1. Policy statement
1.1 Patients using the Onemed independent healthcare service will have access to a complaints procedure in the event they are unhappy with any aspect of the service being provided.
1.2 Patients’ complaints and comments will be listened to and acted upon promptly in accordance with the procedures outlined in this policy.
1.3 This policy outlines the different stages of the complaints procedure and includes arrangements to identify, receive, record, handle and respond to any complaint.
1.4 Onemed will take all reasonable steps to ensure that staff are aware of and comply with this policy and procedure. Team members will receive training in dealing with concerns/complaints.
1.5 Onemed will use lessons learned from feedback to improve the quality of services and include it in supervision and training.
1.6 Onemed acknowledges its legal obligation to address complaints appropriately and effectively, in accordance with regulations such as the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014.
2. Submitting feedback
2.1 Compliments and concerns can be given verbally or in writing to any member of the team or manager.
2.2 Patients are actively encouraged to provide feedback and are also send feedback links or forms.
2.3 Comments made on social media platforms will generally not be considered formal complaints unless they are submitted in writing through the specified methods.
2.4 Compliments received in writing or verbally should be documented and are fed back to relevant team members.
3. Management of concerns
3.1 This involves identifying, prioritising and resolving issues and problems.
3.2 Many concerns stem from a lack of information or understanding and can often be resolved by providing additional information, guidance, or an apology.
3.3 Onemed staff will endeavour to act promptly to resolve a concern straight away or direct the concern to the most appropriate person.
3.4 Upon receipt of the concern, staff will first ensure that the person’s immediate health care needs are met.
3.5 Enquiries and information gathering would be undertaken and thereafter an explanation/advice/apology would be provided to resolve the matter.
3.6 The person raising the concern would be given the opportunity to make a formal complaint as well as discuss their concern further.
3.7 All concerns are recorded and discussed with the team members.
3.8 Onemed strives to provide a swift response and recognises the need for excellent communication.
4. Making a complaint
4.1 Onemed is committed to providing a high-quality healthcare service. However, if any patient is unhappy with any aspect of the healthcare service being provided, they will be invited to make a complaint.
4.2 Complaints must be submitted in writing to the manager via letter or email admin@onemed.co.uk. If unable to submit a complaint in writing, the complainant must raise the complaint with the manager who will record the details of the complaint.
4.3 Staff can either log complaints via email admin@onemed.co.uk
4.4 No patient, or person acting on their behalf, will be discriminated against for making a complaint.
4.5 No person’s care and treatment will be affected in any way if a complaint is made by them or on their behalf.
5. Information given to patients about how to complain
5.1 Written information on the complaint’s procedure will be made available to patients by Onemed.
5.2 Information on how to make a complaint will be available as a separate patient information leaflet.
5.3 Patients will be assured that they will not be discriminated against for making a complaint.
5.4 Information will be available to the public on the Onemed website.
6. Receiving and recording a complaint
6.1 Complaints can be made by a patient, a former patient, or someone acting on a patient’s behalf.
6.2 If the complaint is from a child i.e. someone under 18 years old, the complaint may be made by the child, either parent of the child, the legal guardian, or other adult who is legally responsible for the care of the child.
6.3 All received complaints in writing will be recorded.
6.4 Recorded details will include:
- the date and time the complaint was received
- a description of the complaint
- details of the investigation carried out
- any actions taken, and
- whether or not the complaint was upheld.
6.5 Where a complaint is received anonymously, Onemed will carry out an
investigation as far as they reasonably can, depending on the content of the
complaint.
6.6 Onemed will maintain a complete record of all complaints received and copies
of all related correspondence. These records will be kept separately from
patients’ healthcare records.
7. Handling a complaint
7.1 All complaints received will be treated in the strictest confidence.
7.2 All complaints, written or verbal, will be investigated.
7.3 All complainants will receive a written acknowledgement of their complaint within three (3) working days. The written acknowledgement will include the name and contact details of the person investigating the complaint on behalf of Onemed.
7.4 Onemed will offer to meet with the complainant in order to discuss the manner in which the complaint is to be handled and how the issue/s might be resolved.
At this meeting, the following information will be obtained and/or provided (as far as is reasonably possible):
- How the complainant wishes to be addressed e.g. Miss, Ms, Mr, Mrs or their first name.
- How the person wishes to be kept informed e.g. in writing by letter or email, by telephone, or through an agreed third-party representative or advocate.
- Confirm with the person if they give their consent to access healthcare records (where appropriate) for the purposes of investigating the complaint.
- Confirm if the person has any disabilities that need to be considered during the investigation.
- Advise the person that they can have a representative to support them through the complaints process.
- Ask the person what they are seeking as an outcome to the complaints investigation e.g. an apology, new appointment, reimbursement for costs or loss of personal belongings, or an explanation.
- Agree a plan of action, including when and how the complainant will hear back from Onemed.
7.5 In the event that the complainant does not accept the offer of a meeting as set
out at 7.4 above, Onemed will determine the response period and notify the
complainant in writing of that period.
7.6 Onemed will carry out an investigation of the nature of the complaint and provide a full written response to the complainant within twenty (20) working days of the complaint being received.
7.7 If a full response cannot be given within twenty (20) working days of receiving
the complaint, Onemed will write to the complainant to explain the reason for the delay.
7.8 A full written response will be made within five (5) days of a conclusion and
outcome being reached.
7.9 If a complainant is not satisfied after a complaint has been investigated by
Onemed, they may write to the Leadership Team to request an internal appeal. Onemed will provide further information to the complainant in terms of potentially escalating the complaint to an external body. This will be done on an individual complaint specific basis depending on the nature of the complaint. Onemed will co-operate with any independent review of a complaint that has been escalated.
8. Internal appeal
8.1 Upon receiving an appeal, the Leadership Team will:
- Thoroughly review the specifics of the initial investigation and its conclusion.
- Reach out to the complainant to understand their dissatisfaction with the initial outcome.
- Assign an impartial individual within the organisation if possible to conduct the appeal investigation.
8.2 The Independent Investigator will:
- Assess the initial investigation and its findings.
- Communicate with the complainant if required to discuss their ongoing concerns.
- Conduct additional inquiries if necessary.
- Determine whether to uphold the initial investigation’s outcome.
- Inform the complainant of the appeal’s result and provide pertinent feedback.
- After concluding the appeal, the Independent Investigator will update the incident management system with detailed information about the appeal, including actions taken and the outcome. They will also present their findings to the Leadership Team.
9. External independent review
9.1 If the complainant is not satisfied with the result of the investigation by Onemed, IDF (Independent doctors federation) will be the next level of escalation for complaints:
Stage 1: Inhouse complaints handling as above
Stage 2: Internal appeal as above
Stage 3: The IDF has a three stage Patient Complaints Procedure:
- Stage 3.1 involves the doctor and the practice which is the subject of a complaint.
- Stage 3.2 the IDF Chief Executive Officer considers the complaint with input from the complainant and the doctor who is the subject of the complaint.
- Stage 3.3 Thereafter, unresolved complaints move into Stage 3 with referral to the Independent Sector Complaints Advisory Service (ISCAS), an independent body.
Stage 4: Health Watch
Patients can get independent advice from Healthwatch in Brighton and Hove:
Healthwatch, Community Base, 113 Queens Road, Brighton, BN1 3XG
Telephone 01273 234041
Stage 5: GMC
If the patient wishes to make a complaint about the doctor involved in their care, they can raise concerns with the GMC by calling the Private Healthcare information number on 0161 923 6602
10. Emergency situation:
In cases where concerns relate to the suspected abuse or neglect of children
(up to the age of 18), or vulnerable adults, the local safeguarding authority
should be notified without delay.
In cases where conduct is thought to be/or could be causing serious harm or danger, the police will be contacted immediately.
11. Receiving and handling unreasonable complaints
11.1 Some complaints may be vexatious or malicious and this may involve serial complaints about different matters or persisting with the same complaint when nothing further can be done to assist. In situations where the person making the complaint can become aggressive or unreasonable, Onemed will instigate appropriate actions from the list below and will advise the complainant accordingly:
- Ensure contact is being overseen by an appropriate senior member of Onemed staff who will act as the single point of contact and make it clear to the complainant that other members of staff will be unable to help them.
- Ask that they make contact in only one way, appropriate to their needs e.g. in writing.
- Place a time limit on any contact.
- Restrict the number of calls or meetings during a specified period.
- Ensure that a witness will be involved in each contact.
- Refuse to register repeated complaints about the same issue.
- Do not respond to correspondence regarding a matter that has already been
- closed; only acknowledge it.
- Explain that Onemed will not respond to correspondence that is abusive.
- Make contact through a third person such as an independent advocate (where appropriate).
- When using any of these approaches to manage contact with unreasonable or aggressive people, provide an explanation of what is occurring and why.
- Maintain a detailed dated and timed record of each contact with the complainant during the ongoing relationship.
- Inform the complainant that in extreme circumstances Onemed reserves the right to refer unreasonable or vexatious complainants to solicitors or police if appropriate.
13. Support to staff
13.1 Investigating complaints can be stressful for the team members involved, necessitating support and sensitivity during this period.
13.2 Managers should support their team members by:
- Providing timely guidance on the specific information required from them, allowing sufficient time for team members to seek support from colleagues and/or unions.
- Maintaining good information governance practices, ensuring that details about individuals are treated confidentially and respectfully, and shared only as necessary for the investigation.
- Conducting interviews in a professional and supportive manner.
- Clarifying that the review is part of a learning and safety culture, rather than assigning blame.
- Keeping team members informed about the review’s progress.
13. Care Quality Commission (CQC)
13.1 Onemed is registered with and regulated by the CQC and will produce an annual summary of complaints received.
13.2 A complaints summary will be sent to the Care Quality Commission at any time on request, no later than 28 days from the date of receiving such a request.
13.3 Any complaints summary provided to the Care Quality Commission, will not contain any confidential personal information about complainants.
14. Annual review of complaints
14.1 Onemed will review all complaints on an annual basis in terms of:
- The number of complaints received.
- The issues that these complaints raised in terms of any trends or areas of risk that might need to be addressed.
- Whether complaints have been upheld.
- Improvements or changes to the service that were made.
15. Learning opportunities
15.1 Onemed will review all complaints received with a view to continuous quality
improvement within the independent healthcare service.
15.2 All complaints received will be used as a learning exercise to consider improving aspects of the healthcare service provided to patients.
16. Guidance and further reading
• Being open – communicating patient safety incidents with patients and their carers
(NPSA, 2009).
• Data Protection Act 1998 http://www.legislation.gov.uk/ukpga/1998/29/contents
• Department of Health guidance Complaints in the NHS
• Listening, improving, responding: a guide to better customer care (DH, 2009)
• MIND – complaining about health and social care
http://www.mind.org.uk/information-support/legal-rights/complainingabout-
healthand-social-care/
• NHS Constitution https://www.gov.uk/government/publications/the-nhs-constitution-for-england
• NHS Litigation Authority guidance about complaints
• Mental Capacity Act 2005
• The Health and Social Care Act 2008 (Regulated Activities) Regulations 2014
• Care Act 2014
• Human Rights Act 1998
• Principles of Good Complaint Handling (PHSO, 2009)
chrome-extension://efaidnbmnnnibpcajpcglclefindmkaj/https://www.ombudsman.org.uk/sites/default/files/page/0188-Principles-of-Good-Complaint-Handling-bookletweb.pdf•
Public Interest Disclosure Act 1998
http://www.legislation.gov.uk/ukpga/1998/23/contents