Complaints, Suggestions and Compliments Policy

INTRODUCTION

 The Complaints, Suggestions, and Compliments Policy and Procedure are uploaded on QCS App and readily available for all staff.  A summary setting out the approach to complaint handling, Complaints Leaflet is available at reception for any patient requesting a copy.

THE POLICY

The purpose of this policy is to have in place a comprehensive system for complaints, compliments, suggestions, and other feedback that informs patients of ways in which their views can be heard, how procedures work, and why all feedback is important to Mediwell Clinic to ensure high quality of care and an excellent Patient experience. Any Patients will not be discriminated against for making a complaint and we will act appropriately on any concerns and where appropriate, make changes to ensure improvements in service delivery.

This necessitates:-

• All team members are trained and supported in the facilitation of complaints procedures and are fully compliant with their own professional, obligatory requirements within their scope of practice.
• Awareness and understanding of the complaints and suggestions procedure and timescales.
• Accurate record keeping.
• Recognizing and acting upon opportunities for change.
• Providing an effective method of identifying and monitoring complaint patterns, trends, and themes together with the evidence to be similarly shared, demonstrating change for service improvement and a better Patient experience based on feedback and suggestions received.
• To implement an honest and open culture within Mediwell Clinic whilst actively seeking and acting upon Patient feedback.

Well-handled complaints can benefit the Practice as well as the Patient resulting in:-

• The opportunity to correct errors and improve standards of service.
• Satisfy the Practice’s Patients.
• A Practice service that is truly customer Patient focussed, that “listens” to and, wherever possible, acts upon people’s concerns.

Poor communication and attitude are often the basis for dissatisfaction, this highlights the need for ensuring that great emphasis is placed on informing and communicating with Patients.

If dissatisfaction does arise everyone within the company must deal with it according to the complaints policy/procedure.

I. Complaints Policy

The primary objective of this procedure is to provide the opportunity for the investigation and resolution of complaints as quickly as possible, aiming to satisfy the patient, whilst being fair to staff. (See Appendix A, Complaints Flow Chart)

Before beginning an investigation, Mediwell Clinic will assess the seriousness of the complaint. If a complainant does not wish to pursue an issue, Mediwell Clinic will investigate the issue to identify what led to the complaint so that Mediwell Clinic can use complaints as part of the learning and improvement cycle to assist in service improvement.

The complainant may be invited to meet with Practice Manager, Semiha Dogus to discuss the complaint. This may be done face-to-face, online, or over the telephone if appropriate. It is important to establish, at the earliest opportunity, what outcome the complainant expects, and to let the complainant know whether this is a realistic and possible expectation.

Complaints can be made either by Patients or by someone who is affected or likely to be affected, by the action, omission, or decision of the responsible body that is the subject of the complaint

Mediwell Clinic will support all members of staff involved in the complaints process.

• Time Limits for Submitting a Complaint

The period for making a complaint is normally:

All complaints should normally be made within 12 months of the date of the event complained about.

The Registered Manager has the discretion to extend the time limits if the complainant has good reason for not making the complaint sooner, or where it is still possible to properly investigate the complaint despite extended delay.

When considering an extension to the time limit it is important that the Registered Manager takes into consideration that the passage of time may prevent an accurate recollection of events by the doctor/clinician concerned or by the person bringing the complaint. The collection of evidence, Clinical Guidelines or other resources relating to the time when the complaint event arose may also be difficult to establish or obtain. These factors may be considered as suitable reason for declining a time limit extension.

Mediwell Clinic will obtain agreement from locum GPs, locum nurses and other temporary clinical staff members for them to participate in the complaints procedure if required, as it is possible that complaints will arise after the locum or temporary member of staff has moved on.

Mediwell Clinic will give locums and temporary members of staff involved in the complaints process every opportunity to respond to complaints with no discrepancy between the way the process treats locums, temporary staff, salaried GPs, GP partners or any other permanent staff members.

A complaint can be received either verbally or in writing and can be made by:

• Patients
• Someone acting on behalf of a Patient with their written consent, for example a relative, advocate or Member of Parliament.
• Someone acting on behalf of a Patient who is unable to represent his or her own interest provided this does not conflict with the Patient’s right to confidentiality or a previously expressed wish of the Patient.

 Complaints can be done via:

• completing our Complaints Form on our website
• emailing: info@mediwellclinic.co.uk
• post
• filing in a copy of our Complaints Form at Reception.
• Phone 02039510203

The procedure for complaints

Local Resolution

• Try to resolve verbal complaints to the complainant’s satisfaction within 24 hours in order to avoid a formal complaints process and as it can be difficult to separate a complaint from a concern , this policy will be followed whenever dissatisfaction is clearly expressed
• All complaints are directed to the designated complaints manager , usually the Practice Manager, Semiha Dogus with Nurten Cetin as the responsible person.
• Make provision for an oral complaint to be committed to writing
• Acknowledge complaints within 3 working days
• A further response will be sent within 20 working days following an investigation of the issues. It should also say who is dealing with it i.e. manager.
• If it is not possible to conclude any investigations within the 20 working days, then the patient should be updated with progress and possible time scales.
• A full investigation should take place with written notes and a log of the progress being made.
• It may be that outside sources will need to be contacted and if that is the case then a patient consent form will need to be signed to make such a request.
• A clear statement of the issues, investigations and the findings, giving clear evidence-based reasons for decisions if appropriate
• Where errors have occurred, explain these fully and state what will be done to put these right, or prevent repetition
• A focus on fair and proportionate the outcomes for the patient, including any remedial action or compensation
• A clear statement that the response is the final one, or that further action or reports will be send later
• An apology or explanation as appropriate
• In the event that the complainant is dissatisfied with the response to their complaint they can request a review of the complaint, and must do so in writing, within 6 months of the response to their complaint.

Internal Complaint Review

• The practice manager will provide a written acknowledgement to complainants within 3 working days of receipt of their complaint at this stage.
• The Practice Manager will have arrangements in place by which to conduct an objective review of the complaint. Normally this will involve a senior member such as one of the partner doctors or the registered manager, who has not been involved in handling of the complaint previously.
• This shall involve a review of all the documentation and may include interviews with relevant staff. The records made as part of this review should be complete and retained since these may be required in future.
• Provide a review of the investigation and the first response made .
• Offer a meeting with the complainant.
• Provide a full response on the outcome of the review within 20 working days or, where the investigation is still in progress, send a letter explaining the reason for the delay to the complainant, at a minimum, every 20 working days.
• The aim should be to complete the review in most cases within three months.
• If the complainant is still dissatisfied with the outcome and feel we have not met any of the Health and Social Care Act 2008 regulations, they can escalate their complaint to Independent External Adjudication.

Independent External Adjudication

• Complainants cannot access independent external arbitration until they have gone through the stages of internal complaint procedures;
• Complaints should be made in writing within 6 months of the final response to their complaint;
• For Mediwell’s Dental Section, the external complaint can be made through Dental Complaints Service :

           Post: DCS
           37 Wimpole Street London W1G 8DQ
           Tel: 020 8253 0800
           Email: info@dentalcomplaints.org.uk
           Website: https://dcs.gdc-uk.org

• For Mediwell’s Medical Section , the external complaint can be made through Centre for Effective Dispute Resolution:

           POST: CEDR
           100 St Paul’s Churchyard London, EC4M 8BU
           Tel: 0207 520 3800
           Email: applications@cedr.com
           Website : https://www.cedr.com/

If at any time during the complaint process the complainant or their representative or advocate decides they would like to withdraw the complaint this request can be made either verbally or in writing. The withdrawal of a complaint will be acknowledged in writing.

Safeguarding

Safeguarding is a key element of complaints management and review. It may be necessary to identify if any of the following elements are evident in the information/complaint:

• Safeguarding concerns to the person, to include their ability to manage with daily living
• Safeguarding concerns regarding the adequacy of care/support being provided to the person
• Safeguarding concerns regarding the behaviour of a professional to a patient or carer
• Safeguarding concern regarding the behaviour of the person/complainant to professional staff

All complaints staff must have at least Level 2 training in safeguarding to enable them to identify the key safeguarding concerns.

All complaints handlers will require a DBS check as part of their recruitment process.

Verbal Complaints

It is an important feature of the process that verbal complaints made to staff are dealt with and responded to by the person to whom the complaint is made.

The member of staff dealing with the complaint should respond appropriately by:

• Offering the complainant the opportunity to discuss his/her concerns in private.
• Listening carefully.
• Expressing regret that the complainant feels unhappy about the service.
• Thanking the complainant for bringing the matter to our attention.
• Resolving the issue on the spot wherever possible.
• Undertaking to investigate the complainant’s concerns and respond verbally within two working days.
• Making accurate notes if necessary.
• Seeking the help and support of the Practice Manager.
• Assuring them that the complainant is satisfied with the response to the complaint.

Confidentiality/storage of complaints records and information

If the complainant is not the patient, staff must make reasonable efforts to ensure that the complaint is made with the patient’s knowledge and consent.

All records relating to complaints will be stored in a specific file and held centrally, which will have the highest standard of confidentiality.

Recording

• All verbal complaints must be recorded electronically, (see Appendix B) outlining the Date & time of the complaint; Name of Complainant; Where the complaint took place; What the complaint was; Witnesses to the complaint and forwarded to the Practice Manager within one working day.
• The electronic complaint must be referred to the Complaints Manager for handling.
• Any unresolved complaint must be acknowledged by the Practice Manager within 3 working days of receipt.

Unreasonable Complaints

Where a complainant becomes aggressive or, despite effective complaint handling, unreasonable in their promotion of the complaint, some or all of the following formal provisions will apply and will be communicated to the patient:

• The complaint will be managed by one named individual at senior level who will be the only contact for the patient
• Contact will be limited to one method only (e.g. in writing)
• Place a time limit on each contact
• The number of contacts in a time period will be restricted
• A witness will be present for all contacts
• Repeated complaints about the same issue will be refused
• Only acknowledge correspondence regarding a closed matter, not respond to it
• Set behaviour standards
• Return irrelevant documentation
• Keep detailed records

Anonymous Complaints

Anonymous  complaints received online via the company website or social media etc will be investigated in the same way as named complaints. They will be logged and any corrective action necessary will be taken and recorded in the same way as named complaints. If appropriate, the response will be displayed in reply to the complaint that appeared on the Mediwell website, social media, etc.

Vexatious Complaints

Occasionally, Mediwell Clinic may receive complaints that are vexatious in that they cause considerable disruption to the work at Mediwell Clinic, disproportionate cost and time to handle, and impact the well-being of staff ( because of the way the complaint is made or because of its repetitive nature).

Mediwell Clinic will ensure that it meets the requirements of the Equality Act 2010 to make ‘reasonable adjustments’ for disabled customers. In some circumstances, customers may have a disability that makes it difficult for them to either express themselves or communicate clearly and/or appropriately. Where there is an indication that this may be the case, Mediwell Clinic will consider the needs and circumstances of the Patient or complainant in the first instance and use this information to inform any decisions that are made. Where appropriate Mediwell Clinic will consider complaints to be vexatious but would not label an individual complainant vexatious. Even if Mediwell Clinic decides that an individual’s complaint about the service is vexatious, that does not preclude that person from making a formal complaint. Mediwell Clinic would still consider any such complaints in line with the usual procedures.

To help decide whether a complaint is vexatious, Mediwell Clinic will consider the full history and context of interactions with the individual making the complaint and will look at both the nature of the complaint and the manner in which it is made. The particular issues that will inform a decision will include whether:

• The primary purpose and/or effect of the complaint is to disturb, disrupt and/or pressurize Mediwell Clinic, its staff, or an individual member of staff.
• The primary purpose and/or effect of the manner in which the complaint is made is to disturb, disrupt and/or pressurize Mediwell Clinic, its staff, or an individual member of staff.
• The complaint is otherwise clearly unreasonable.

If at any point in the handling of a complaint, a member of staff believes it meets the criteria to be deemed vexatious it must be referred to Nurten Cetin, with a summary of why it is thought to be vexatious. Nurten Cetin will consider the complaint, seek external advice if appropriate and will either declare the complaint as vexatious or not. Where a complaint is not deemed to be vexatious, it will be returned to the appropriate point in the complaints handling process.

If a complaint is deemed to be vexatious, Nurten Cetin will respond directly to the complainant explaining why it is thought to be so and explaining that the complaint will be closed with no further action. Nurten Cetin will also consider if the making of a vexatious complaint also requires the application of a restriction on communication following unreasonable behavior.

The decision to declare a complaint as vexatious will be recorded in the complaints register for future reference.

Any declaration that refers to the specific complaint being vexatious and any further complaints from the same individual will still be considered.

If any individual wishes to challenge a decision made in relation to this policy, and all the attempts to resolve the complaint locally have been unsuccessful, details of the independent complaints organization will be shared with the complainant.

The Complaints Register

This will contain all correspondence from each complaint received including the following:

• Details of the complaint including the subject matter, date of receipt, and method of receipt.
• Date and method of acknowledgment
• Notes from any meetings with the complainant wherever possible agreed with the complainant by countersignature.
• Details of any reason for delay where investigations took longer than any agreed response period and evidence of keeping the complainant informed of the delay.
• The date the response letter was sent to the complainant
• Dates when the complaint was discussed in Mediwell Clinic internal meetings.
• Changes of developments made in response to the complaint as a result of the complaints investigation, including how and when these are shared
• Learning from the complaint to improve the quality of care
• Dates of formal complaints reviews

Where complaints are raised by telephone, the log will include the date and time of the call and the content of the conversation.

Complaints to be shared for learning purposes will be anonymized by removing all identifiable Patient information or details and information pointing to the identity of the complainant.

A complaints register will also assist in the completion of the Annual Complaints Report.

Complaints Files and Records

A separate file will be kept for complaints records and letters. These must never appear in a Patient’s electronic or paper medical records or that of a complainant who is not the Patient who is a registered Patient of Mediwell Clinic.

Any complaint received by Mediwell Clinic via the formal complaints procedure will be kept on record for 10 years- the same length of time as for litigation cases.

Mediwell Clinic will comply with Data Protection legislation and UK General Data Protection Regulations in relation to complaint handling, recording, storing, and archiving.

II. Compliments, Suggestions, and Feedback

Mediwell Clinic will ensure services delivered are effective and responsive to the needs of Patients, carers, and other users by encouraging and welcoming feedback from Patients about the service and their experiences.

Mediwell Clinic will comply with the April 2015 contractual requirement for all General Practices in England to establish and maintain a Patient Participation Group (PPG) and make reasonable efforts to:

• Identify areas of good practice, strengths, and what Mediwell Clinic does well
• Identify areas of improvement, lessons learned, and any changes to be made as a result
• Demonstrate that Mediwell Clinic values Patients’ and others’ concerns and comments about the work of the Practice Team by making changes in response to feedback received

Mediwell Clinic will reflect on compliments, suggestions and other feedback received formally and informally depending on the content. A record of all compliments, suggestions and other feedback will be maintained, together with the register of complaints at Mediwell Clinic and will be reviewed on a regular basis at Practice meetings in addition to regular and annual complaints reviews.

Compliments, suggestions, and feedback received will be explored by the team at Mediwell Clinic, and a response provided to the individual as well as to the wider Patient and the stakeholder population (via the usual communication methods and channels at Mediwell clinic), in particular when changes have been made or developments are planned in response.

• Compliments

Receiving compliments via any Practice feedback or ad hoc voluntary method is an opportunity to celebrate and recognize success. Mediwell Clinic will ensure:

• All compliments are shared with members of the Practice Team formally or informally.
• Compliments will be anonymized, or permission sought from the Patient or representative before being published, put on display, or shared via Practice communication channels
• Number of compliments received are logged as with complaints and other feedback via the Practice register
• Verbal positive feedback from Patients and users will be recorded and shared. The Patient or representative can be asked if their compliments can be reproduced on a named basis with their consent, or anonymously.
• Compliments, together with complaints, suggestions and other feedback, will be taken as a standing agenda item at relevant Practice meetings.

• Suggestions and Feedback

Suggestions can be made verbally or in writing using all the feedback and communication channels at Mediwell Clinic (Patient Participation Group or other engagement groups direct to Mediwell Clinic). These are usually made by Patients or users seeking to improve Mediwell Clinic, meet needs or respond to changes and trends.

Suggestions are not complaints. However, they will be recorded, reviewed and actioned to prevent any risk of a future complaint in relation to the suggestion made. Suggestions will be managed in the same way as other feedback and informal complaints and included in reports in meetings together with other feedback.

III. Audit and Evaluation

Mediwell Clinic will record, monitor, review and analyse all complaints and other feedback received about the service as part of the Practice continuous improvement cycle to identify and inform performance, effectiveness, quality, safety and trends. Mediwell Clinic will investigate or explore what has been received and act on the findings that emerge.

Mediwell Clinic will:

• Share themes and trends with the Practice Team and as appropriate in the interests of the development and dissemination of best practices.
• Review complaints, compliments, and other feedback received, together with the outputs and outcomes from the management process, as a standing agenda item at Practice meetings.
• Ensure that staff members are trained to deal with complaints, compliments, suggestions, and feedback and understand the complaints procedure so that they can advise complainants with accuracy