POLICY TITLE :
This document is set out according to the following sections : Policy Procedure Quality and Risk Management Responsibilities Attachments
Consumer Complaints Policy and Procedure
POLICY
Introduction and Philosophy
Current, past and future users of the Practice X have a right to have their concerns about service delivery and their care and treatment heard and addressed. They also have a right to receive information about progress and improvements in service delivery if they are concerned about current inadequacies. The consumer complaints process is an appropriate avenue for encouraging patients/clients and their friends and relatives to express their concerns and to offer views about different aspects of our service delivery. In this way the consumer complaints process contributes to quality and risk management throughout the hospital. Fundamental to the consideration and resolution of consumer complaints is the principle that complaints, whenever possible, should be resolved at the point at which they originate. All complaints are to be received and handled with dignity in a spirit of helpful co-operation with the complainant to ensure that the complainant feels they have received a fair hearing and that their complaint was properly considered and any remedial action taken as soon as practicable. Attachment 1 provides further guidelines on how to respond positively to complaints. This document sets out the policy and procedure for the investigation and satisfactory resolution of consumer complaints. It is consistent with the Medicare Agreement, the Charter for State Public Health System Consumers, and the Practice X Consumer Rights and Responsibilities Policy.
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Definitions
Consumer A consumer is a direct or indirect user of the WCH. This could be a patient or client, family member, or visitor. Complaint A complaint is an expression of dissatisfaction or concern by or on behalf of an individual consumer or group of consumers regarding care and treatment, administrative practices, or any other aspect of service. Incident An incident is any event which did harm or could have harmed a consumer.
Categories of Complaint
There are several categories of complaint: Verbal complaints (minor and major) Written complaints (all classed as major) Serious notifiable complaints These categories are shown in Figure 1. Figure 1 - Categories of Complaint Minor Can be immediately resolved by staff member Major Cannot be resolved immediately Serious Notifiable Allegations of assault or abuse
Verbal
Written
Any written form of expression of dissatisfaction with care and services
Allegations of assault or abuse
Verbal Complaints (Minor) These complaints are verbal expressions of concern or dissatisfaction which are minor in nature and can be dealt with courteously and immediately to the consumer's satisfaction. If a consumer states they wish to take the matter further, then the procedure for making a major verbal or written complaint should be followed, even though staff may consider the complaint to be of minor importance.
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Verbal Complaints (Major) A major verbal complaint is one which involves matters that cannot be resolved immediately. These complaints are usually major departures, or perceived as major departures by the consumer, from the standards of care expected by the community and accepted professional and ethical procedures. Written Complaints A written complaint is any expression of concern or dissatisfaction that a consumer or other person makes in writing to the Hospital. Written complaints are usually letters, but may also be notes, addendums to patients surveys, on suggestion forms, etc. Serious Notifiable Complaints These complaints may be received verbally or in writing, and involve allegations of assault and abuse. Statutory reporting requirements must be followed in these instances.
Eligibility to Lodge a Complaint
Anyone can lodge a complaint with the hospital - patients/clients, their friends or relatives, carer, support person, health professional, legal professional, service provider, and/or other concerned individual, agency or group.
Categories of Complaint Outside Consumer Complaints Policy and Procedures
Incidents An incident, such as is required to be reported in an incident report, should continue to be reported this way. A consumer complaint and an incident are to be treated as separate matters, although in some instances they might relate to the same matter. Where an incident, such as is required to be reported on an Incident Report, is accompanied by a complaint, then a Consumer Complaint Report should also be completed. Employee Grievances Employee grievances are not dealt with under these guidelines.
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State Ombudsman
Consumers have the right to take their complaint to the Consumer Health Complaints Unit of the State Ombudsman‟s office. To this end, department, units and wards are to ensure that the following SAHC brochures are available in their area, and provided to consumers upon request, or when a complaint arises : “Your Rights and Responsibilities. A Charter for South Australian Public Health System Consumers” “Do you have a complaint that needs a check up? State Ombudsman Consumer Health Complaints”
Staff Rights
In accordance with the „Code of Conduct for public employees‟, staff have certain rights, including the right to appropriate feedback and communication on work performance, fair and consistent treatment, and reasonable avenues of redress. Persons investigating complaints, in particular those where staff are cited, are to ensure that staff rights are respected throughout the process.
PROCEDURE
The procedures for dealing with and responding to complaints are explained in the following sections, and shown in the flowcharts attached to this document. Verbal Complaints (Minor) Complainants should be encouraged to voice their concerns or complaint at the point of service as soon as they feel unhappy. This allows staff to help resolve the matter with a complainant to the satisfaction of everyone at the time. Where a solution is possible immediately, the staff member should endeavour to resolve the matter without delay. Verbal complaints may be received face-to-face or over the telephone. Guidelines on how to respond to verbal complaints are included at Attachment 1. All verbal or telephone complaints should be resolved at the source immediately or with a return phone call within the hour if possible. However, staff should ensure that patient confidentiality is maintained when discussing clinical matters over the telephone. Staff are encouraged to make a written record of minor complaints and their outcome using the Consumer Complaint Report (Attachment 2) and send these through their line management to the Risk Manager. Attachment 3 shows the process flow for dealing with minor verbal complaints.
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Verbal Complaints (Major) Guidelines on how to respond to a verbal complaint are included at Attachment 1. When a verbal or telephone complaint is received by a staff member and cannot be resolved immediately, or when the complainant states that they wish to take the matter further, the person receiving the complaint is to write down the details in full, and refer the complaint to the senior staff member present, their department/unit head or divisional chief. The Consumer Complaint Report (Attachment 2) is to be used for this purpose. Verbal complaints received in administration or by nursing/medical support services are to be similarly recorded, with copies sent to the relevant division for action and the Risk Manager for registration. The department/unit head or divisional chief is to resolve the complaint with the involvement of relevant staff, and respond verbally and in writing, as appropriate. He or she should inform the Risk Manager immediately if there is any potential for litigation arising from the complaint. If the department/unit head or chief has difficulty resolving the matter, assistance should be sought from their chief, Executive Director, or the Risk Manager. A written record of major verbal and telephone complaints and their outcome is to be made using the Consumer Complaint Report and a copy sent to the Risk Manager. The Risk Manager will register all reported verbal and telephone complaints in the central complaints database. The process flowchart for dealing with major verbal complaints is shown at Attachment 4. Written Complaints Complainants should be encouraged and assisted by staff to make their complaints in writing. If a complainant has difficulty putting the complaint in writing, a member of staff should assist by writing down the dictation of the complainant. Appropriate assistance should be provided where required to people with specific cultural or language needs. Written complaints are to be investigated within the appropriate Division. Divisional chiefs / department heads are to ensure that staff named in complaints are informed and involved in the process. For data collection purposes, a Consumer Complaint Report (Attachment 2) should be raised to accompany a written complaint, and a copy sent to the Risk Manager upon finalisation of the complaint. The Risk Manager should be informed immediately of any complaint that has the potential for litigation. Complaints received by executive administration or nursing and medical support services are to be referred to the Risk Manager, who will assess and register it, and to the relevant division for acknowledgment, investigation and a response. Copies may also be sent to others as required, eg, Executive Directors.
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The Risk Manager is available to provide assistance with investigation or information, or with a written response if required, before it is sent to the person lodging the complaint. The process for dealing with written complaints is shown at Attachment 5. Serious Notifiable Complaints The Risk Manager should be informed of any complaints which involves allegations of assault or abuse. In addition, statutory reporting requirements must be followed. Further information may be obtained from the Risk Manager, or Child Protection Service. Written Responses In the case of written and major verbal complaints, a letter of acknowledgment must be sent by the Division to the person making the complaint within 2 days of its receipt within the Division. A letter of acknowledgment will confirm receipt of the complaint and provide details as to the name of the person handling the complaint, a contact number, and some expectation of the resolution date. All written complaints should receive a detailed written response within 2 weeks of receipt of original complaint. Every effort should be made to achieve a final resolution and written response within 28 days. All written responses are to be signed by either the Chief Executive Officer, an Executive Director, a Divisional Chief, a department/unit head, or the senior officer responsible for the area in which the complaint arose, whoever is the most appropriate. A copy of all major verbal and written complaints, their final response, and information about the outcome and improvements initiated are to be sent to the Risk Manager for registration. Referral of Complaints If a complainant is not satisfied with the hospital's response to their complaint they must be referred to the appropriate Executive Director, or where all avenues have been exhausted, to the Risk Manager. The Executive Director or Risk Manager may seek to discuss the matter further with the complainant to explore other options for resolution, or refer the matter to other persons, as appropriate. Evaluation of Complainant's Satisfaction Finalised complaints will be evaluated in order to ensure that the complainant is satisfied with both the outcome of their complaint, and the manner in which their complaint was handled. This will be done by the Quality Manager, who will also provide feedback to staff involved in responding to the complaint.
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QUALITY AND RISK MANAGEMENT
Complaints are an important source of feedback about care and services, and as such can lead to quality improvement. They may also serve to identify potentially unsafe practice, and can therefore contribute to risk management activities. While complainants may sometimes name individuals, complaints should nonetheless be treated as opportunities for improving systems of care, rather than as a search for 'bad apples'. Persons who investigate and respond to complaints are encouraged to initiate system improvements, wherever possible, and to document the outcomes. The Consumer Complaint Report should be used for this purpose. The Quality Manager is available to assist with this process. Aggregated data about complaints can be a useful source of information to guide future improvement strategies. To this end, the Quality Manager will provide regular complaint reports to management.
RESPONSIBILITIES
Risk Manager
The Risk Manager will: Maintain a register of complaints. Register all formal complaints in the central complaints register and forward documentation of all major complaints for investigation to appropriate persons. Assist in the investigation and mediation of patient complaints where required. Determine if their is a potential for litigation, and if so make appropriate notifications.
Quality Manager
The Quality Manager will : Assist in familiarising staff with the investigation, recording and possible resolution of patient complaints. Report ongoing cases to management or other staff, as required. The Quality Manager may suggest that remedial action be taken where indicated. Evaluate complainants' satisfaction, and provide feedback to staff involved in investigating and responding to a complaint. In liaison with the Risk Manager, ensure a quarterly report on complaints received, apparent trends, and recommended improvement/preventive strategies is forwarded to the Chief Executive Officer and the Quality Council (Chiefs Operational Group). Assist staff to implement system improvements as a result of complaints received.
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Divisional Chiefs and Department/Unit Heads
Divisional Chiefs and Departmental/Unit Heads will : Ensure that complaints are investigated and resolved quickly and sensitively, with due consideration given to both consumer and staff needs. Ensure that staff rights are protected by informing and involving them, particularly where staff are named in complaints. Ensure documentation is completed in a timely manner, including the Consumer Complaint Report and letters to the complainant, and that copies are sent to the Risk Manager. Ensure the Risk Manager is informed immediately of any complaints that have the potential for litigation. Review local records of complaint and resolution on a regular basis. Initiate improvement and/or preventive strategies to systems of care and service.
Executive Management, COG and the Board of Directors
Executive Management, COG and the Board will : Act upon reports and recommendations received from the Quality Manager and Risk Manager to ensure that complaints contribute to the overall improvement in quality of care. Initiate improvement and/or preventive strategies in response to trends in complaint reporting.
ATTACHMENTS
1. 2. 3. 4. 5. Complaints Handling Procedures - extract from Australian Standard 4269.1995 Consumer Complaint Report Process Flowchart - Verbal Complaints (Minor) Process Flowchart - Verbal Complaints (Major) Process Flowchart - Written Complaints
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AS 4269 - 1995
SECTION 4 COMPLAINT HANDLING PROCEDURES
1 General These guidelines are for processing written or oral complaints, including telephoned complaints.
2
Processing Oral Complaints The steps are : a) Identify yourself, listen, record details and determine what the complainant wants. Confirm the details received. Empathise with the complainant in a courteous manner. Explain the courses of action available. Do not attempt to lay blame or be defensive. Resolve the complaint if possible or commit to doing something immediately, irrespective of who will ultimately handle the complaint. Ensure that the consumer is informed the complaint is receiving attention, without creating false expectations. Check whether the consumer is satisfied with the proposed action and, if not, advise alternative courses of action. Provide acknowledgment eg. a thank you letter, a telephone call. Follow up as appropriate and monitor to ensure the consumer remains satisfied as well as receives feedback.
b) c) d) e) f)
g)
h)
i) j)
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Processing Written Complaints In principle, this is the same as processing oral complaints, however, in this situation, a response should be given promptly, in writing. Minimising Disputes Handling a difficult consumer and the consumer‟s complaint efficiently needs patience and skill to avoid an initial „negative‟ situation becoming even more negative and degenerating into a dispute.
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The two main elements in a complaint situation that need to be effectively handled to minimise the likelihood of dispute are : a) Dealing with the complainant‟s feelings : i) ii) Listen - this is the first step in reducing the tension Acknowledge the complainant’s feelings - denying that the complainant is, or has the right to be upset may antagonise the complainant. Empathise - relieves communication. tension and so opens channels of
iii)
iv) b)
Do not offer excuses, or argue with the complainant.
Dealing with the specifics of the complaint : i) Ask the necessary questions in a polite and even-handed manner to obtain the most detailed response. Agree on a solution - without appearing to dictate terms in order to avoid the likelihood of re-raising tension. Set a timetable. Take action on the agreed solution.
ii)
iii) iv)
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Attachment 3
PRACTICE X
CONSUMER COMPLAINTS PROCESS FLOWCHART
Verbal / Telephone Complaints (Minor)
Consumer makes a verbal/telephone complaint
Can the staff member receiving the complaint resolve it?
Go to process for major Verbal/Telephone complaints
The complaint is resolved
Staff Member completes Consumer Complaint Report
This step is encouraged, but optional.
Staff member sends copy of Consumer Complaint Report through their Line Management to Risk Manager for registration
Quality Manager evaluates complainant satisfaction
Feedback provided to person / unit Regular report produced for management
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Attachment 4 PRACTICE X
CONSUMER COMPLAINTS PROCESS FLOWCHART
Verbal / Telephone Complaints (Major)
Consumer makes a verbal/telephone complaint which cannot be resolved immediately Consumer states he/she wishes to take the telephone complaint further Department/Uni t Head or Divisional Chief completes Consumer Complaint Report
Or
Staff member completes Consumer Complaint Report and sends this to the senior staff member available, department/unit head or divisional chief
Administration/s upport service staff complete Consumer Complaint Report and sends this to the Risk Manager for registration and relevant division for resolution Department/Unit Head investigates and resolves complaint
Risk Manager is informed if there is a potential for litigation to arise.
Department/Unit Head, Divisional Chief responds to consumer and, if appropriate, documents 0utcome on Consumer Complaint Report
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