|References||GMC: Good Medical Practice 2013 |
DoH: Listening Responding Improving
CQC: Fundamental Standards
Appendix 3. IDF Complaint resolution Procedure
Appendix 5. Complaint Procedure for patients regarding nurse
|Appendices||1. Patient Complaint Information Leaflet |
2. Complaint Form
3. CEDR Private Healthcare Mediation Scheme Rules
4. Guidance for managing unacceptable, vexatious behaviour
5. Complaints regarding the Practice Nurse
|Scope||All individuals in the employ of this establishment |
(‘employ’ means any person who is employed, self-employed, a volunteer, working under practising privileges or contract of service with this establishment)
Definition of complaint
Any communication involving goods or a service that requires an investigation and formal response. Complaints may be made by letter or e-mail or text. We want to ensure that all patient concerns and complaints are dealt with thoroughly, promptly in accordance with the principles of effective complaints handling:
resulting in satisfactory conclusions and improvement in delivery of care where appropriate. PrivateGP.com accepts the rights of patients (and their relatives or representatives, if appropriate) to make complaints and to register comments and concerns about the services received and that they should find it easy to do so. We welcome complaints and look upon them as opportunities to learn, adapt, improve and provide better services.
PGP believes that failure to listen to or acknowledge complaints leads to an aggravation of problems, service user dissatisfaction and possible litigation. PGP supports the idea that most complaints, if dealt with early, openly and honestly, can be sorted at a local level between just the complainant and the Practice.
The Registered Manager is responsible for following through complaints for the practice. The Clinical Governance Committee formally reviews all complaints at least every three months as part of its quality monitoring and improvement procedures, to identify the lessons learned.
Staff must treat all patients, whether complaining or not, with courtesy, politeness, empathy and professionalism.
All complaints, whether given verbally or in writing, must be taken seriously and acknowledged. The complainant should be directed to the policy and procedure and especially to the patient leaflet at
Appendix 1. Written complaints must be acknowledged within three working days. The acknowledgement should start with a sentence that the member of staff is sorry that the complainant feels that the practice has not acted in a way that they would have expected. This does not constitute an apology for the issue, nor that the complaint is valid, rather it acknowledges the complainant’s feelings about the issue.
A meeting could be offered to the complainant to which they may bring a friend, relative or a representative such as an advocate. It would be helpful to know whether the advocate was a lawyer attending as a friend or in a legal capacity on behalf of the patients.
If the complaint is about Dr Julia Piper or another IDF clinician member, the practice manager must be informed and the Complaint Resolution Procedure at Appendix 3 and Appendix 4 followed.
If the complaint is about the practice nurse, the complaints procedure at Appendix 5 must be followed.
If you are unhappy with the facilities or services you have received from any member of staff at PrivateGP.com, whether clinical or non-clinical, we would like to know about it as soon as possible so we can investigate your concerns and explain, apologise and take positive action where necessary. In most circumstances, if you tell us about your concern quickly, we can resolve matters straightaway. To let us know about something with which you are unhappy please speak with the Operations Manager in the first instance. If the complaint is against the Operations Manager, please speak with Dr Piper.
Complaints against the Practice Nurse
Please see Appendix 5
Verbal complaints must be written down by the member of staff receiving them, signed and dated. If the complainant has telephoned the member of staff must read back the complaint to ensure that there is complete understanding of the details of the complaint, names, times and dates. If possible, the member of staff receiving the complaint should try to resolve the issue themselves. If the complaint has been resolved by the member of staff to the satisfaction of the complainant, the resolution must be sent to the complainant in writing as a follow up.
If the complaint is in writing, this must be acknowledged within three working days and the investigation to be concluded, if possible, within 20 working days with a letter to the complainant fully explaining the investigation, any meetings held, the outcome and any learning arising from this to be inculcated into the working of the practice. All actions associated with the investigation must be logged in the complaints record. Should the investigation take longer than 20 working days, the complainant must be informed in writing and given an indicative date by which the investigation would be concluded and the result produced. If it is found at this stage that the complaint is complex and may require legal input, then legal advice must be sought and the complainant advised of this. The complaint may then be moved to Stage 2.
If the complaint is being made on behalf of the patient by a relative or other representative (advocate), it must first be verified that the person has permission to speak for the patient, especially if confidential information is involved. Signed and dated consent by the complainant is required. It is very easy to assume that the advocate has the right or power to act for the service user when they may not. If in doubt, it should be assumed that the patient’s explicit consent is needed prior to discussing the complaint with the advocate.
The letter advising the complainant of the outcome at Stage 1 must detail what action the complainant should take for resolution. This is detailed in Stage 2.
If not, then the complainant must be informed that their complaint will move to Stage 2, that they should complete the form, Appendix 2, and that it will be forwarded to the practice manager.
If following receipt of the letter informing the complainant of the outcome of stage 1, the complainant is not satisfied, the complainant must complete a Complaint Form, Appendix 2, and send it to the practice manager at PrivateGP.com within 20 days of receiving the outcome of Stage 1. The Practice Manager or other senior member of staff, with no prior knowledge of the original complaint will be assigned to investigate the complaint, using the documentation from Stage 1. If appropriate, a meeting will be held with the complainant, accompanied if they wish as above, the member of staff who investigated at stage 1 and any witnesses required by the investigator at stage 2. The meeting will be called within 15 working days of the receipt of the complaint form, unless the complainant is unable to attend, in which case a second date will be arranged. Should this date not be convenient for the complainant, the meeting may still go ahead. The decision will be sent to the complainant within five working days.
if following receipt of the letter informing the complainant of the outcome of stage 2, the complainant is not satisfied, the complainant should apply to use the Private Healthcare Mediation Scheme run by the Centre for Effective Dispute Resolution (CEDR). See Appendix 4.
PGP takes seriously any comments or complaints regarding its service. However, there are service users who can be treated as vexatious complainers due to the inability of the practice to meet the outcomes of the complaints, which are never resolved. The process at Appendix 5 will be used in this case. See CR26c Guidance for Managing Unacceptable, Vexatious Behaviour by Complainants.
Complaints that involve clinicians or other healthcare professionals
Complaints made about the clinical care delivered at PGP are treated seriously. The practice manager will immediately seek advice from the medical director who will take advice from the GMC and/or the MDU or other indemnity organisation. The practice manager will work with the medical director to resolve the complaint. (Note: if the complaint is made about the medical director, the practice manager will share the complaint with another clinician).
Complaints that involve children
Complaints involving children are to be treated seriously and investigated with care. If the complaint is of a safeguarding nature, the safeguarding lead must be contacted immediately and will lead the investigation. Depending upon the circumstances, Gillick competency and/or Fraser Guidelines may or may not have been involved with decision making processes and all clinical staff engaged with looking after or having contact with children must have knowledge of these and have made appropriate documented notes.
Patient Complaint Information Leaflet
As a practice we strive to provide the best possible service for our patients. However, we recognise that sometimes you may feel that we have not met your needs.
If you have a concern or complaint about the service you have received from the doctors or staff working at this centre, you are entitled to ask for an explanation.
We operate an in-house complaints procedure to deal with your complaint. This procedure does not deal with matters of legal liability or compensation.
Our promise to you
How to make your complaint
We hope that we can resolve your problem easily and promptly, often at the time the problem arises and with the person concerned. If your problem cannot be sorted out in this way and you wish to make a formal complaint, we would like you to do so as soon as possible. This will enable us to establish what happened more easily.
Please make your complaint in writing to the practice manager. If you would like assistance with making your complaint, a member of staff will be able to help you complete a Complaint Form.
Please be assured that any complaint you make, written or verbal, will be treated in strict confidence and have no effect upon the level of treatment and care that you receive at the practice.
If you would prefer a family member, friend or advocate to make the complaint on your behalf, they may do so and the centre will work with them, and yourself, to resolve the problem. However, whilst we can receive a complaint on your behalf, we cannot provide any medical information to a third party without your authority. To discuss or provide information about you, we will require a note to this effect signed and dated by you. A member of our staff would be happy to assist you with this.
What happens next?
Your complaint will be acknowledged within three working days of receiving it. This may well be a phone call from the practice manager to you (or your advocate) to make sure we fully understand your complaint.
We aim to make a full response to you within the next twenty working days. During that time we will conduct an investigation to find out what has happened and whether there is any action that can be taken to put things right. If at the end of those twenty days we are still conducting our investigations, we will notify you of the position and keep you fully informed until our investigations have been concluded.
As a result of the practice investigation we will:
Getting further help with your complaint
We hope that, through our practice complaints procedure, we can resolve your problem satisfactorily. We believe that this will give us the best chance to put the matter right with you and the opportunity to improve our services for all our patients.
In the case of nursing staff:
Where the complaint cannot be resolved between the parties, independent external arbitration will be sought by the NMC.
For those clinicians who are members of the Independent Doctors Federation and will refer to the IDF if internal resolution cannot be achieved. Should there still be an impasse then the IDF will refer the complaint to the Independent Healthcare Sector Complaints Adjudication Service. ISCAS and its findings will be final to both parties.
For those clinicians who are not members of the IDF, the complaint will go straight to ISCAS if internal resolution (Stages 1 and 2) cannot be achieved.
You may also contact the Care Quality Commission, if you feel that your complaint is not being dealt with in a satisfactory manner, on 03000 616161. (Note: the CQC will not arbitrate in a complaint but require the provider to make their (CQC) contact details available to the service user).
Patient Complaint Form
Patient name: ……………………………………………………
Telephone number: ……………………………
Best time of day to be contacted on phone: ………………
If complaint is being made on behalf of the patient, please note relationship to patient: ……………………….
Where appropriate, a consent letter must be signed and dated by the patient allowing a relative to speak on their behalf.
Telephone number: ……………………………
Best time of day to be contacted on phone: ………………
Nature of complaint / problem:
*Signed by: ………………………………………… on ……/……../……… Time: …………………..
Referred to: ……………………………………….. on ……/……../……… Time: …………………..
*Please note: If a patient is unable to put his/her complaint in writing, please use this form to record the complaint and indicate that you are writing it on behalf of the patient and ask them to sign a the end of the statement to confirm it is accurate and you have permission to refer it on.
Private Healthcare Mediation Scheme Rules
Mediator within 5 working days and will inform the parties accordingly.
T: +44 (0)20 752000 W: cedr.com/consumer/E: email@example.com
Legal status and effect of the Mediation
27. The process is governed by the law of England and Wales and the courts of England and Wales shall have exclusive jurisdiction to decide any matters arising out of or in connection with this Agreement and the Mediation.
30. These Rules may be amended by CEDR from time to time, and current Rules apply to any application on the date of application.
|Centre for Effective |
100 St. Churchyard
London EC4M 8BU
|T: 020 7520 3800 |
T: +44 (0)20 7520 3800
|Registered Charity number 1060369 |
Registered in England as
Centre for Dispute Resolution
Limited number 2422813
Most people who complain about an independent healthcare act entirely reasonably. Occasionally, complainants may act inappropriately towards the staff involved in the investigation of a complaint for several reasons. A small number of complainants may take up a disproportionate amount of staff time in dealing with their complaint. Where a complaint investigation is ongoing – the appropriate manager should write to the complainant setting parameters for a code of behaviour and the lines of communication. If these terms are contravened, consideration will then be given to implementing other action. This should help to avoid any complainant behaving in a way that is not acceptable.
Handling unacceptable behaviour by complainants places a great strain on time and resources and causes undue stress for the complainant and staff who may need extra support. A complainant who behaves in a way that is unacceptable should be provided with a response to all their genuine grievances and be given details of independent organisations that can assist them, for example, the Citizens Advice Bureau, Patient Organisation, independent advocacy.
Although staff are trained to respond with patience and empathy to the needs of all complainants, there can be times when there is nothing further which can reasonably be done to assist them or to rectify a real or perceived problem.
When dealing with such complainants, staff should consider the following:
Where a complaint investigation is complete – at an appropriate stage, the appropriate manager should write a letter informing the complainant that:
In extreme cases, the appropriate manager should reserve the right to take legal action against the complainant.
Once complainants have ceased behaving unacceptably, they should be informed that the policy on unacceptable behaviours no longer applies if, for example, the complainant subsequently demonstrates a more reasonable approach or if they submit a further complaint for which the normal complaints process would appear appropriate. As staff use discretion in identifying unacceptable behaviours discretion should similarly be used when recommending that the policy on unacceptable behaviour no longer applies.
Examples of unacceptable behaviours include
Making a complaint to the Practice in no way prejudices the patient’s right to complain to the Nursing & Midwifery Council should the complaint not be resolved to their satisfaction.
The Practice Manager co-ordinates the complaints procedure on behalf of the Practice.
Complaints should be submitted in writing as soon as possible after the event giving rise to the complaint, ideally within 20 days or at least within 6 months.
The Practice Manager will then ensure that all relevant details are recorded and arrange for the complaint to be investigated.
The Practice aims to report back to the complainant within 20 working days. If this is not possible the reason for the delay will be explained to them and they will be given a revised date for the completion of the investigation.
An initial ( Stage 1) investigation will take place within the Practice. In the event of the issues not being resolved:
CR26 Complaints Policy and Procedure Version 2 21.02.2022 2022. Review due 21.02.2024