Managing Complaints, Concerns and Compliments Policy (POL-021)

Purpose

Healios is committed to the promotion of client welfare and the delivery of a high quality and safe clinical service.

When concerns or complaints are raised, the organisation has a responsibility to acknowledge the concern or complaint, be open and transparent, improve the quality of care,  identify learning, prevent recurrence and identify service improvements.

Aim

The aim of this policy outlines our commitment to dealing with complaints about the service provided by Healios. It also outlines the process for the receipt and management of compliments and complaints.

This policy aims to ensure :

• all complaints are well managed as quickly as possible and in accordance with national assurance frameworks
• colleagues are empowered to deal with complaints as they arise in an open and non defensive way
• learning from complaints is identified and used for improvement
• the complaints service is accessible, well publicised, open and transparent
• the complaints procedure is supportive for those who find it difficult to complain

When dealing with complaints we aim to adhere to NHS England’s organisation values, principles, and follow the ‘Good Practice Standards for NHS Complaints Handling’

We support the Parliamentary and Health Service Ombudsman’s Principles of Good Complaints Handling which includes a number of clients’ rights relating to complaints.

Scope

This policy applies to all staff employed within Healiios including those within an associate or  agency  role.

Associated processes, policies or legislation

• Standard Operating Procedure – Managing Complaints
• Standard Operating Procedure -Contested Outcomes

Definitions of Keywords

A concern is a problem, which can be dealt with more quickly and informally. All concerns will be documented and reviewed for trends.

A complaint is an expression of dissatisfaction that requires a more formal response. It is usually a problem which has not yet been resolved, or which may  concern past treatment.

Local Resolution is the investigation and resolution of complaints under the first stage of the complaints procedure. It includes everything we do locally, before a complaint is considered by the Parliamentary Health Service Ombudsman (PHSO).

A complainant is a person who raises a complaint.

The Ombudsman refers to the Parliamentary and Health Service Ombudsman (PHSO) who are the final stage of the complaints procedure. If Healios is unable to resolve a complaint and local resolution has been exhausted, the only available option to the complainant would be to approach the Ombudsman and request a review. The Ombudsman will assess if Healios has acted fairly in the complaint investigation and if the response has adequately addressed the complaint.

A compliment is an expression of praise, commendation, or admiration. All compliments will be recorded for trend analysis

Time Limit of initiating complaints

In order that an effective and meaningful investigation can take place a complaint should be made as soon as possible and within 12 months of the date of the event complained about, or as soon as the matter first came to the attention of the complainant.

Types of complaints

Complaints can be expressed in the following format :-

• Informal – minor comments/verbal criticisms
• Informal – patient feedback systems
• Formal –   verbal or written

Informal- Minor comments/verbal criticisms

Team Managers  will take the role of investigation lead, with support for Head of Departments where required.

Even those complaints that appear low impact MUST be managed sympathetically and it will frequently be possible to provide an explanation and acceptable answer at the time.

Minor comments and verbal criticisms should be dealt with at local level. These comments may be made in person, on the phone or via email. Comments made via the organisation website will be followed up by Team Managers. Complaints made via social media platforms monitored by the marketing department and directed to the Clinical Governance Team to manage.

Invariably patient concerns regarding treatment outcome can be dealt with by simply arranging a review appointment with the clinician.

It is important to ensure that if the client requires a response that this is delivered in the timeline agreed.  This response should be made verbally to the client, not by any other means of communication. Details should be documented on the electronic patient record system with the action taken and outcome.

Healios’ target is to resolve and respond to informal complaints in writing within ten working days. This is recorded via the complaint log.

Friends and Family Test

Healios uses its own bespoke platform, Panacea, to receive feedback on Friends and Family Test (FFT).  The data and feedback is available for the services  to access and review. It is the responsibility of the Team Managers to ensure that this data is shared with the staff  in monthly  team meetings to highlight areas of good practice and to recognise opportunities for improvements to be made.

Feedback where a concern has been highlighted must be reviewed, and if appropriate, used as means to improve the service either by carrying out a service review, clinical audit and/or complaint investigation. This must be demonstrated in practice and displayed visually for example, using the “you said, we did”, methodology.

Feedback is reviewed as part of our Client experience Group and reported monthly within our Quality and Assurance reporting .

Formal complaints procedure and summary

The Clinical Governance Team will convene a complaint review panel and co-ordinate all necessary processes . In addition they will establish contact with the complainant (as appropriate) to ascertain  the outcome that the complainant would hope to achieve.  All acknowledgements and the final response will be sent by the Clinical Governance team.

8.1 Stage 1-Local Resolution

• All clients who wish to complain formally will be advised to make their complaint
• In writing preferably to the Clinical Governance Department at Healios Ltd., Vintage House, 36-37 Albert Embankment, London, Greater London, SE1 7TL detailing the Patient’s Name, Address and Date of Birth
• By email and should be sent to [email protected] detailing the  Clients (YP/Family) Name, Address and Date of Birth. For reasons of data protection and patient confidentiality, we will only acknowledge receipt of the complaint by email. Response/s will be sent via email
• Complaints from an authorised representative can only be accepted with the written consent of the patient concerned.
• An email acknowledgement will be sent within 3 working days.
• We will undertake an immediate investigation into the concerns provided and, once all relevant records and reports have been compiled, the investigation lead will carry out a review. It may also be necessary to take advice from other Clinical Specialists within Healios.
• On completion of the investigation review, the complainant will receive an email  from the Clinical Governance Team , within 20 working days of receiving the complaint. (This timescale does not include Weekends or Bank Holidays). This response will contain a full written account of the outcome of the investigation, an apology for any deficiencies, and an explanation of remedial action taken.
• On any occasion when a written response cannot be provided within this timescale, we will inform the client  of the status of the complaint at a minimum of 20 working day intervals and aim to reach a timely conclusion.
• Clients that are unhappy with comments from the Stage 1 response should email concerns to the above email address. An acknowledgment will be sent within 3 working days. A further response addressing additional issues raised will be sent within 20 working days.
• Safeguarding concerns identified will be managed by Healios’ internal process.

  8.2 Stage 2 – Internal Appeal

If, following receipt of the final response from the Clinical Governance Team , a client wishes to seek a review of Stage 1 they should email the Head of Clinical Governance who will undertake a  Stage 2 review.

• This request should be made within 6 months of the final written response, stating the reason why they are not satisfied with the Stage 1 handling of the complaint.
• A written acknowledgement will be sent within 3 working days
• The Head of Clinical Governance will undertake an immediate review into the outcome provided at Stage 1 by the investigation panel.
• The Head of Clinical Governance will respond, following review, within 20 working days of receiving the letter, to confirm the decisions and actions taken by the Clinical Governance Team or to offer an alternate resolution.
• Where the investigation is still in progress and a decision has not been made, the  Head of Clinical Governance will send a letter explaining the reason for the delay to the complainant, at a minimum every 20 working days.
• If the Head of Clinical Governance confirms the decision of the original complaint response , the client has the right to take the matter to Independent External Adjudication (Stage3).

8.3 Stage 3 – Independent External Adjudication:

NHS Clients

Complainants who are dissatisfied with Healios’ stage 1 and stage 2 response may ask the Parliamentary and Health Service Ombudsman  (PHSO) for an independent review of their complaint. The PHSO is an independent body established to promote improvements in health care through the assessment of the performance of those who provide services.

Contact Details for Each Region

England 

The Parliamentary and Health Service Ombudsman

Millbank Tower

Millbank London

SW1P 4QP

Phone: 0345 015 4033

E-mail: [email protected]

Scotland
SPSO,
Bridgeside House,
99 McDonald Road,
Edinburgh,
EH7 4NS

Phone 0800 377 7330
Email:- www.spso.org.uk/contact-form

Wales
Public Services Ombudsman for Wales
1 Ffordd yr Hen Gae,
Pencoed,
CF35 5LJ

Phone 0300 790 0203.
Email:-[email protected]

Northern Ireland
Northern Ireland Public Services Ombudsman,
Progressive House
33 Wellington Place,
Belfast, BT1 6HN

Phone 0800 34 34 24.
Email:-[email protected]

The Complainant must contact the Ombudsman’s office within 12 months of the incident causing the complaint. The Complainant must explain what they are still not happy about and why ‘Service Line Resolution’ did not work for them. They will advise the Complainant, in writing, what they will do.

Private Clients

Complaints relating to Private Pay services may ask the Centre for Effective Dispute Resolution (CEDR) to review their case. The CEDR provides independent adjudication on  complaints and if the complainant is not satisfied with the complaint review they have the right to refer the matter to independent external adjudication through CEDR. The complaint would need to be made in writing within six months of receiving the final response from Healios.

To contact the Centre for Effective Dispute Resolution (CEDR) please email:[email protected] or telephone 020 7536 6000.

Monitoring compliance and effectiveness

All complaints are reviewed on a monthly basis, with trends and themes identified and reported to relevant committees. Where learnings are identified they are shared with the relevant stakeholders and any training needs highlighted will be addressed.

Duty of Candour

Throughout the investigation process , if it is highlighted that something went wrong that appears to have caused or could lead to significant harm, ” Duty of Candour” will be undertaken which means the organisation will  be open and honest with clients, or their families.

CQC Notifications

If CQC incident reporting notifications  are  identified from the complaint or through the investigation process they will be notified to the CQC by the Clinical Governance Team

EIA

The Equality Impact Assessment helps to ensure that any new policy or policy changes are fair and don’t discriminate against or negatively impact any protected group. Using this tool helps to centre inclusion and equity when reviewing our policies, and consider the intentional and unintentional impact they have. Please click here for the full details of the EIA. An assessment concluded that this policy has a positive impact on all protected characteristic groups.