that should be addressed.

All feedback should be discussed in practice meetings. Some issues can stimulate immediate changes, but others might require analysis to identify the underlying causes of a problem. There are two methods for doing this – a significant events audit (SEA) or a root cause analysis (RCA). Detailed guidance on conducting an SEA or RCA can be found on the National Patient Safety Agency’s website, along with templates and online tutorials, at www.npsa.nhs.uk. Much of this guidance can also be usefully applied in the investigation of a complaint.

4 – Co-ordinated handling

Now that all NHS organisations (including voluntary and independent sector organisations under contract) and social services in England are all governed by the same legislation, co-ordinated complaint handling should be easier to achieve than it was in the past.

You must operate within the bounds of the legal and professional framework governing the use of personal information

When you receive a complaint that involves other organisations, you should (with the patient’s consent) copy the complaint and your acknowledgement letter to the organisations concerned. They will institute their own investigations, but you might need to share records between you to facilitate a co-ordinated approach.

If so, you must operate within the bounds of the legal and professional framework governing the use of personal information. Your PCT is likely to have an interagency information-sharing protocol that you should follow. If not, you should ask your Caldicott Guardian for guidance.

The most effective way of co-ordinating the complaint handling is for the agencies concerned to agree which of them will take on the lead role, and be responsible for making sure that the complaint handling stays on track and for keeping the complainant informed about progress. An effective way of achieving this co-ordination would be to share a complaints manager in partnership with other agencies in your locality. Alternatively you could approach your PCT to ask if they would co-ordinate on your behalf.

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