A Review of Complaints Handling, Performance and Learning...organisations providing data in both...

0 Chair: Dr Amr Zeineldine Ch

The best possible health outcomes for Southwark people

A Review of Complaints Handling,

Performance and Learning

Omar Al-Ramadhani

Planning and Performance Manager, Southwark CCG

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1 Chair: Dr Amr Zeineldine Chief Officer: Andrew Bland


Table of Contents

1. Aim of the Review .......................................................................................................................... 2

1.1. Introduction ................................................................................................................................ 2

1.2. National standards ................................................................................................................... 2

1.3 National context ......................................................................................................................... 3

2. Total Annual Complaints Received .......................................................................................... 5

2.1 Complaints by directorate ......................................................................................................... 5

2.2 Complaints by subject ............................................................................................................... 7

2.3 Other complaints themes.......................................................................................................... 9

3. Unresolved, Escalated and Serious Complaints ................................................................. 11

3.1 Complaints referred to the Public Health Service Ombudsman ....................................... 11

3.2 Risk grading .............................................................................................................................. 12

4. Response Rates ........................................................................................................................... 14

4.1 Guy’s and St. Thomas’ ........................................................................................................... 14

4.2 King’s College Hospital ........................................................................................................... 15

4.3 South London and Maudsley ................................................................................................. 16

5. Complaints Process .................................................................................................................... 17

6. Training and Good Practice ...................................................................................................... 18

7. Summary of Findings ................................................................................................................. 19

8. Initial Recommendations ........................................................................................................... 20

Appendices ........................................................................................................................................ 21

Appendix A – GST internal complaints process ............................................................................ 22

Appendix B – GST improvement plans – provided in July 2013 ................................................. 23

Appendix C – KCH improvement plans – provided in August 2013 ........................................... 24

Appendix D – Recommendations from the Francis Report ......................................................... 26

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1. Aim of the Review This review presents a detailed summary of provider complaints across Southwark’s commissioned portfolio (King’s College Hospital (KCH), Guy’s and St Thomas’ acute and community services (GST), South London and Maudsley (SLaM)). To provide greater clarity on the issue of complaints, this review has gathered additional data and information to that already made available to Southwark CCG via provider quality reports. The sources of information for this review were: Quarterly and annual complaints reports (patient experience reports where applicable) Provider presentations at CQRG meetings (KCH and GST) Meetings and discussions with provider complaints managers. The review concludes by making recommendations and highlighting areas that require further actions.

1.1. Introduction

The Francis report highlighted the importance of maintaining an effective complaints handling system and how it can be a perceptive measure of the quality of care at an organisation:

‘Complaints, their source, their handling and their outcome provide an insight into the effectiveness of an organisation’s ability to uphold both the fundamental standards and the culture of caring.’1

In response to the Francis report, the Prime Minister has asked Ann Clwyd MP and the Chief Executive of South Tees Hospitals NHS Foundation Trust, Tricia Hart, to conduct a review into complaints handling. It is hoped that this deep-dive review will add a local perspective to the findings from the national review which are due to be published in autumn 2013. A list of recommendations made in the Francis report relating to complaints are listed in Appendix D.

1.2. National standards

The NHS Constitution sets out a number of patient rights concerning complaints and redress:

The right to have any complaint you make about NHS services acknowledged within

three working days and to have it properly investigated.

The right to discuss the manner in which the complaint is to be handled, and to know the

period within which the investigation is likely to be completed and the response sent.

The right to be kept informed of progress and to know the outcome of any investigation

into your complaint, including an explanation of the conclusions and confirmation that

any action needed in consequence of the complaint has been taken or is proposed to be

taken. 1 Mid Staffordshire NHS Foundation Trust 2013. Report of the Mid Staffordshire NHS Foundation Trust Public Inquiry - Executive summary London: Crown Copyright

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The right to take your complaint to the independent Parliamentary and Health Service

Ombudsman or Local Government Ombudsman, if you are not satisfied with the way

your complaint has been dealt with by the NHS.

The right to make a claim for judicial review if you think you have been directly affected

by an unlawful act or decision of an NHS body or local authority.

The right to compensation where you have been harmed by negligent treatment.2

The NHS Constitution also makes the following pledges which the NHS commits to achieve:

To ensure that you are treated with courtesy and you receive appropriate support

throughout the handling of a complaint; and that the fact that you have complained will

not adversely affect your future treatment.

To ensure that when mistakes happen or if you are harmed while receiving health care

you receive an appropriate explanation and apology, delivered with sensitivity and

recognition of the trauma you have experienced, and know that lessons will be learned to

help avoid a similar incident occurring again.

To ensure that the organisation learns lessons from complaints and claims and uses

these to improve NHS services.2

Some of the rights set out in the NHS Constitution are difficult to measure and are open to interpretation.

1.3 National context

The number of reported written complaints about Hospital and Community Health Services (HCHS) has increased by 8.3% from 99,057 in 2010-11 to 107,259 in 2011-12. For organisations providing data in both years the total number of HCHS complaints has decreased by 2.3% from 98,232 to 95,989 in 2011-123.

The Health Service Ombudsman’s annual review of complaints handling by the NHS in England in 2011-12 found that there had also been an 8% increase in the number of complaints it received from the previous year, and reported a 50% rise in the number of complaints in which patients felt that the NHS had inadequately acknowledged mistakes in care4.

2 Department of Health, 2013. NHS Constitution. London. Department of Health 3 The Health and Social Care Information Centre, 2012. Data on Written Complaints in the NHS ‐ 2011‐12. The Health and Social Care Information Centre. 4 Parliamentary and Health Service Ombudsman (2012). The Ombudsman’s review of complaint handling by the NHS in England 2011‐12. London: Parliamentary and Health Service Ombudsman

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Table 1.1: Total number of all Hospital and Community Health Services complaints from

2007-2012.

Year 2007-08 2008-09 2009-10 2010-11 2011-12

NHS Complaints 87,080 89,139 101,077 99,057 107,259

The Ombudsman's report says that common pitfalls in how the NHS handles complaints

include:

Equivocal language and sitting on the fence over care decisions that had been made

Getting key facts wrong

Using technical language without appropriate explanations

False or insincere apologies.

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2. Total Annual Complaints Received

The total number of new formal complaints has increased at GST and KCH by 8% in 2012/13 from the number of complaints received in 2011/12. The total number of new formal complaints at SLaM has remained similar since 2010/2011.

Table 2.1: Total number of new formal complaints received per trust.

2010/11 2011/12 2012/13

GST 802 743 801

KCH 570 589 638

SLaM ~550 555 551

2.1 Complaints by directorate

The most complained about directorates at the acute Trusts are acute medicine, women’s services and surgery which also have the highest patient throughputs. The most complained about CAG at SLaM is psychosis which also has the highest patient throughput.

Table 2.2: The most complained about directorates

Top 3 most complained about directorates

GST Acute Medicine (94) Women’s Services (94) Surgery (83)

KCH TEAM (137) Surgery (89) Women’s Services (88)

SLaM (CAGs) Psychosis (40%) Mood, Anxiety & Personality Disorder (19%)

Behavioural & Development Psychiatry (15%)

TEAM = Trauma, Emergency and Acute Medicine.

Note: Caution should be taken in making conclusions about a Trust’s complaints performance based solely on the number of reported written complaints, particularly when benchmarking performance against other Trusts. An organisation that welcomes patient feedback; publicises its willingness to learn from complaints and is generally open and non-defensive may attract more complaints. Benchmarking Trusts is also problematic when comparing the raw number of complaints as this does not reflect differences in patient throughput.

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2.1.1 Trauma, Emergency and Acute Medicine

Trauma, acute medicine and surgery are amongst the most complained about directorates at the acute trusts, a trend which is echoed in national statistics. GST and KCH identified that the issues complained about in these directorates cover a range of concerns which can include:

Patients being unhappy with clinical advice Concerns about clinical treatment Poor outcomes Inadequate discharge planning

It is difficult to identify themes in these broad directorates as most complaints are multi-faceted and complex, however below are examples of complaints and improvement plans at GST and KCH.

At KCH the number of complaints in TEAM have increased by 15% from 2011/12. Complaints often relate to discharge arrangements and planning, medical care and availability of staff.

The emergency and medicine teams hold monthly meetings along with risk managers where complaints are reviewed, themes identified and remedial actions planned and monitored.

There have been improvements in discharge planning which has resulted in fewer complaints. The Trust has implemented earlier discharge planning which involves using a discharge checklist, planning with the patient’s family early on and improving the booking of transport.

EXAMPLE: Failure to identify fractures in A&E and Urgent Care Centre - GST There have been a number of complaints over the time taken to identify fractures following x-ray. There was also a recent serious incident investigation into a system failure which resulted in a backlog of abnormal x-rays not being reviewed by clinicians in A&E which led to the potential for missed diagnosis. Improvement plan: As a result a robust action plan has been implemented to prevent this from recurring.

EXAMPLE: Medication and dosage error - KCH A family member complained that their mother had received the medication of another patient over a number of unspecified days while being an inpatient and had this not been pointed out by the family member, the clinical team would have been unaware. At the time this was brought to the attention of the ward staff, medication for another patient was found in the patient’s own drug locker (POD) which had not been removed at the time of the previous patient’s discharge in line with Trust Policy. Improvement plan: The Trust apologised and investigated the event as an adverse incident. The Matron has used the complaint to reinforce the importance of emptying the POD, and this situation is being monitored.

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2.1.2 Women’s Services

At KCH the rate of complaints in the women’s service has increased by 26% in 2012/13 compared to 2011/12 and there has been a 50% increase in complaints relating to gynaecology. More than 50% of complaints in women’s services relate to maternity care where complaints were made regarding inadequate management of pain during labour and staff being uncaring and unhelpful. The Trust also feels that women’s services is more likely to receive a relatively high number of complaints due to the demographic of its patients. The Trust believes that a generally younger, more educated cohort of patients is more likely to be inclined to write a formal complaint. The Trust provides general customer care training, however complaints regarding staff attitude are usually addressed through peer support and performance management. The complaints team keeps a record of staff who are the subject of complaints and notify respective managers. At GST, women’s services are also a common source of complaints particularly regarding post natal services. Complaints relate to how women feel they are being treated by midwives; generally not receiving enough help or support particularly relating to breast feeding. GST do provide a mid-wife led breast feeding drop-in service and report that 91% of women who give birth at the Trust start breastfeeding.

2.2 Complaints by subject

The most complained about subjects at the providers were clinical treatment/care, communication and staff attitude/behaviour.

2.2.1 Clinical treatment/care

It is difficult to theme complaints in this area as complaints are often multi-faceted and involve other divisions, however some complaints relate to discharge arrangements and planning, medical care and availability of staff. The below are examples of complaints at KCH and SLaM.

EXAMPLE: Women’s services - KCH

The Nightingale Birth Unit at KCH had the highest number of complaints in 2012/13 with 61% of the complaints relating to the care provided by the midwifery staff. While in most cases the clinical care was found to be appropriate, women reported feeling disappointed with their overall experience which the Trust say reflected the high activity within the ward throughout the year. Other concerns related to the interaction between midwife and patient which was perceived as unhelpful and unsympathetic towards pain.

Improvement plan: Improvements in staff attitude are implemented through peer/manager support and performance management. The Trust also provides customer care training.

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2.2.2 Communication

The GST complaints team feel that most complaints stem from poor communication or inadequate information being conveyed to patients. Patients can sometimes be unaware of ward rules, meal times and care arrangements post discharge.

Improvement plans:

Improving the quality of literature with a particular focus on information leaflets. A number of complaints have been related to patients not being aware of ward procedures so leaflets are being produced to provide this information on admission.

Providing ward welcome packs which include information like ‘who to go to’, ward procedures, meal times and accessories like toiletries, ear plugs and non-slip socks.

Improving telephony services by providing call centre training to staff and training staff to by recording and learning from calls. This has been a particular focus in dental care.

Producing information packs upon discharge for managing care.

EXAMPLE: Neurology wards - KCH

Three neurology wards received a high number of complaints and PALS contacts. The Trust has struggled to recruit to neurology wards and has faced a number of staffing issues. The wards have had to discipline a number of staff which has resulted in staff being sacked. Neurology has had long standing issues and the Trust were keen to highlight that performance was improving and that feedback through HRWD has been steadily improving over the last 3 years. Currently recruitment is still a challenge within neurology with the Trust claiming that the area is perceived by the workforce to be unappealing and particularly challenging.

EXAMPLE: Bed management - SLaM

Complaints regarding bed management have been a particular issue due to ongoing bed pressures. This is an issue that is affecting patients from all sites and Southwark patients in the Ruskin ward. On occasion patients go on leave and return to find that they have been transferred to another bed which can sometimes be on a different ward. Another issue some patients have faced is repeatedly being moved while staying at the same site which is distressing for the patient and for the patient’s family who lose track of where the patient has been moved.

Improvement plans: The Trust has made understanding the scale of the issue and making improvements a priority. The Trust-wide complaints committee have asked for an audit to be carried out to understand the scale of the problem which will be reviewed by the complaints committee and subsequently be taken to the bed management committee to resolve. The issue will be monitored on an ongoing basis.

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2.2.3 Staff attitude and behaviour

Staff attitude and behaviour is a common source of complaints at SLaM. The Trust explained that patients complain about the way they are restrained by staff and how their rights and diagnosis are communicated. Patients also complained that staff were sometimes uncaring and did not listen to their concerns.

Improvement plans:

The Trust highlighted that it takes such complaints seriously and if upheld may lead to staff being performance managed, particularly if they are complained about more than once. The Trust has in the past implemented trust-wide customer service training and is considering rolling this out again, mainly for reception and customer service staff.

2.3 Other complaints themes

Guy’s and St Thomas’ Access to medical records The department receives a variety of complaints some of which refer to requests to see their patient records. From the complainants perspective there does not appear to be a consistent message from members of staff about how to access records. Improvement plan: Work is on-going to train staff on the ‘access to medical records’ process. Patient centred care The Trust wanted to improve the patient experience for patients being admitted for surgery. Improvement plan: The surgical admissions team are implementing staggered admission times with some surgical teams, with plans to roll this out for all surgical specialities in the future. This should make the environment less busy and allow for more patient centred care. Additional communication skills training has been arranged for their staff.

EXAMPLE: Communication in outpatients - KCH

Patients complain that communication boards do not reflect the actual waiting time in outpatients and that patients are not always kept updated on waiting times.

Improvement plan: A new patient calling system will be installed into Suite 3 of the Golden Jubilee Wing in July 2013. It is expected that this system will have real-time, information as to the difference between the patients’ appointment time and the time that they are called in to see the doctor. It is hoped that this system will give patients a better estimated waiting time. These improvements are part of an outpatient clinic redesign project and the initiatives will be rolled out to all outpatient clinics.

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King’s College Hospital

Liver, Renal and Surgery

The Liver, Renal and Surgery services received the highest rate of outpatient complaints and the second highest rate of inpatient complaints. Complaints in these directorates are often complicated and unique so themes are not easily identified. Commissioners should investigate this further.

Providing dignified care for patients requiring transport

The Trust received complaints regarding the needs of patients requiring transport.

Improvement plans: Volunteers have been recruited from the extensive Volunteer Programme to help support transport staff to give more attention to waiting patients.

South London and Maudsley

Patient property

A number of complaints have been made regarding the safe storage and accessibility of patient property, which has been a particular issue for long stay patients.

Improvement plan: In the wards where this has been a problem, additional storage capacity has been built to store patients belonging’s and staff have been informed to better assist patients in accessing their belongings.

Quality of meals

Patients have complained that the quality of food is sub-standard; portions are too small; the evening meal is served too early and that there isn’t enough choice.

Improvement plan: A working group has been in operation for some time to review concerns regarding the food and has setup a service user group to audit the quality of food. Concerns and feedback have been passed onto Hotel services to make improvements.

Temperature on the psychiatric intensive care units (PICU)

A number of complaints were made regarding the cold temperature on the unit during the winter of 2012/13.

Improvement action: The heating in the wards was found to be faulty and this has now been resolved by estates.

Refer to Appendix B and C for improvement plans provided by GST and KCH respectively.

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3. Unresolved, Escalated and Serious Complaints 3.1 Complaints referred to the Public Health Service Ombudsman Guy’s and St Thomas’ The table below shows the number of complaints that were escalated to the Public Health Service Ombudsman (PHSO) at GST.

Table 3.1: Details of complaints at GST which were escalated to the PHSO.

Detail of contact Q1 12/13 Q2 12/13 Q3 12/13 Q4 12/13 Total

New Contact

Trust agreed to further local resolution

4 1 0 1 6

Files requested for assessment

9 13 14 6 42

On-going/ Closed

Closed after assessment

6 10 8 4 28

PHSO investigation initiated

1 3 2 0 6

Outcome of PHSO investigation received

0 0 0 1 1


In 2012/13 the Trust was informed of 18 complaints which had progressed to the Ombudsman for independent review (refer to Table 3.2). This is a decrease on the numbers referred in the preceding two years (2011/12 – 21; 2010/11 – 33).

Table 3.2: The number of PHSO referrals for complaints received at KCH.

Division Number of PHSO

referrals % of complaints received

by division

Ambulatory & Local Networks 2 3%

Liver, Renal & Surgery 3 2%

Networked services 5 5%

TEAM 3 4%

Women’s & Children’s 5 2%

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The Trust has received two requests for Independent Review by the PHSO relating to complaints received by the Trust during 2012/13. This accounts for less than 1% of complainants asking for a further review of their complaint under the second stage of the Complaints procedure. One complaint related to a carer wanting full access to their deceased mother’s records and another related to a client’s concerns about being transferred from River House to a prison.

3.2 Risk grading

Guy’s and St Thomas’

Complaints received are risk assessed and graded by the complaints department using the Trust incident grading system. This assessment comprises scoring of the consequence of the patient/complainant multiplied by the likelihood of recurrence at the same consequence.

Where necessary the complaints department provide advice and support to the directorate throughout the local resolution process. There were no red-graded complaints across the Trust in 2012/13. There were 129 (16%) orange graded complaints in 2012/13 compared to 174 (23%) in 2011/125.


All complaints are graded for severity by the complaints team using the Department of Health’s grading guide. All complaints that indicate an adverse incident are flagged as a high priority for the investigating team and the Risk Management team are notified.

The table below illustrates the severity of complaints received in 2012/13. Two cases were considered serious and also investigated as serious incidents with root cause analysis.

Table 3.3: Grading of complaints at KCH

Grading Number of complaints & %

Low – Unsatisfactory service or experience 293 (46%)

Medium – Service or experience below reasonable expectations

239 (37%)

High – Significant issues regarding standards and quality of care

104 (16%)

Serious – Serious failure causing serious harm

2 (1%)

5 Note: Red - indicates a catastrophic impact of an incident (e.g. an ‘incident leading to death’ and ‘gross failure to

meet national standards’). Orange - minor injury, formal complaint (stage 1), single failure to meet internal

standard. Green - minimal injury, informal complaint, small loss/risk of claim.

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Around nine per cent of complaints were high severity and under one per cent serious severity. High severity complaints refer to complaints that relate to significant issues regarding standards, quality of care and safeguarding or denial of rights and serious complaints would result in high-level investigation.

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The Trust does inform patients if responses are delayed and the complaints department is trying to support divisions to increase their response rates. Performance is being monitored through the Performance Committee and Divisional performance meetings.

4.3 South London and Maudsley

Note: SLaM do not report response rates in their annual complaints report and only monitor rates internally. SLaM currently responds to 50% of complaints within 25 working days which is the internal response target.

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5. Complaints Process

After speaking to complaints managers at all three Trusts it was clear that all the Trusts had a detailed and thorough complaints handling process. All the Trusts use a sophisticated complaints management software (Datix) which can store the details of every complaint that comes into the trust. The software can store written copies of all correspondence between the complainant and the trust, carry out analysis of complaints themes, record improvement plans and if upgraded can sort complaints by commissioner (SLaM’s system has this ability).

There were many similarities between the Trusts’ complaints processes including:

Complaint acknowledgement time of three working days (nationally mandated)

Importance placed on speaking to or meeting with complainants (particularly at SLaM)

A target response time of 25 working days

A number of avenues to accept complaints

Executive review and sign-off.

Refer to Appendix A for an example process provided by GST.

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6. Training and Good Practice

All Trusts provide a good level of complaints training which includes the following:

Staff training programmes and induction training - All trusts offer bespoke complaints training for those investigating and responding to complaints; complaints is also included in induction training.

Written policy and procedures - There are written policies and procedures available at all the trusts which cover complaints investigation and response writing.

Non-executive review - Non-executive reviews of complaints takes place at GST (on a quarterly basis) and SLaM (currently recruiting).

Regular directorate/team meetings - All the trusts have a multi-layered approach to reviewing and monitoring complaints from service teams through to the Governing Body.

Complaints on the agenda at executive meetings - Complaints performance is presented to the Governing Body at regular intervals. Each Trust produces an annual complaints report which summarises performance, complaints themes and the main areas of learning and improvement.

Executive sign-off - All complaints are eventually signed-off by the chief executive which ensures that complaints themes are known to the executive.

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7. Summary of Findings

7.1 Performance and complaints themes

The number of new formal complaints increased by 8% between 2011/12 – 12/13 at both GST and KCH. Complaints at SLaM have remained similar over the same period.

Response times are well below target at all providers with KCH and SLaM meeting their internal response time target of 25 working days in 50% of complaints (target 70%). GST have an average response time of 60 working days. SLaM monitors response times but does not report these externally.

The most complained about directorates at the acute Trusts are trauma, emergency and

acute medicine, women’s services and surgery. The most complained about subjects across the three providers were medical

care/treatment and staff attitude and communication. 16% of complaints at KCH had a high severity grading and 1% had a serious severity. At

GST 16% of complaints were ‘orange rated’ and no ‘red rated’ complaints were identified. 9% of complaints at SLaM were high severity and less than 1% were serious..

7.2 Complaints handling systems

The three providers use the Datix complaints management system to register complaints and to analyse and report complaints data and information.

The three providers have detailed processes for handling complaints which are similar. The three providers try to speak or meet with the complainant upon receiving a

complaint. There is a particular emphasis to do this at SLaM. There is a good level of complaints training available at all three providers including

complaints training at induction, the availability of detailed guidelines and support from complaints teams.

KCH & GST provided complaints handling and patient engagement improvement plans.

7.3 Learning and improvement

The three providers have produced annual complaints reports which examine themes of complaints, lessons learnt and system improvements.

The three providers review complaints performance and improvement plans at executive

level. GST and SLaM have in place or are recruiting a non-executive director to further scrutinise complaints performance.

KCH and GST presented complaints as a substantive item at recent CQRG meetings.

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8. Initial Recommendations

This review has brought together information on complaints across Southwark’s commissioned portfolio. A number of areas were identified that need further investigation, these are listed below: 1. There are a number of complaints in specific service areas at KCH which may need

further investigation by commissioners as part of our quality assurance role:

a) There was a high number of complaints received relating to renal, liver and surgery.

b) There has been a 50% increase in the number of gynaecology complaints.

2. SLaM are not reporting complaints response times to commissioners and response times are not included in the Trust’s annual or quarterly complaints report. Commissioners should monitor response times at SLaM.

3. Response times at GST and KCH remain well below target. Commissioners should request improvement plans and actions to improve performance.

4. Commissioners should request detailed information regarding the most severe complaints. This should include the high and serious severity complaints at KCH, complaints, which are ‘orange-rated’ at GST and the ‘high’ and ‘serious’ rated complaints at SLaM.

5. As lead commissioner, SCCG may wish to review the progress made by KCH in implementing the improvement plans detailed in this review. Commissioners should also follow up SLaM’s progress in resolving bed management issues.

6. Complaints should be covered in more detail at CQRG meetings.

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Appendices

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Appendix B – GST improvement plans – provided in July 2013 Area for improvement Actions Start date Completion date Review

Efficiency and effectiveness by revising the operational application of the policy and procedure

Incoming complaints triaged - where complex, a proposed management plan identified by a senior team member should be in place. Dec 2011 Jan 2012 In place and ongoing

Complaints handling toolkit to be developed to provide guidance and training on: quick fixes holding meetings and associated paperwork keeping complainants updated drafting responses

Apr 2012 July 2012 Currently being revised

Complaints workshop Apr 2012

Ongoing

Overall performance improved – reduction in numbers of complaints requiring further local resolution

Establish regular meetings between COs and directorate leads Jun 2012 Directorates have a lead person for “signing off “ complaints Apr 2012 The complaints manager will review draft responses before they are sent to the Trust secretary / CEO

Mar 2012

Accessibility to complaints information / data / performance information to facilitate improved management, capturing and sharing learning

A key performance matrix will be agreed with the directorates Regular updates on performance and complaint issues to Safe in Our Hands Robust mechanism for capturing and recording actions arising and learning from complaints to be established using Datix as the preferred medium for data capture (when Datix manager in post)

Jan 12

April 12

Mar 13

June 12

Ongoing

Sept 13

Complete Commenced and ongoing In progress

Performance of central complaints department

A revised SOP (flow chart) to be produced for all stages in the process Monitor performance on a weekly basis through 1:1 meetings with complaints manager Programme of regular audits from Datix to establish compliance at all stages of the process

Mar 13

Mar 13

Jun 13

Apr 13

Apr 13

Jul 13

Documents produced and in operation April 13 1:1s in place from Mar 13 Audit designed to be carried out w/c 24/06/13

Board level scrutiny and assurance

Quarterly non–executive director review of randomly selected complaint files (locally resolved) and complaints assessed / investigated by PHSO

Jan 12 Ongoing

In place and ongoing. Feedback to Trust Board of Directors and complaints team

ENC Bvi



Appendix C – KCH improvement plans – provided in August 2013

Objective Actions Completion date Improve Complaints Process

Improve access for patients and the public making a complaint or comment.

Review Trust website to improve access to Complaints/PALS, HRWD and Friends and Family. Ensure current leaflets/posters sign-posting to PALS/Complaints and HRWD are available on wards, in clinics and all public spaces. Merge PALS and Complaints leaflets/posters to provide seamless interface between these services (following the publication of the DH revised NHS complaints procedure).

August 2013 June 2013 - complete As soon as new NHS Complaints Guidance published

Revise the Trust’s complaints procedure to align with revised National guidance on handling complaints

Publish new complaints procedure and roll out Trust wide.

As soon as new NHS Complaints Guidance published

Report names of individual staff whose names appear recurrently in complaints

Devise a reporting template and implement. Provide monthly reporting thereafter.

August 2013

Objective Actions Completion date

Improve Feedback to Patients

Invite complainants to participate in patient feedback events

Include a new paragraph in Chief Executive’s sign off letter inviting participation Involve complainants and complaints more systematically in staff training Invite complainants to King’s in Conversation Listening Events

June 2013 - complete September 2013 June 2013 onwards – in place

You said – we did Publish information on complaints themes and summary outcomes on Trust website

September 2013

ENC Bvi



Objective Actions Completion date

Improve Listening To and Learning From Patient Feedback and Complaints

Get feedback from patients/complainants on their experience in making a complaint.

Develop a feedback questionnaire – roll out questionnaire on ongoing basis. Report results and actions to Divisions and via quarterly patient experience report.

October 2013

Ensure service improvements and actions arising from complaints are followed through and implemented at divisional level, and that learning is shared Trust wide.

Implement a reporting template. Review at Divisional Risk & Governance meetings and confirm that actions/service improvements have been put in place with identified leads and timescales.

Information to inform monthly divisional performance meetings and be presented to Patient Experience Committee to share learning

September 2013

Patient complaints /stories received by the Board.

A Division to present a patient story or complaint and service improvements at each Quality and Governance Committee

July 2013 onwards – in place

NED Champion Identify lead NED to champion and challenge the Trust’s approach to learning from patient experience and feedback.

ASAP

Continue to develop patient video stories to use them as a learning tool

Consider how themes emerging from Video Stories and other forms of patient feedback are aligned to outputs and action planning from the King’s in Conversation event themes.

Ensure successful handover of Video Patient Stories to Public and Patient Involvement team and support staff in their development and use as a training tool. King’s in Conversation Steering Group

From July 2013 October 2013

ENC Bvi



Appendix D – Recommendations from the Francis Report

It is important that greater attention is paid to the narrative contained in complaints data, as well as to the numbers – Providers and Commissioners Methods of registering a complaint should be easy with a number of gateways available, however a uniform process should be followed – Providers Actual or intended litigation should not be a barrier to the processing or investigation of a complaint at any level. The duties of the system to respond to complaints should be regarded as entirely separate from the considerations of litigation – Providers Providers should promote to patients and carers their desire to learn and improve from comments and complaints – Providers Patient feedback which is not in the form of a complaint but which suggests cause for concern should be the subject of investigation and response of the same quality as a formal complaint – Providers The recommendations and standards suggested in the Patients Association’s peer review into complaints at the Mid Staffordshire NHS Foundation Trust should be reviewed and implemented in the NHS – Providers and Commissioners Comments or complaints which describe events amounting to an adverse or serious untoward incident should trigger an investigation – Providers Arms-length independent investigation of a complaint should be initiated by the provider trust where any one of the following apply:

1. A complaint amounts to an allegation of a serious untoward incident; 2. Subject matter involving clinically related issues is not capable of resolution without

an expert clinical opinion; 3. A complaint raises substantive issues of professional misconduct or the performance

of senior managers; 4. A complaint involves issues about the nature and extent of the services

commissioned - Providers Where meetings are held between complainants and trust representatives or investigators as part of the complaints process, advocates and advice should be readily available to all complainants who want those forms of support - Providers A facility should be available to Independent Complaints Advocacy Services advocates and their clients for access to expert advice in complicated cases - Providers Subject to anonymisation, a summary of each upheld complaint relating to patient care, in terms agreed with the complainant, and the trust’s response should be published on its website. In any case where the complainant or, if different, the patient, refuses to agree, or for some other reason publication of an upheld, clinically related complaint is not possible, the summary should be shared confidentially with the Commissioner and the Care Quality Commission – Providers and Commissioners Commissioners should require access to all complaints information as and when complaints are made, and should receive complaints and their outcomes on as near a real-time basis as possible. This means commissioners should be required by the NHS Commissioning Board to undertake the support and oversight role of GPs in this area, and be given the resources to do so – Commissioners

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