PRINCIPLES: The following principles underpin the feedback management system and will be reflected in feedback management procedures at all levels:

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1 Approved by: of Directors Effective Date: May 7, 2013 No. B-22 Issued by: Administration Review Date: May 7, 2013 Department(s) All Version: 2 Archived: Y POLICY: The of Directors recognizes that patient feedback, both positive and negative, is essential to ensure the provision of quality health care services that meet patient and community needs. This policy affirms and supports the right of patients to provide feedback and to have complaints heard and acted upon. Lennox and Addington County General Hospital demonstrates integrity and accountability to the Community by having an ethical, comprehensive and patient friendly feedback management system. The implementation of the feedback management system strives for patient satisfaction in the way their feedback is handled, and provides reliable and accurate information, which is used to improve quality and safety in health care. (See the Feedback Management Model page 8 of this document) PRINCIPLES: The following principles underpin the feedback management system and will be reflected in feedback management procedures at all levels: 1. Organizational Improvement - Using information from feedback enhances organizational performance. Service improvement results from both handling feedback at the individual level and from collation and analysis of aggregated data. 2. Commitment - Adequate resources are allocated to ensure effective and efficient management of feedback. 3. Patient Rights and Responsibilities - Patients have the right to provide feedback about the provision of a health service before, during or after the provision of the service, in whichever method of communication they prefer. Patients have a responsibility to: - Provide factual and full information in a timely manner; - Work collaboratively with staff to resolve issues; - Not knowingly make frivolous or vexatious complaints. 4. Transparency The feedback management process is open, clear and plainly evident to patients and staff. This openness demonstrates accountability to the Community. Hospital Policies and Procedures Page 1 of 8

2 PRINCIPLES (CONT D.): 5. Fairness The feedback management process is unbiased, objective and impartial to all parties. All feedback is treated as legitimate and is properly assessed. Procedural fairness and natural justice are key elements throughout the feedback management process. 6. Privacy and Confidentiality The privacy of all complainants and any staff member named in a complaint is respected with information disclosed on a need to know basis. No reference to the lodging of a complaint will be made in a patient s health care record. 7. Timeliness - Patient feedback is acknowledged and managed efficiently without unnecessary delays. 8. Assistance Patients are given assistance to provide feedback wherever necessary and are supported throughout the feedback management process. Assistance is also available to staff who are subject of a complaint or are involved in the assessment/investigation of a complaint. TYPES OF FEEDBACK: Patients may offer compliments through satisfaction surveys, letters, in person, by phone and through the Hospital website. Such feedback will be shared and the staff acknowledged for their contribution to a quality patient experience. Patients may offer suggestions that are intended to provide information on how to change or improve care. Staff are requested to document and forward suggestions to the unit supervisor for consideration within the quality management system. An inquiry is a question or request for clarification of information pertaining to hospital services which cannot be provided at the point of service. A complaint is an expression of dissatisfaction with some aspect of care/services when an expectation is not or cannot be met by the provider at the point of service. A complaint can be made verbally (in person or by telephone) or in writing (survey response, through the Hospital website, mail, or fax). A complaint may be made by or on behalf of a patient or group of patients by an individual or an organization. SCOPE AND APPLICATION: The policy applies to all Hospital employees (permanent, temporary and casual) and all individuals acting as a Hospital agent (including Medical Staff, visiting health professionals, students, contractors, consultants, and volunteers). RESPONSIBILITY: Handling feedback is the responsibility of everyone in the organization. Specific accountabilities are identified in Table 1. Hospital Policies and Procedures Page 2 of 8

3 SERIOUSNESS CATEGORIES FOR COMPLAINTS: All complaints are categorized in a manner that reflects the seriousness of the complaint. The seriousness categories are applied to the risk management framework within the Hospital and used in data analysis to facilitate learning. 1. Minor No or minimal impact on the provision of care/organization. May be resolved at the point of service but requires review for sustained quality improvement. 2. Moderate Impact does not have a long lasting effect on the provision of care/organization. Issue requires investigation and follow up. Immediate supervisor must be notified. 3. Major Serious issues, which may result in long lasting damage to person/organization. Claims or legal review may be pending. Issue requires comprehensive investigation. Immediate supervisor must be notified as soon as possible. Supervisor notifies Chief Executive Officer or delegate of the incident and reviews actions undertaken. PRIVACY AND COMPLAINTS: The Hospital Privacy Officer will be contacted when a complaint is received regarding an alleged breach of privacy. It is the responsibility of the Privacy Officer to report to the Privacy Commission. When accepting a complaint from a party other than the patient, in relation to the treatment of a patient, the hospital will confirm that the patient or the substitute decision-maker (SDM) is aware and supports the investigation. For release of any health information in relation to the patient and their treatment, the hospital will require consent of the patient. (For example, the daughter of an elderly patient complains her mother was spoken to rudely by a staff member. The investigator would be required to inform the daughter that we would need to discuss the complaint with her mother. Depending on the capabilities of the patient, the SDM may need to be contacted and the issues discussed with that person if it is not the daughter.) Complaints may be received with a request that the complainant s identity not be revealed. These requests may be due to fear that complaining will have negative repercussions on current or future communication or treatment. Although information received in strict confidence may limit the extent of the investigation, the matter is investigated as thoroughly as possible and information is used for organizational improvement wherever possible. DOCUMENTATION: Patient feedback will be documented as part of the feedback management process. Refer to Feedback Management Form at the end of this document. All investigators will document their findings and submit their written report to the Director of Quality. Recommendations and follow up by review committees or administration will be documented. Hospital Policies and Procedures Page 3 of 8

4 PERFORMANCE STANDARDS: 1. All complaints will be acknowledged within 3 business days of receipt (verbally or in writing). 2. At least 80% of complaints will be investigated and resolved within 28 calendar days. 3. Complainants are advised of the progress of the complaint every 28 days until resolved. 4. Every complaint, the related investigation and follow up are documented. 5. Complaints are logged in a registry that allows analysis for the identification of patterns and trends. 6. Aggregated feedback information will be reported monthly to the Quality Committee of the of Directors including: the number of complaints, issues, seriousness categories and actions implemented. Table 1 Responsibility: Position Responsibilities and Specific Accountabilities All Staff All staff are required to: Be aware of and comply with the principles and directives contained in this policy. Assist patients and/or visitors to provide feedback to the organization in a spirit of helpful co-operation. Investigators Address and resolve issues within your scope upon receipt. Document patient or visitor feedback as required on the Service Feedback Form and submit to your immediate supervisor. Are assigned by the Director of Quality to undertake detailed inquiry of matters arising from complaints. Therefore they are responsible for: Investigating complaints objectively, fairly, confidentially and in a timely manner. Establishing the facts associated with a complaint. Compiling a report on the investigation findings including relevant documentation. Forwarding reports to the Director of Quality in a timely manner. Ensuring the principles of natural justice and procedural fairness are upheld throughout the investigative process. Hospital Policies and Procedures Page 4 of 8

5 Directors/Managers/ Supervisors ( persons with line responsibility includes Charge Nurse in the off hours ) Executive Assistant These positions are responsible for : - Acknowledging staff when compliments are received Ensuring all staff are aware of and comply with the policy. Ensuring minor complaints are adequately assessed, reviewed and acted upon in a fair and timely manner. Assist and support staff to resolve minor complaints at point of service. Reviewing information obtained from complaints, identifying areas for improvement, risk and making recommendations regarding possible changes to be implemented. Ensuring that consumer and employee rights are upheld throughout the complaint management process. Dealing with complaints referred in areas of responsibility through discussion and negotiation with the complainant and relevant staff where possible. Ensuring all complaint information is referred to the Director of Quality when resolution of minor complaints is achieved. Ensuring complaints of moderate or major categories and the supporting documentation is submitted to the Director of Quality in a timely manner. Notifying the Director of Quality if they have a conflict of interest with the complaint or consider their impartiality or ability to work with the complainant may be questioned. Implementing any service level changes that arise from consumer feedback. Completing all necessary documentation. Informing staff for educational purposes of complaint outcomes. This position is responsible for: Maintaining a register of complaints with numeric identification. Maintaining the complaint files and archiving for access. Drafting letters of acknowledgement as requested. Tracking response dates. Typing response letters for approval prior to posting. Populating the quality improvement report for analysis. Distributing analytical reports. Hospital Policies and Procedures Page 5 of 8

6 Director of Quality Service Teams/ Committees Chief Executive Officer This position is responsible for: Acknowledge the receipt of complaints. Co-ordinating internal investigations of all complaints and assigning responsibility to conduct investigations. Ensuring that information obtained from complaints is considered as part of the quality improvement and risk management processes. Assisting in the timely management and resolution of complaints. Reviewing outcomes and identifying any aspects of the complaint that may be unresolved. Where directed refer complaints externally for review. Assisting in the identification of cases for referral to claims management or legal consultation. All Management Committees or teams are responsible for: Regularly reviewing consumer feedback relevant to their area of responsibility. Reviewing organizational performance against the performance standards. Recommending and instigating organizational improvement where appropriate. This position is responsible for: The leadership of all areas of responsibility in a manner consistent with the Hospital mission and values. The overall implementation of the Feedback Management System ensuring the principles are upheld, that line management accountability for reporting and investigation of complaints occurs and that adequate resources are identified and provided. Maintaining a Hospital wide register that includes required information. Ensuring that performance standards are met. Ensuring that all complaints of the major seriousness category are assessed for claims management and legal consultation. Ensuring that all complaints requiring external reporting are acted upon in a timely manner (mandatory reporting to Regulated Colleges, Privacy Commission). Ensuring appointed investigators are appropriately resourced and skilled. Ensuring the Director of Quality is appropriately resourced and skilled. Ensuring that the of Directors receive matters arising from consumer complaints and are informed of corrective and preventative actions taken. Hospital Policies and Procedures Page 6 of 8

7 of Directors Ultimately, the of Directors is accountable for the operation of the Hospital, which includes the establishment and maintenance of suitable processes for the management of consumer feedback, including the management of consumer complaints. Hospital Policies and Procedures Page 7 of 8

8 Feedback Management Model Feedback management is the responsibility of everyone in the organization. The management of feedback is represented in the model below. 1 Tier 1- Frontline Feedback Management Staff have clear delegation to answer inquiries and resolve minor complaints at first point of service wherever possible Staff document feedback Staff refer moderate, major and unresolved minor complaints, inquiries or suggestions to their supervisor Organizational Improvement Implementation of Recommendations and Staff feedback Tier 2 Internal Review Supervisors or appointed investigators undertake in-depth and /or root cause analysis of complaint matters Director of Quality reviews complaints and ensures comprehensive assessment or investigation of moderate and major complaints is completed and aggregate data is analysed Director of Quality refers relevant matters to the CEO Patient/ Visitor Satisfaction Tier 3 External Review Complaints are referred externally for review or investigation as required ( Regulated Colleges for Health Professionals, Privacy Commission) Complainants informed of alternative avenues for resolution if complaint is not resolved to their satisfaction. 1 Adopted from the NSW Ombudsman (2000), Effective Complaint Handling System 1/7/07 Hospital Policies and Procedures Page 8 of 8

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