Policy for the Management of Concerns and Complaints

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1 Policy for the Management of Concerns and Complaints Ratification process Lead Author Developed by: Approved by: Patient Experience Manager, C&P CCG Patient Experience Manager, C&P CCG Patient Safety & Quality (PSQ) Committee Ratified on and by: February 2015 Patient Safety and Quality Committee Version No. 2 Latest Revision date January 2015 Next review date January 2018 Policy for the Management of Concerns & Complaints (Dec 2014) Page 1 of 23

2 Document Control Panel Development and Consultation: Dissemination Implementation Training Audit Review Equality and Diversity Director of Nursing, Quality & Patient Experience Director of Corporate Affairs CCG Secretary Designate Director of OD and HR Director(s) of Communications and Engagement Patient Experience Lead Patient Experience Manager Patient Safety & Quality Committee Equality & Diversity Systems Advisor Dissemination will be through CCG Staff Briefings and accessed through the CCG intranet web site Director of Nursing, Quality and Experience Through team briefs, workshops 12 months from the date of implementation Patient Experience Lead / Manager Patient Safety & Quality Committee Cambridgeshire and Peterborough CCG works within the Equality Delivery System Framework. This policy has therefore been impact assessed against our four goals:- Goal 1 Better health outcomes for all Goal 2 Improved patient access and experience Goal 3 Empowered, engaged and well-supported staff Goal 4 Inclusive leadership at all levels Revisions Version 2 Amended to reflect as a new organisation from 1 April Review and update in line with changes to NHS structure Amended to reflect changes in the management of NHS complaints and concerns following changes to NHS structure Policy for the Management of Concerns & Complaints (Dec 2014) Page 2 of 23

3 Definitions used in this procedure A Complaint Issues/concerns Joint complaint PALS Chief Clinical Officer Director of Nursing Quality and Experience Service Director / Lead Patient Experience Manager The Parliamentary & Health Service Ombudsman (PHSO) A written or oral expression of dissatisfaction with the service provided or the circumstances associated with its provision which requires a formal investigation and response. A written or oral expression of dissatisfaction with the service provided (or not provided) or the circumstances associated with its provision, but which can be resolved by the end of the day after which the complaint was made, without the need for formal investigation and formal correspondence. A complaint which involves more than one NHS body or an NHS body and another external organisation. Patient Advice and Liaison Service (PALS) provides advice and liaison to patients who have queries/concerns about the NHS. The Chief Clinical Officer (CCO) is the Accountable Officer for NHS Cambridgeshire and Peterborough CCG. As such, the CCO is responsible for ensuring that the CCG achieves its Statutory Responsibilities as set out in the Health and Social Care Act The person identified in the CCG responsible for overseeing the complaints procedure The person identified in the CCG responsible for handling and investigating an individual complaint. Person responsible for the day to day operational management of concerns and complaints Referral body for complainants when a complaint cannot be resolved at local level. Policy for the Management of Concerns & Complaints (Dec 2014) Page 3 of 23

4 Useful addresses: Name Address Purpose Director of Nursing Quality and Patient Experience Patient Experience Team NHS England POhWER ICAS Healthwatch England The Parliamentary & Health Service Ombudsman (PHSO) Lockton House Clarendon Road Cambridge CB2 8FH Patient Experience Manager NHS Cambridgeshire & Peterborough CCG Lockton House, Clarendon Road Cambridge CB2 8FH Telephone: Free phone: PO Box Redditch B97 9PT Tel: PO Box Birmingham B6 9BL Cambridge branch: 6 Oak Drive, Huntingdon, PE29 7HN Tel: Peterborough branch: Peterborough CAB, St Marks Street, Peterborough, PE1 2TU Millbank Tower Millbank London SW1P 4QP Tel: Fax: Responsible for overseeing the complaints procedure within the CCG Provides advice and support in relation to NHS services Responsible for the day to day administration of this procedure Responsible for the management of complaints arising from primary care, military, offender health and specialised services Provides advocacy support to people who wish to make a complaint against the NHS. Independent consumer champion for health and social care in England. Ensures that voices of patients and service users reach the ears of the decision makers Investigate complaints by individuals who have been treated unfairly or have received poor service from the NHS in England. Policy for the Management of Concerns & Complaints (Dec 2014) Page 4 of 23

5 CONTENTS Chapter Title Page No 1. Summary 6 2. Introduction 6 3. Aim 7 4. Legislative Context 7 5. Scope 8 6. Mission Vision & Values 9 7. Accountability and Responsibility 9 8. Intended Users Definition of a Complaint Equality Impact Statement Patient Experience Team Complaints Procedure Time Limit for Making Complaints Persons who can raise complaints Vexatious and Persistent Complainants Complaints not handled by the CCG Mediation NHS England Parliamentary & Health Service Ombudsman (PHSO) Lessons learned Working in Partnership Accessibility Monitoring and Performance Management of the policy 20 Appendices A: Procedure for Handling Persistent and Vexatious Complainants 21 B: Flowchart - Procedure for the Management of Concerns and Complaints 23 Policy for the Management of Concerns & Complaints (Dec 2014) Page 5 of 23

6 Cambridgeshire & Peterborough Clinical Commissioning Group Policy & Procedure for the Management of Concerns and Complaints 1. Summary This policy outlines the process by which complaints and concerns are handled by Cambridgeshire & Peterborough Clinical Commissioning Group ( the CCG ). The primary function of this policy is to ensure that procedures are in place to address concerns and to ensure that information, findings and recommendations are implemented to improve quality standards. This policy outlines the process by which complaints and concerns will be handled when raised by or on behalf of the patient/service user. The primary function of this policy is to ensure that procedures are in place to address the concerns and complaints raised with or about the CCG. This will include providing: An explanation An apology (where appropriate) Assurance that the matter has been looked into; and Action has been taken to prevent the same thing from happening again The secondary function is to ensure that information, findings and recommendations are provided to the relevant directorate or department to help assist quality standards. This policy will also outline the procedure to be followed when dealing with: Complaints about services not commissioned by the CCG Complaints relating to any action or decision taken by the CCG, including those relating to the commissioning of health service for the local population and provision of community services Complaints relating to other NHS trusts or local authority services Complaints relating to services purchased from the independent sector and Complaints relating to more than one organisation. 2. Introduction Cambridgeshire and Peterborough CCG (the CCG) recognises that comments, concerns and complaints are a valuable source of information from service users about the quality of the services it commissions. It is essential that all complaints and suggestions are received positively, investigated thoroughly and promptly and responded to in an open and empathic manner, with action taken, where appropriate, to prevent a recurrence of the circumstances leading to the complaint. The CCG welcomes complaints as a valuable means of receiving feedback on the services its commissions for the people of Cambridgeshire and Peterborough and also on the way the CCG goes about its business. The CCG aims to use information gathered from complaints as a means of improving its services. The CCG will seek to identify learning points that can Policy for the Management of Concerns & Complaints (Dec 2014) Page 6 of 23

7 be translated into positive action and, where necessary, provide redress to set right any injustice which may have occurred. Patients and service users are encouraged to express complaints, concerns and views, both positive and negative, about the treatment and services they receive, in the knowledge that: they will be taken seriously they will receive an efficient response by a member of staff with the appropriate knowledge to respond appropriate action will be taken there will be no adverse effects on the care that they or their family members receive; and lessons will be learnt and disseminated accordingly to the CCG Quality and Performance teams to ensure that learning from complaints is monitored via Contract monitoring and Clinical Quality Review (CQR) meetings. 3. Aim The aim of this policy is to set out the CCG s approach to receiving, handling and responding to complaints made under the provisions of the Local Authority Social Services and National Health Service Complaints (England) Regulations 2009 (SI 20009/309) 1. The management of complaints and concerns is provided by the CCG s Patient Experience Team. The aim of this policy is to ensure that the complainant is at the centre of the process and the CCG strives to provide the complainant with a high quality service that will respond openly to the issues and concerns that have been raised. The CCG recognises that in some instances it may not be possible to provide satisfaction to a complainant and, where this is the case, the CCG will work closely and co-operatively with the Parliamentary & Health Service Ombudsman (PHSO) on any case the Ombudsman chooses to investigate. 4. Legislative Context (a) The Local Authority Social Services and National Health Service Complaints (England) Regulations 2009 ensure that the CCG, as a commissioner of health services, manages complaints in accordance with the NHS Complaints Procedure 2009: (b) The NHS Constitution explains your rights as a patient or service user when it comes to making a complaint 13/the-nhs-constitution-for-england-2013.pdf and states that patients/service users have the right to: have their complaint acknowledged and properly investigated, discuss the manner in which the complaint is to be handled and know the period in which the complaint response will be sent 1 Policy for the Management of Concerns & Complaints (Dec 2014) Page 7 of 23

8 to be kept informed of the progress and to know the outcome including an explanation of the conclusions and confirmation that any necessary action has been taken take their complaint to the independent Parliamentary and Health Service Ombudsman (PHSO) if they are not satisfied with the way the NHS has dealt with the complaint, make a claim for judicial review if they think they have been directly affected by an unlawful act or decision of an NHS body, and receive compensation if harmed by negligent treatment This policy does not duplicate issues which are clearly set out in legislation, but adapts and supplements these to meet local needs and recent developments in the NHS. It also aims to meet the principles of good complaints handling laid down by the PHSO by: Getting it right Being customer focused Being open and accountable Acting fairly and proportionately Putting things right Seeking continuous improvement 5. Scope This policy applies to the commissioning role of the CCG. This policy also covers those complaints where the CCG agrees with another organisation to take the lead. This policy and its procedures apply to both clinical and non-clinical complaints and relates to: complaints about services commissioned and managed by CCG; complaints regarding actions, behaviours or attitude of any person employed by the CCG; health related complaints that include elements relating to the Local Authority; complaints regarding access to or review of funded care; complaints regarding Commissioning decisions; and complaints regarding an NHS body or independent provider. and should be read in conjunction with other associated CCG policies, Incident and Near Miss Serious Incident Reporting Policy and Procedure, Risk Management Strategy. The policy does not cover concerns or complaints raised by CCG staff in relation to employment matters which are handled separately through line management arrangements and Human Resource policies e.g. Grievance Procedure and Disciplinary procedures. Policy for the Management of Concerns & Complaints (Dec 2014) Page 8 of 23

9 6. Mission Vision & Values Our Vision Cambridgeshire & Peterborough Clinical Commissioning Group is led locally by clinicians in partnership with their communities, commissioning quality services that ensure value for money and the best possible outcomes for those that use them. Our Mission: Our mission is to empower our communities to keep healthy and to commission good quality healthcare for all those who need it. Our Values: Patient focused: Our population, patients and their families are at the centre of our thoughts and actions, we will commission care tailored to their needs. Quality driven: We will constantly strive to be the best we can be as individuals and as an organisation and we will ensure that this is reflected in our commissioning decisions. Work locally: Through our Local Commissioning Groups (LCGs) working within their communities. Excellent: Our aim is to be an excellent organisation for our communities, clinicians and our staff. The CCG will work with its commissioned service providers to ensure that a similar customer focussed approach is taken to complaint handling. 7. Accountability and Responsibility The CCG s Governing Body will oversee the complaints management process to satisfy itself that the required quality of service by all providers and of commissioning activity and decisions are achieved and maintained. This includes the responsibility for approving the CCG policy and procedures for the management of complaints and concerns. The Chief Clinical Officer is ultimately responsible for all complaints received by the CCG. However, this responsibility is delegated to the Director of Quality Safety & Patient Experience as the Director with corporate responsibility for ensuring the CCG has arrangements in place that comply with the regulations, and that appropriate action is taken arising from complaints. The person responsible for managing the CCGs complaints procedures in accordance with the arrangements made under the Regulations is the Director of Nursing and Quality. The Patient Safety and Quality Committee ( PSQ ) is accountable to the Governing Body for assurance on complaints management and ensures appropriate learning is identified and shared. The PSQ Committee will monitor the implementation of the policy and procedure, receive and review quarterly complaints reports including details on trends and themes, review issues and ensure that appropriate actions are taken, lessons are learned and making recommendations to the Governing Body as necessary. The Patient Experience Manager is the person responsible for day to day management of complaints and takes responsibility for: Ensuring effective implementation of this policy Policy for the Management of Concerns & Complaints (Dec 2014) Page 9 of 23

10 The satisfactory management of complaints handling and coordinating the complaints process; Review all complaints received and preparing reports for the PSQ Committee,, Information Commissioners and the PHSO as appropriate; Assess the severity of the complaint, whether escalation is required and/or the need to contact other agencies; Provision of advice/support to CCG staff dealing with complaints; Providing information to complainants regarding sources of support such as ICAS/Pohwer and other advocacy services; Ensure publicity, explaining how to raise concerns/complaints, is accessible to the public and complainant; Summarise complaints information and conclusions to inform commissioning quality monitoring and reporting across providers; Develop and maintaining a database to categorise and record all complaints received; The preparation of acknowledgement and response letters within the required timescale. All members of staff are responsible for acquainting themselves with the complaints policy and the complaints procedures relevant to their area of work. Members of staff will be expected to assist as required in any complaint investigation, e.g. Local Chief Officers (LCOs), Service Leads and Senior Commissioning staff. Members of staff with specific duties under the complaints procedure should ensure that a suitable colleague is nominated to deputise on her or his behalf in her or his absence. All Providers are required to have their own arrangements for complaints handling in accordance with the Local Authority Social Services and National Health Service Complaints (England) Regulations The CCG s Standard Contracts for Commissioned Services requires each provider to: operate and publicise a complaints procedure that complies with the law; provide such details of its complaints procedure as may be required; shall implement lessons learned from complaints; demonstrate at CQRs the extent to which service improvements have been made as a result. Providers are required to provide the CCG with monthly, quarterly and/or annual reports giving the numbers of complaints received, of those the number of justified complaints, the subject matter of the complaints and actions taken to improve services as a result of the consequences of the complaint. 8. Intended Users This policy is intended for use by the CCG s members and staff, persons wishing to make a complaint under the Regulations, parliamentary and other representatives who provide support to persons wishing to make a complaint. This policy is also available for scrutiny by external agencies with an audit and inspection role regarding the CCG s complaints function. Because of the diverse audience for which this policy is intended, it is written in such a way as to make it a practical guide to using the CCG s complaints handling service and the types of complaints the CCG covers. 9. Definition of a Complaint For the purposes of this policy a complaint is defined as an expression of dissatisfaction received from a patient, carer, service user or third party representative about any aspect of the local health services which requires a response. Policy for the Management of Concerns & Complaints (Dec 2014) Page 10 of 23

11 Such expressions of dissatisfaction may be made in a variety of ways; verbally, in person, by telephone, in writing, including electronically by or fax. This wide definition empowers staff to resolve minor comments, grumbles and problems immediately and informally. The decision as to whether a matter is dealt with informally as a concern or as a formal complaint will depend on whether an immediate response can be given or whether further investigation is required. 10. Equality Impact Statement The CCG welcomes feedback on this policy and the way it operates. We are interested to know of any possible or actual adverse impact that this policy may have on any groups in respect of gender or marital status, race, disability, sexual orientation, religion or belief, age, deprivation or other characteristics. The person responsible for the equality impact assessment for this policy is the Director of Nursing and Quality. This policy has been screened to determine equality relevance. The policy is considered to be high in equality relevance particularly in relation to: age, disability, race, gender, religion/belief, sexual orientation, transgender and deprivation. It is important for staff to remember that complainants may not be able to read or write, may not have English as their first language or may have disabilities which make it difficult for them to express their complaint. There are many groups in our communities that find it hard to access the services that they need. Therefore, it is important that the CCG has arrangements in place to ensure that all groups are given the opportunity to access proper health care services. This policy embraces diversity, dignity and inclusion in line with statutory requirements and human rights guidance. The CCG recognises, acknowledges and values differences across all people. Every person will be treated with respect, courtesy and with consideration for their individual backgrounds. The CCG will ensure that everyone is treated fairly and conveys equality of opportunity in service delivery and employment practice. Practically, this means that the CCGs will anticipate and take steps to meet individual needs. This will include making reasonable adjustments to processes and communications to help ensure their accessibility to all. 11. Patient Experience Team The CCG s Patient Experience Team (PET) will provide all necessary activities to enable the CCG to meet its statutory duties and obligations as set out in the 2009 Complaints Regulations. The key elements are: A central access point (Mon to Fri 9am to 4.30 pm) exc. bank holidays; A dedicated telephone number and address; Provide details of the CCG s procedure and related NHS procedures to customers and complainants Policy for the Management of Concerns & Complaints (Dec 2014) Page 11 of 23

12 Acknowledgement of concerns or complaints: Record all contact details and maintenance of internal database, together with the outcomes on a complaints database; Identification of the main issues and the outcomes required to resolve the case for the complainant or customer Analysis of data and production of quarterly and annual reports Point of contact and liaison with the PHSO office; Facilitate and support face to face meetings between customer and complainant Signpost patients to appropriate agencies and support groups outside of the NHS Identify the appropriate Service Lead to secure the information and facts which enable a full response to be made; Co-ordination of and support to the investigation including obtaining consent where appropriate, chase progress on the complaint investigation, send reminders of response deadlines and negotiate extensions with complainant when more time is required; Preparation of CCG response letters following clarification and investigation ensuring that all issues identified in the complaint have been addressed; where findings do not fully address all of the issues raised, identify the issue, feedback to the Service Lead or Local Chief Officer (LCO) for further information and negotiate revised timescales for a response. Provide Service Lead/manager/LCO with details of the case and timescales for completion. Ensure that the CCG lead receives updates as agreed throughout the process and quality check draft response letters; Arrange for signature of response letter and sending to complainant. 12. Complaints Procedure The CCG s Complaints Procedure aims to meet the following criteria: Be well publicised and easy to access. Simple to understand and use. Fair and impartial. Complaints dealt with within a pre-advised timescale of between days which is dependent on the issues and nature of the complaint raised Provides a thorough mechanism for resolving complaints and investigating matters of concern. Be regularly reviewed and amended if necessary. Be consistent with National Guidance The CCG s Complaints Procedure consists of two elements: Local Resolution Local Resolution aims to provide the fullest possible opportunity for the investigation and resolution of the complaint and will be tailored to meet the needs of the complainant. The Parliamentary and Health Service Ombudsman (PHSO) If a complainant is dissatisfied with Local Resolution they have a right to refer their outstanding concerns to the PHSO. Local Resolution Procedures Policy for the Management of Concerns & Complaints (Dec 2014) Page 12 of 23

13 Complaints about the CCG and its staff CCG staff are encouraged, in conjunction with their line manager, to deal with concerns and requests for information to which they can provide an immediate response. If a matter remains unresolved the complainant should be informed about the formal complaints procedure and provided with the relevant information. Details of any formal complaints should be passed promptly to the Patient Experience Team, to be acknowledged within three working days of receipt, and forwarded to the appropriate manager for investigation. If the complainant is not the patient, appropriate consent will be sought. Although there is no statutory deadline for providing a response, the CCG aims to provide a response within 30 working days. If the complaint is complex and it is felt that the investigation will require more time, the complainant will be advised as to the extra time required in order to carry out an investigation and provide a substantive response Complaints Regarding Commissioning Decisions Complaints to the CCG about commissioning decisions should be directed to the Patient Experience Team. All necessary investigations will be addressed by the relevant director and/or service lead and a response provided for signature by the Chief Clinical Officer or Chief Operating Officer Complaints about any services commissioned by the CCG The complainant has the option to complain directly to an NHS body, or NHS independent provider or to ask the CCG to handle their complaint and obtain a response on their behalf. In cases where a complainant chooses the CCG to handle the complaint, the Patient Experience Team will seek the complainant s consent to refer the matter to and obtain a response from the relevant provider. Complainants will be encouraged to put their concerns in writing so that an accurate interpretation of events can be forwarded on for a response. The Patient Experience Team will provide support to Independent Providers to ensure that they comply with the NHS Complaints procedure. Where appropriate, PET will arrange conciliation for the parties involved. In some cases, it may be appropriate for the Patient Experience Manager to act as an intermediary between the organisation and the complainant. The Patient Experience Manager will remain impartial during this process and only advise parties of the complaints process and options available to them i.e. conciliation if appropriate. Independent Providers are expected to have local complaints procedures which are comparable to those operated in the NHS. Complaints directed to the CCG which relate to care commissioned by the CCG will be forwarded to the relevant provider for investigation if the complainant wishes this to happen. Progress and resolution of the complaint will be monitored by PET. Policy for the Management of Concerns & Complaints (Dec 2014) Page 13 of 23

14 Independent Providers will be encouraged to co-operate in the investigation of any multi-sector complaints in which they are involved. Independent Providers must comply with any requests for information from the CCG in relation to the number of complaints received, of those the number of justified complaints, the subject matter of the complaints and actions taken to improve services as a result of the consequences of the complaint Complaints About or Involving Another Sector of the NHS and/or the Local Authority/Inter Agency and Multi Agency Complaints Complaints may sometimes need to be redirected to another agency within the NHS or to the Local Authority. This will be done promptly by PET in consultation and with the consent of the complainant, and details of the forwarding process should be recorded. Sometimes complaints will require multi-agency investigation. Local protocols are in operation and in such cases discussions will take place between the relevant complaints managers of the organisations involved as to who will coordinate and lead the response. When an approach is agreed the complainant should be provided with details of how the investigation will take place, and the appropriate NHS timescales should apply. The time limit for responding to a complex complaint will be agreed with the complainant, and any delay will be put in writing with an explanation for the delay and a new response date given. A local protocol has been agreed for handling these complaints Complaints received from a Member of Parliament (MP) Complaints received through Members of Parliament will invariably be addressed to the Chief Officer. As in all other complaints the Chief Officer will sign the reply. However, in some cases, the complaint will be handled directly by the Patient Experience Manager with the complainant and in such cases a letter stating that this is happening may be an appropriate reply to the MP Complaints already addressed by Provider organisations The 2009 NHS Complaints Regulations provide for a two-stage complaints process: Stage 1 being local resolution by the provider concerned, Stage 2 being a review by the Health Service Commissioner (Ombudsman) There is no provision in law for the CCG to be an intermediary between stages 1 and 2 where the complaint has already been made to and responded by the provider that is the subject of the complaint. At the end of Stage 1, local resolution, the response to the complainant should include details of how to raise the matter with the Ombudsman if the complainant is not satisfied with the final response. The CCG is aware that sometimes this does not happen, and in some instances complainants are misinformed that the CCG is the next stage in the complaints process. In these circumstances the Policy for the Management of Concerns & Complaints (Dec 2014) Page 14 of 23

15 CCG will inform the complainant of the correct procedure to follow and will not conduct a review of the complaint. 13. Time Limit for Making Complaints The statutory time limit for making a complaint is 12 months from the date on which the matter being complained about occurred, or 12 months from the date on which the complainant became aware that they have grounds for complaint, whichever is the later. A complaint made outside of the time limit can be considered if the CCG decides there are good reasons for the complaint not being made within the time-limit and the case can still be properly investigated. 14. Persons who can raise complaints Generally it will be the person who has received the service that makes the complaint. However, the CCG appreciates that there are circumstances in which another person can make a complaint on behalf of the patient, which are: If the patient is a child who is not able to make the complaint on their own behalf; or Is a person who has been assessed under the provisions of the Mental Capacity Act 2005 as not having capacity in this matter; Where the patient with capacity has given consent for another person to act on their behalf; Where a person is deceased (the CCG will seek consent from the next of kin or power of attorney to progress the complaint). With regards to children and people without capacity, the Regulations permit the responsible body for the complaint to take a view on whether the person is acting in the patient s best interests and, if it is felt that this is not the case, then the responsible body can refuse to handle the complaint person. This means that the CCG will not assume that a parent or guardian can make a complaint on behalf of a child if it is felt that the child has sufficient maturity and capacity to make, or withhold, consent. The CCG will only exercise this power after full and proper consultation with relevant other parties. If an adult with capacity consents to a third person acting on their behalf, and the appointed person can provide a valid and acceptable form of consent, the CCG will regard the appointed person as a proxy for the patient in the complaint process. However, where a third person claims to be making a complaint on behalf of someone with capacity and does not have that person s valid consent in place, the CCG will contact the patient and request their consent for the complaint to proceed. This will assure the CCG that the patient provides consent to the complaint being made. Where this consent is not provided the CCG will not act. The CCG will also seek written consent for complaints submitted by representatives or other third parties on behalf of an individual or family member in order to demonstrate that the representative is acting in accordance with the individual instructions. 15. Vexatious and Persistent Complainants The CCG is committed to treating all complaints equitably and recognises that it is the right of every individual to pursue a complaint. The CCG therefore endeavours to resolve all complaints to the complainant s satisfaction. However, on occasions, the CCG may consider that a complainant who persists in making complaints raising the same or similar issues Policy for the Management of Concerns & Complaints (Dec 2014) Page 15 of 23

16 repeatedly, despite having received full responses to all the issues they have raised may be identified as a persistent complainant. Where a complainant is considered persistent in nature, the Patient Experience Manager will, in agreement with the CCG s senior officers, follow the CCG s Procedure for Handling Persistent Complainants (Appendix A). Zero tolerance The CCG operates a zero tolerance policy for complainants who chose to be rude or abusive in the manner by which they communicate their complaint. This is in accordance with the CCG s Dignity at Work policy. In this instance the CCG may protect its staff by limiting the communication channels open to the individual making the complaint. This may include individuals who are persistent or vexatious complainers. 16. Complaints not handled by the CCG The following complaints are not required to be dealt with in line with the Regulations and in light of the changes to the NHS System from 1 April 2013: A complaint about a primary care provider (GP, dentist, optician, pharmacist), these are now within the remit of NHS England (Tel: ) or A complaint about private treatment A complaint made by another responsible body A complaint made by an employee of a local authority or NHS body about their employment A complaint made orally and resolved to the complainants satisfaction no later than the next working day on which the complaint is made A complaint that has already been resolved A complaint that has already been investigated under these regulations or previous regulations A complaint arising from the alleged failure to comply with a request for information under the Freedom of Information Act 2000 A complaint from another responsible body, e.g. a hospital trust, GP practice, or independent provider; Matters relating to the employment arrangements of an employee of an NHS body; A complaint the subject matter of which has been previously dealt with under complaint regulations; An oral complaint that has been dealt with and resolved to the complainant s satisfaction within a working day of the complaint being voiced. a complaint which has been previously handled and a final response directing the complainant to the PHSO provided; and Matters that have been referred to or have been investigated by the PHSO. Additionally the CCG will consider declining to handle a complaint: made beyond the time limit for making complaints and for which a reasonable explanation of the delay has not been given or accepted; In which the CCG is not satisfied that a third party is a suitable person for making a complaint on behalf of the patient; Policy for the Management of Concerns & Complaints (Dec 2014) Page 16 of 23

17 made by an adult on behalf of a child who is capable of making the complaint themselves and has chosen not to do so, or has not provided consent for the complaint to be made on their behalf; From an individual whom the CCG has determined to be persistent and vexatious as outlined in Appendix A of this policy and no satisfactory change in behaviour has been identified. Where the CCG declines to handle a complaint, it will notify the complainant in writing of the decision and the reasons, providing signposting information of other organisations who may be able to support the complainant. 17. Mediation The CCG is not in a position to provide a formal mediation service for providers and complainants who are having difficulty resolving a complaint. However, it may be able to provide advice on how to resolve a complaint to either party but this will not involve a representative from the CCG attending meetings between complainant and provider. Where it is appropriate, the CCG will advise the complainant of the services of the Independent Complaints Advocacy Service that is established to assist complainants with the management of their complaint. 18. Primary Care complaints Services directly commissioned by NHS England include: Primary care services, ie GP, dentist, pharmacy, optometry Specialised services Offender health Military services The CCG has no role to play in responding to complaints about these services. Should the CCG receive a complaint which is determined falls under the jurisdiction of NHS England, the complainant will be advised accordingly. The Patient Experience Team will, with consent, re-direct any correspondence to NHS England as appropriate. Where a complaint includes services commissioned jointly by the CCG and NHS England, the Patient Experience Team will advise the complainant and liaise accordingly with NHS England to establish who will be the main lead in the management of the complaint. 19. Parliamentary & Health Service Ombudsman (PHSO) The CCG welcomes the closer involvement of the PHSO with regards to complaints as a result of the 2009 regulations. The PHSO is in a position to take an independent view of how the CCG has handled and responded to a complaint, and whether it has provided sufficient redress where an injustice has taken place as a result of the matters being complained about. By taking the approach that the CCG will seek to provide the best answer it can in the final response, and by taking whatever time is reasonably necessary in order to ensure the best quality response, the CCG will regard a referral to the PHSO in a positive light. There will be Policy for the Management of Concerns & Complaints (Dec 2014) Page 17 of 23

18 one of two outcomes from a referral to the PHSO: it will either be decided that we have provided an appropriate response and no further action will be taken; or the PHSO will investigate and provide a view on the handling and outcome of the complaint. If the PHSO should choose to investigate and find failings or omissions in the CCG s response then that will provide learning opportunities that can be put to use in future investigations. The CCG will not regard a referral to the PHSO as an indicator of failure to properly investigate and respond to a complaint because it is acknowledged that a full response may not always provide the complainant with answers that will satisfy them. This is particularly relevant to cases where the redress sought by the complainant is beyond the power or lawful authority of the CCG to deliver. The CCG will co-operate fully with the PHSO on any complaint that is referred to it and will take action on any findings that the PHSO makes as a result of a complaint. It should be noted that the PHSO will be primarily concerned with identifying whether any maladministration has taken place in the matters raised in the complaint, or in the handling of the complaint, and whether the CCG has failed to provide a service that it is statutorily required to provide. The PHSO will not necessarily challenge a decision made by the CCG as long as it can be demonstrated that no maladministration or failing has taken place in the process by which the decision was made. 20. Lessons learned The Patient Experience Manager will provide a learning and outcomes based report to the CCG Patient Safety & Quality Committee (PSQ). This report will provide details of the nature of concerns and complaints which have been raised, what lessons have been learned and key outcomes and changes made as a result. Should a complaint identify risks that the CCG needs to record on its risk register, the Patient Experience Manager will request the Service Lead completes a risk assessment and ensure appropriate actions are taken to mitigate or eliminate the risk as per the CCG s Risk Management Strategy. 21. Working in Partnership Multi-Agency Complaints Note: This section is founded on regulation 9 duty to co-operate and will only apply where a section of the complaint is about the CCG s exercise of its functions. If no element of the CCG s functions can be identified within the complaint, the CCG will not act as broker for the complaint and will pass it on to the organisation with the majority of the content of the complaint. Complaints can feature more than one service or organisation and the 2009 Regulations permit responsible bodies to agree that one body should take the lead in the handling of a complaint. Where it is considered appropriate for the CCG to take the lead in handling a multi-agency complaint it will do so, and will work closely with the other agencies involved to ensure that the complaint is properly investigated and the issues complained about are addressed. Where the CCG is not the lead agency but a party to the complaint, it will make all best efforts to ensure full co-operation and relevant sharing of information with the lead agency. Policy for the Management of Concerns & Complaints (Dec 2014) Page 18 of 23

19 Where the CCG is the lead agency in handling a complaint and for any reason finds an agency to be uncooperative in assisting with the proper handling of the complaint, the agency will first be reminded of its obligations under the Regulations and any relevant legislation. If this does not resolve the issue then the lack of co-operation will be clearly identified in the complaints response. It will then be a matter for the complainant to decide whether they wish to raise these matters with the PHSO or other relevant body, such as the Information Commissioner. CCG Advice & Enquiries Service (formerly PALS) The Patient Experience Team provides an advice service for dealing with informal issues, enquiries and concerns about the CCG s commissioning decisions and the NHS generally. NHS Complaints Advocacy It is not the role of the CCG s Patient Experience Team to provide advice on the merits of a complaint, or on how the complaint should be framed, but it can advise on the process that will be followed for handling and responding to complaints. NHS Complaints Advocacy has been established by the Department of Health to provide complainants with an advocacy service that can assist complainants with writing letters, preparing for and attending meetings, the options available at each stage of the complaint and help with making decisions on the complaint. The contact details for Complaints Advocacy in Cambridgeshire are: POhWER NHS Complaints Advocacy PO Box Birmingham B6 9BL Telephone: Accessibility The CCG is committed to ensuring that the guidance in this policy is accessible to all. This means that, as required, additional support will be provided to help ensure that the information in this policy can be understood and its guidance followed. This support includes (but is not limited to): The provision of the policy and any associated documents in alternative formats. Enabling individuals to have an advocate or interpreter involved for support with communication Making reasonable adjustments, in discussion with individuals or their representative, to procedures where these are necessary to ensure their accessibility All staff involved in the implementation of this policy will need to proactively consider the additional actions that might be required to ensure that individual needs can be met as far as is practicably possible. Ensuring accurate and appropriate communication will help to reduce communication errors and the effective and fair handling of complaints. Actions to improve communication could include providing: Policy for the Management of Concerns & Complaints (Dec 2014) Page 19 of 23

20 easy read, Braille, pictures and symbols, or other formats when explaining information a translator for people for whom English is not their first language information using picture communication symbols Supplying correspondence and leaflets in alternative languages and formats, including easy read Information about access to advocacy services if needed telephone advice and support using alternative languages and formats 23. Monitoring and Performance Management of the policy In addition to the quarterly reports, an annual combined summary will be produced at the end of each year including lessons learned and changes made as a result of complaints and concerns raised with the CCG. This report will be presented to the Patient Safety & Quality (PSQ) Committee. The CCG shall also receive reports on complaints handled by the providers it commissions services from and will use information obtained from these reports to inform their contract monitoring and evaluation work. This policy is scheduled for a review every 3 years or earlier should a change in legislation occur. JANUARY 2015 Policy for the Management of Concerns & Complaints (Dec 2014) Page 20 of 23

21 Appendix A PROCEDURE FOR HANDLING VEXATIOUS & PERSISTENT COMPLAINANTS 1. INTRODUCTION 1.1. Persistent complainants can place a strain on resources and cause undue stress. CCG staff are trained to respond with patience and understanding to the needs of all complainants but there are times when nothing further can be done to assist them or rectify a real or perceived problem In determining arrangements for handling such complainants, staff are presented with two key considerations. The first is to ensure that the complaints procedure has been correctly implemented so far as possible and that no material element of a complaint is overlooked or inadequately addressed. In doing so it should be appreciated that even persistent complainants may have issues which contain some genuine substance. The need to ensure an equitable approach is therefore crucial. The second is to be able to identify the stage at which the complainant has become unreasonably persistent. It is emphasised that the identification of a complainant as persistent should only be used as a last resort and after all reasonable measures have been taken to try to resolve complaints following the NHS complaints procedure. 2. IDENTIFYING A PERSISTENT COMPLAINANT A persistent complainant may display some or all of the following behaviour: The complainant changes the substance of a complaint or continually raises new issues or seeks to prolong contact by continually raising further concerns or questions upon receipt of a response whilst the complaint is being addressed. The complainant is unwilling to accept documented evidence of treatment given as being factual, e.g. drug records, General Practitioner manual or computer records, nursing records The complainant denies receipt of an adequate response in spite of correspondence specifically answering their questions. The complainant does not accept that facts can sometimes be difficult to verify when a long period of time has elapsed. The complainant does not clearly identify the precise issues which he/she wishes to be investigated, The complainant does not accept that the concerns identified are not within the remit of the CCG to investigate. The complainant persists in pursuing a complaint where the NHS complaints procedure has been fully and properly implemented and exhausted. The complainant makes an excessive number of contacts with the CCG and places unreasonable demands on staff. The complainant is known to have recorded meetings or face-to-face/telephone conversations without the prior knowledge and consent of other parties involved. The complainant makes unreasonable demands and fails to accept that these may be unreasonable (e.g. insists on responses to complaints or enquiries being provided more urgently than is reasonable or normal recognised practice). Policy for the Management of Concerns & Complaints (Dec 2014) Page 21 of 23

22 3. AGGRESSIVE / ABUSIVE COMPLAINANTS 3.1. Staff should be aware that some complainants may: Threaten or use actual physical violence towards staff or their families or associates. Harass or be personally abusive or verbally aggressive on more than one occasion towards staff dealing with their complaint or their families or associates. This will include racial harassment. (Staff must recognise that complainants may sometimes act out of character at times of stress, anxiety, or distress and should make reasonable allowances for this. They should document all incidents of harassment). 4. OPTIONS FOR DEALING WITH A PERSISTENT, AGGRESSIVE OR ABUSIVE COMPLAINANT 4.1. Where a complainant persists with displaying any of the above behaviour, the Patient Experience Manager, in agreement with a relevant senior manager and Chief Officer, should take the following action: Warn the complainant that if they persist with the approach they are taking, they will be classed as a persistent complainant. Warn the complainant that in extreme circumstances the CCG reserves the right to pass unreasonably persistent complaints to the CCG s solicitors. If appropriate, draw up a signed agreement with the complainant which sets out a code of behaviour for the parties involved if the CCG is to continue processing the complaint. Consider involving the Local Security Management Services (LSMS) should the CCG consider such action necessary for the protection of its members If any of the above actions do not elicit the required behaviour, the patient / complainant will be advised that they are being classed as an unreasonably persistent complainant, the reasons why will be clarified and a temporary suspension of all contact with the complainant or investigation of a complaint will be noted. Legal advice or guidance from the relevant agencies such as the Counter Fraud and Security Management Services This notification may be copied for information of others already involved in the complaint, e.g. staff, ICAS or Member of Parliament and a record kept for future reference of the reasons why a complainant has been classified as persistent. 5. WITHDRAWING PERSISTENT COMPLAINANT STATUS 5.1. Where a complainant subsequently demonstrates more reasonable behaviour on submission of a further complaint, a discussion will be held with the Chief Officer and appropriate senior manager regarding the complainant s status. Subject to their approval, normal contact with the complainant and application of the NHS complaints procedures will then be resumed. 6. REVIEW OF PROCEDURE This procedure will be reviewed and revised every 3 years as appropriate in line with CCG s Complaints Policy and Procedure on a yearly basis. Policy for the Management of Concerns & Complaints (Dec 2014) Page 22 of 23

23 Appendix B: Procedure for the Management of Concerns and Complaints Correspondence re Concern or Complaint received Correspondence passed to Patient Experience Team (PET) PET establish responsibility for Response Concern or Complaint about CCG policy, process, decisions etc Concern or Complaint about CCG commissioned services Concern or Complaint primary care service Consent to share requested Details passed to CCG Service Director/Lead to arrange investigation/response Details passed to Service Provider Details passed to NHS England Matter closed Service Director/Lead sends investigation outcome/response to PET PET compile response on behalf of CCG Final response sent to EA, Corporate Services to arrange signature Matter closed Policy for the Management of Concerns & Complaints (Dec 2014) Page 23 of 23

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