❋ UMGH Complaints Policy
Table of Contents
Summary of Policy...................................................... 1
Purpose...................................................................... 3
Scope......................................................................... 3
Definitions.................................................................. 4
Principles of Complaint Handling................................. 5
Confidentiality of Complaints....................................... 5
Process and Timescales............................................. 5
Supporting SOPs and Related Policies........................ 7
Roles and Responsibilities........................................... 7
Communication and Training....................................... 8
Success Criteria and Monitoring Compliance............... 9
Consultation, Review and Auditing............................. 10
References and Resources and Relevant Legislation. 10
Summary of Policy
This policy outlines the commitment of United Medical Group Healthcare to provide a fair, transparent, and effective process for managing all complaints received from a patient, their representatives, or other stakeholders.
We are dedicated to resolving concerns promptly, learning from complaints and taking appropriate action to resolve complaints in a timely manner.
1. Purpose
The purpose of this policy is to provide a clear statement of intent with regards to the assessment, handling and investigation of customer complaints. The policy has been created to meet, and be compliant with, general standards and requirements.
In doing so, United Medical Group Healthcare aim to ensure that all customer complaints, either written or verbal, are handled in a consistent and regulated manner and that further complaint incidents are mitigated and, where possible, prevented. Where a parent/carer has cause to complain, the complaint policy will be followed in every instance and a record will be made of the complaint to help improve our services and reduce the occurrence of similar complaints.
United Medical Group Healthcare is committed to delivering a fair, open and clear process for complaints, ensuring a satisfactory outcome for all customers who raise a complaint. We provide staff training in our internal complaint handling procedures and support our staff in how to handle complaint situations in face-to-face, written and/or telephone context.
This policy sets out our intent and objectives for how we handle complaints, from offering a clear and approachable system for customers to complain, through to conducting root cause analysis on all complaints received to identify the cause, issues and corrective actions regarding the complaint, and to implement measures to prevent reoccurrences where applicable.
2. Objectives
For the purposes of this policy, a complaint is defined as any customer contact whereby a negative communication or outcome has occurred. The parent/carer does not have to formally address their communication as an official complaint or to request a response for The United Medical Group Healthcare to treat the incident as a complaint and to follow the related procedures.
Internal complaint handling are:
1. To provide a fair complaints procedure which is clear and easy to use for anyone wishing to make a complaint.
2. To ensure that our complaints procedure is fully accessible so that people know how to contact us to make a complaint.
3. To make sure everyone at United Medical Group Healthcare knows what to do if a complaint is received.
4. To make sure all complaints are investigated fairly and in a timely way.
5. To gather information which helps us to improve what we do and how we do it.
6. To ensure that the Data Protection Officer is involved in any complaints relating to personal data.
The United Medical Group Healthcare objectives for the complaint handling process are:
1. Formal complaints will be investigated and responded to within 28 days from the date that the complaint is received.
2. Formal complaint responses will always be provided in writing.
3. The complaint procedure will be available via the company website.
4. All complaints will be investigated by a trained member of staff who will consult with all relevant parties where it is practical and possible to do so.
5. Complaint records will be used to revise company procedures and to improve communication and business practices where applicable.
UK legislation, including the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, Data Protection Act 2018 (GDPR), Equality Act 2010, and best practice guidance from the Care Quality Commission (CQC) and other professional bodies.
3. Scope
This policy applies to:
· All associates staff engaged by United Medical Group Healthcare to provide services
· All aspects of the service provided by United Medical Group Healthcare including and not limited to:
This policy covers complaints made by patients, their legal representatives, family members (where appropriate consent is given or in the best interest of the service user), or other relevant third parties.
4. Roles and Responsibilities
The Chief Executive Officer (CEO) has overall accountability for ensuring that the Complaints Policy meets statutory requirements. Signing of complaint response letters will be delegated in the first instance to the Clinical Director.
All employees and contractors
· To be aware of this complaints policy and the complaints procedure.
· To treat all expressions of dissatisfaction seriously and with empathy.
· To log all complaints within the RADAR system for review.
· To attempt to resolve minor concerns informally and promptly where appropriate and possible, at the first point of contact.
· To immediately escalate any formal complaint or unresolved concern to the complaints manager.
· To cooperate fully with any complaint investigation, providing accurate and timely information as requested.
5. Procedure
Raising a complaint: Customers who request United Medical Group Healthcare’s complaint policy will be provided with a copy of the policy and will be asked to raise their complaint in writing as soon as possible after the incident.
If a customer telephones United Medical Group Healthcare and wishes to raise a complaint, they should be passed through to a senior member of staff who will try to resolve the complaint then and there. Even if the complaint is resolved at the time, the parent/carer must still be offered the option of receiving the complaints policy prior to ending the call.
Informal complaint resolution: United Medical Group Healthcare considers and responds to all complaints and issues, no matter how they are raised or what they refer to. Some issues and complaints we can resolve immediately or within a three-working day timeframe and are referred to as informal complaints. Such instances are where an investigation is not required because the nature of the complaint is clear, and a resolution can be obtained without further review of the facts.
Where we resolve a complaint within the timeframe, the details are still logged on our complaint register.
United Medical Group Healthcare takes every opportunity to resolve complaints at the first initial point of contact, where feasible and possible. Informal resolution is always attempted where the issues raised are straightforward and potentially easily resolved, requiring little or no investigation. Most face-to-face and telephone issues can be resolved in this manner; however, the complainant is always offered the option of making the complaint formal if the resolution is not to their satisfaction.
Where an informal complaint is received, it is acceptable for the point of contact or addressed employee to attempt to resolve the issue without involving the Complaints Manager. However, any issue relating to data protection infringes or breaches, no matter how small or informal, are always brought to the attention of the Data Protection Officer or appointed person.
United Medical Group Healthcare associate clinicians and staff are trained to deal with basic issues and informal complaint resolution and are aware of their obligations and the subsequent reporting lines. Such employees are equipped to attempt to resolve a complaint relevant to their area of service or expertise, wherever possible.
Timeframe for informal resolution: It is the aim of United Medical Group Healthcare to resolve informal complaints immediately, or at least within the first 24 hours. Such complaints and issues will have a quick, but informative response, and do not need to have an investigation or enter the formal complaint process. No matter how small or informal the complaint, if a satisfactory resolution has not been achieved within three working days of the complaint being raised or identified, the issue is passed to the Complaints Manager to enter the formal complaint process.
Responding to a complaint: Where an official complaint has been received, or the informal complaint was unable to be resolved at the frontline point of contact, a written acknowledgement is sent to the customer within three working days. The response should detail the complaint policy and provide approximate timelines and expectations for the investigation and future responses. A trained manager or the Data Protection Officer are the only staff members who should respond to customers regarding their complaints.
Investigating the complaint: The designated staff will be assigned the role of investigating complaints and will gather all necessary documents, recordings and information to make an independent review of the incident. All investigations must take place within 28 days of the initial complaint being received so that a final response (decision letter) can be sent to the customer within our designated 28-day period.
Investigations must utilise all the facts and any previous related information to produce an unbiased outcome and an expected course of action. A complaint reference should be assigned and all documents relevant to the complaint should have the reference written on them for continuity. The reference will also be added to the Complaints Log so that the complaint and documents can be audited and traced back in the future.
All staff are provided with clear guidelines of when a complaint is formal and requires an appropriate investigation.
Decision letter (final response): After the complaint has been investigated in full and an outcome and action decision has been reached, the investigator or the Complaints Manager will draft a final response letter to the parent/carer with their findings and decision regarding any action(s) to be taken. The final response must be sent within 28 days of the initial response being raised.
For complaints related to personal data and/or breaches of the data protection laws and regulations, the final response will reiterate the complainant’s right to lodge a complaint with the supervisory authority- the Information Commissioners Office – and will detail the Information Commissioners Office’s telephone number and address, along with the possibility of seeking a judicial remedy.
6. Who can make a complaint?
A complaint can be made by a service user or individual who is dissatisfied with the service they have received. A complaint may be made by a representative acting on behalf of a person who:
• Is a child – United Medical Group Healthcare must be satisfied that there are reasonable grounds for the complaint to be made by a representative of the child (rather than by the child themselves), and that the representative is making the complaint in the best interest of the child (a child is considered anyone up to the age of 18).
• Has a physical or mental incapacity - In the case of a person who is unable to make the complaint themselves because of either physical incapacity or who lacks capacity within the meaning of the Mental Capacity Act 2005, Held Health needs to be satisfied that the complaint is being made in the best interest of that person.
• Has given consent to a third party acting on their behalf - In this case United Medical Group Healthcare will require the following information
i. Name and address of the person making the complaint
ii. Name and either date of birth or address of the person who is the subject of the complaint
iii. A consent form signed by the person who is the subject of the complaint
7. Definitions
· Complaint: Any expression of dissatisfaction, whether written, email or oral, where a response or resolution is explicitly or implicitly expected. The complaint may be about the provision of care, treatment, or services or about the conduct of an individual working for United Medical Group Healthcare on an employed or contractor basis. It includes but is not limited to any dissatisfaction with a diagnosis, treatment plan, medication, communication, access to services, or the overall experience.
· Concern: A concern is an issue that can be raised in a number of ways, however unlike a complaint these may not need to be investigated but should be resolved through local resolution and within two working days. Concerns have the potential to escalate to formal complaints, however dealing with these effectively and quickly can reduce the likelihood of this happening.
Responding to concerns through local resolution is more informal than a complaint, and can be done verbally or via email, but the preference of the person raising the concern and the outcome that they expect should be taken into account.
· Compliment: A compliment is an expression of praise towards one or more people and can be in relation to the services provided. It’s important to record compliments so that we can identify where we are making good progress and excelling either generally or in specific areas. We can then understand more about this good practice and share this learning with other departments.
· Complainant: The individual making the complaint. This may be the service user themselves, or a person acting on their behalf (e.g., a relative, advocate, or legal representative).
· Investigation: The process of gathering all relevant facts, evidence, and perspectives related to a complaint to determine its validity and identify any necessary actions.
· Resolution: The outcome of the complaint process, which may include an explanation, an apology, remedial action, a change in practice, or a combination thereof.
· Early resolution written response: A written email/letter to the complainant outlining the agreed early resolution of a concern.
· Formal response: A written report from the complaints team detailing the investigation into the formal complaint, which includes outcomes and lessons learned.
· Working Day: Monday to Friday, excluding public holidays.
8. Principles of Complaint Handling
United Medical Group Healthcare is committed to the following principles when handling complaints:
· Accessibility: Ensuring the complaints process is easy to understand and access for all individuals, including those with communication needs or disabilities.
· Fairness and Impartiality: Treating all complaints objectively, without prejudice, and ensuring a balanced consideration of all evidence.
· Transparency: Clearly communicating the complaints process, progress, and outcomes to the complainant.
· Promptness: Handling complaints efficiently and within defined timescales, providing updates where delays occur.
· Confidentiality: Protecting the privacy of all parties involved, adhering strictly to data protection regulations (GDPR/Data Protection Act 2018). Information will only be shared on a need-to-know basis.
· User-Centred Approach: Focusing on the complainant's perspective, actively listening to their concerns, and striving for a resolution that addresses their dissatisfaction.
· Learning and Improvement: Using complaints as valuable feedback to identify systemic issues, improve service quality, and prevent recurrence of similar problems.
· Accountability: Taking responsibility for actions and decisions and providing appropriate remedies where errors or shortcomings are identified.
9. Timescales for raising concerns or making a complaint
In most cases, the concern or complaint will need to be made within 12 months of the date of the event or issue occurring, or the date when the person complaining found out about it (whichever is later). We do not automatically refuse to consider any issue that is ‘out of time’ and each must be considered on a case-by-case basis.
Exceptional circumstances - In some cases, there may be a very good reason for not making the complaint before the deadline and we need to consider if it is still possible to respond to the complaint.
This may be due to the person’s individual circumstances e.g. they were too unwell and didn’t feel able to raise within timeframes. If this applies, then the complaints manager will need to carefully consider the reasons and if they feel able to agree to accept the complaint. If needed, further advice should be requested from the associate director of clinical governance.
Complaints investigator
· To be the primary point of liaison for all formal complaints as needed and as allocated by the complaints manager.
· To acknowledge receipt of complaints within the specified period as detailed in the standard operating procedure.
· To liaise with relevant clinicians and administrative staff to gather necessary information and evidence.
· To ensure compliance with all relevant legislation and CQC requirements throughout the complaints process.
· To maintain accurate and confidential records of all complaints.
Complaints manager
· To manage and oversee the entire complaint investigation process, ensuring it is thorough, fair, and timely.
· To identify any trends and themes from complaints and report these to senior management and clinical leads for service improvement.
· To ensure staff involved in complaints are supported and receive appropriate feedback.
· To sign off any formal responses to complainants, ensuring they are comprehensive, empathetic, and address all points raised.
Clinical employees and contractors
· To provide expert clinical input and advice during complaint investigations relating to clinical care, diagnosis, treatment, or prescribing.
· To review relevant clinical records and provide explanations of clinical decisions where required.
· To participate in meetings or discussions related to complaints, as necessary.
· To engage in reflective practice following complaints to enhance their professional development and personal clinical practice.
Registered manager / nominated individual
· To have overall accountability for the effective implementation and adherence to this policy.
· To ensure that adequate resources are allocated for effective complaint handling.
· To review complaint trends and ensure that lessons learned are embedded into service improvements.
· To provide oversight and final approval for responses to complex or high-risk complaints.
· To ensure compliance with CQC fundamental standards regarding complaints.
10. Complaint recording
All complaints, whether formal or informal, are recorded on a Complaints Log. The log should consist of the below information and should be audited on a frequent basis to ensure that incidents are not being repeated and improvements are being made:
1. Date of complaint
2. Customer name
3. Customer reference
4. Nature of complaint
5. Person(s) involved
6. Date formal complaint received
7. Complaint reference
8. Action taken to resolve
9. Date decision letter sent
10. Date complaint closed
The log is made available to any relevant authority, ombudsman or body who relates or oversee the firm’s complaints, as well as being made available with the local Trading Standards should a representative work alongside the organisation.
11. Communication and Training
Effective communication for the successful implementation and adoption of this complaints policy.
Initial communication: This policy will be disseminated to all employees and contractors via email. It will also be added to SharePoint. Clinical leads will be responsible for verbally communicating the policy's key principles to associates staff during scheduled team meetings within one month.
Ongoing communication: Regular reminders about the policy, including updates or revisions, will be circulated quarterly and reinforced during annual performance reviews. Key changes will be highlighted in all-staff emails will be expected to keep current with policies as per the terms and conditions of their engagement with United Medical Group Healthcare.
12. Success Criteria and Monitoring Compliance
We will know that this complaints policy has been consistently adopted and is delivering its intended outcomes and objectives through a combination of qualitative and quantitative measures.
Success criteria
· Increased complaint resolution rate: Aim for an 85% resolution rate for all complaints within the stipulated period.
· Improved complainant satisfaction: Achieve an average satisfaction score of four out of five in post-resolution surveys conducted with complainants.
· Timely acknowledgment and response: 95% of complaints to be acknowledged within three working days and a final response provided within 30 working days.
· Consistent application of procedures: Internal audits will reveal a high level of adherence to the documented complaint handling procedures across all departments.
· Positive employee and contractor feedback: Surveys will indicate a clear understanding of the policy and confidence in applying its principles.
13. Monitoring compliance
Compliance with this policy will be monitored through a multi-faceted approach:
· Complaint log analysis: The quality and safety team will regularly review the centralised complaint log to track key metrics such as volume, resolution times, types of complaints, and outcomes. This analysis will be conducted monthly and reported quarterly to the senior leadership team.
· Internal audits: The internal audit team will conduct bi-annual audits of complaint handling processes across various departments. These audits will assess adherence to procedures, documentation standards, and the quality of resolutions.
· Complainant feedback surveys: The customer experience department will administer post-resolution surveys to a representative sample of complainants to gather feedback on their experience with the complaints process and resolution. This data will be collected continuously and reviewed monthly.
· Employee and contractor feedback: Regular feedback mechanisms will be utilised to gauge understanding and confidence in applying the policy.
· Reporting: A comprehensive report detailing compliance metrics, trends, and areas for improvement will be presented to the executive committee annually by the associate director of clinical governance.
14. Consultation, Review and Auditing
· This policy will be reviewed every three years or sooner if there are significant changes to United Medical Group Healthcare's services, regulatory requirements, or organisational structure. The review will ensure the policy remains effective, relevant, and aligned with our commitment to providing high-quality, safe, and accessible mental healthcare, continuously incorporating learnings from complaints will also influence or patient safety incidents and evolving PSIRF guidance.
· This complaints policy has been developed through a collaborative consultation process to ensure it is comprehensive, practical, and reflects the diverse needs and perspectives within United Medical Group Healthcare. The quality and safety team will review the complaints; the key metrics will be part of the suite of metrics produced by the data analytics team each month. It is the quality and safety team’s role to review them and share learning/themes.
· The quality and safety team will report on key metrics regarding complaints quarterly at each quality and safety committee. Audits will be conducted on a biannual basis to determine the quality and timeliness of complaint handling.
· These audits will assess adherence to procedures, documentation standards, and the quality of resolutions. All complaints will be subject to a 10% quality check monthly from the complaints manager this will be reported to the relevant committees, managers, and individual staff within the organisation.
· Complainant feedback calls will be made post-resolution to a representative sample of complainants to gather feedback on their experience with the complaints process and resolution. This data will be collected continuously and reviewed monthly.
· Training completion rates will monitor mandatory training completion rates for all relevant roles. Non-compliance will be flagged to line managers for follow-up.
References and Resources and Relevant Legislation
· Regulation 16: Receiving and acting on complaints - Care Quality Commission
· Ombudsman Association | Ombudsman Association
· The Local Authority Social Services and National Health Service Complaints(England) Regulation