This article has been provided and sponsored by Quality Compliance Systems.
Author: Tracy Green, Head of Primary Care, Quality Compliance Systems (QCS)
The coronavirus pandemic has brought sudden and unprecedented change to all our lives. Non-urgent appointments have been postponed, cancelled, or in some circumstances, taken place online, or is digitally competent. With phone lines exceptionally busy, patients have been encouraged to book appointments online, but not everyone has access to a smartphone. This has left many feeling digitally excluded.
But remote consultations are just one of many different complaints that have been levelled against GPs and practice staff since the pandemic has taken hold. According to the Medical Defence Union (MDU), complaints relating to the phone manner of GPs during phone consultations, advice about shielding, the use of PPE, and an unwillingness to prescribe extra non-essential medication in the crisis, are other examples.
During the lockdown alone, the MDU says that over 2,500 complaints were made against its members, many of whom are GPs.
The importance of following protocol and embracing best practice
A surge of complaints in the pandemic raises three critical questions, which every GP and practice manager should consider. The first, ‘is what must practices do?’, and the second is, ‘what should practices do?’ At QCS, we recognise that there is a big difference between ‘must’ and ‘should’. One concerns compulsory protocols, the other is centred on best practice. We specialise in providing both.
With this in mind, our policy team recently updated the QCS Complaints, Suggestions and Complaints Policy and Procedure document, which provides comprehensive guidance covering not just the complaints process, but, compliments and suggestions too. Finally, we’ve also drafted a new complaints register, which makes it easier to collate data for the annual KO41B Primary Care Complaints Collection.
But what important protocols should GP surgeries be aware of? As you probably already know, GP practices have a statutory responsibility to comply with the 2009 Complaints Regulations, and the Health and Social Care Act 2008: Receiving and Acting on Complaints (Regulations 14 and 16).
As for the protocols that the Care Quality Commission (CQC) expects surgeries to have in place, in short, they must have an effective and accessible system for identifying, receiving, handling and responding to complaints from people using the service. This also applies to people acting on a patient’s behalf, or that of other stakeholders. All complaints must be investigated thoroughly, and any necessary action taken where failures have been identified.
From a regulatory perspective, when requested to do so, practices must provide the CQC with a summary of complaints, responses and other related correspondence or information. In addition to this, NHS GP practices are required to submit an annual return in their requested format. If GP practices cannot satisfy the CQC requirements, then the CQC has the power to suspend or to withhold registration.
Exceeding basic regulatory standards
Instilling an outstanding complaints mechanism within a practice means having a robust complaints procedure, which properly informs patients how their views can be heard. Most importantly, the process must not only be overseen by a complaints manager but a ‘responsible person’ too. At its very heart, the framework should include information on how the complaints process works, and how positive or constructive feedback can be best given.
Indeed, providing greater transparency is the cornerstone of a set of standards created by The Parliamentary and Health Service Ombudsman (PHSO) for the NHS. Championed by the CQC, the new voluntary guidelines, known as the Complaint Standards Network, are aimed at promoting feedback and continuous new learning.
As a CQC specialist advisor and a former practice manager, I believe that it’s vital that frontline staff have the right skills and experience to properly handle complaints. Just by listening to a patient, offering an apology, and asking that person how the surgery can put things right, is a way that many verbal and potential written complaints can be resolved.
Sometimes, however, patients will ask the complaint handler to document the conversation in a letter or an email. When this happens, my advice is to structure the letter in the ‘You said, we did’ format, which is commonly used in the NHS. The advantage of using this methodology is that not only is the bulleted style of writing clear and concise, it demonstrates to the patient that the surgery has carefully considered the complaint and taken direct action to resolve the issue.
Embedding a rich culture of complaint handling compliance
However, if surgeries are really serious about reducing complaints, they need to constantly assess their processes, and their resources, the most precious of which are of their staff, and the patients that they serve. Instilling a culture of introspection, therefore, is paramount. Complaints should be an agenda item in monthly meetings. Practice managers and GPs should ask frontline staff to identify areas of improvement, log-jams and bottlenecks, which if left unchecked might be a source of future complaints.
The culture should be one of openness and transparency. When things haven’t gone to plan, where possible, monthly meetings can provide an opportunity for the surgery to collectively learn from negative feedback and develop robust solutions, which is a central tenet of the PHSO’s Principles of Good Complaints Handling.
The power of suggestions
Surgeries exhibiting an outstanding complaints handling culture are open to patients making suggestions too. It’s important to reference the role of Patient Participation Groups (PPGs) here. By surveying patients, PPGs can be incredibly effective in identifying persistent issues within a practice that GPs and staff may not be aware of. The survey results might reveal, for example, that a common gripe is the inability to see their doctor on a designated day. With many doctors having portfolio careers these days, this is not always possible. But most patients, in my experience at least, don’t always know or understand this. Therefore, PPG surveys are a highly effective method of highlighting underlying issues like this, and best of all, they might also serve to prevent a flurry of complaints before they happen.
Best practice: what does it look like?
There are a number of ways in which practices can demonstrate best practice. Firstly, while complaints require an individual response, practice managers can gain invaluable insight by studying themes and trends. From there, they can create templates, which show how complaints are being handled. The more information a practice publishes on its website, the more engaged patients will feel, making it less likely that they will make a complaint.
Secondly, practice managers should acknowledge that not everyone who wishes to make a complaint will do so. However, that doesn’t mean to say they are happy with the service that they have received. A good way of capturing as much feedback as possible, therefore, is to ask open questions that focus on the positive, such as ‘How can we make things better?’
Finally, GPs and practice managers need to recognise that complaints handling can be extremely challenging and emotionally draining at times. Frontline workers, therefore, need to have access to the latest complaints handling resources. Given that the language in some of the guidance is sometimes highly complex, having access to a compliance and content management system like QCS, coupled with a collaborative culture of compliance, can pay dividends.
For more insight into complaints best practice, why not tune into the latest CQC podcast by following this link:
To find out how you can join QCS, contact our compliance advisors on 0333-405-3333 or email [email protected].
 Medical Defence Union. Members reporting hundreds of patient complaints during lockdown. 19 June 2020
 Medical Defence Union. MDU reveals over 2,500 complaints made against doctors during pandemic, as GMC report published. 27 November 2020 https://www.politics.co.uk/opinion-former/2020/11/27/mdu-reveals-over-2500-complaints-made-against-doctors-during-pandemic-as-gmc-report-published/
Category => CQC