Can I Help You? Guidance for handling and learning from feedback, comments, concerns or complaints about NHS health care services.

Part 2 - Encouraging, handling and learning from feedback, comments and concerns

2.1 Background

2.1.1 Listening to, understanding and acting to improve the patient experience are essential to the delivery of the NHSScotland Quality Strategy person-centred care ambition. Making a commitment to actively engage with patients and to respond to their feedback, comments and concerns whether these are positive or negative, and to deliver care which is person-centred and responsive to their needs are central to delivering a positive experience. Achieving the aim of continuous improvement in the quality of care and services at the point of delivery is reliant on this patient experience information as it allows the service to target and focus improvements appropriately. It is therefore of paramount importance that NHSScotland embeds a culture that actively encourages and welcomes feedback, comments and concerns.

2.1.2 Patients may offer their feedback and comments and often raise issues of concern without wishing to make a complaint. In many instances they may simply wish to provide their views on the service provided and this can be positive and complimentary identifying areas of good practice. Compliments are of considerable value and help the organisation to identify good practice, ensure that good experiences are maintained and share this positive practice throughout the organisation. In some instances individuals may need reassurance, additional information, advice and support or they may wish to talk to someone to share their experiences. Similarly they may wish to advise staff of their observations and make suggestions on how things might be done differently. Potentially, feedback, comments and concerns may identify shortcomings, areas for improvement, good practice and also reflect the level of satisfaction with the service provided and may often include compliments. Not all will require a response.

2.1.3 The Patient Rights (Scotland) Act 2011 and supporting legislation further supports the person-centred approach by requiring that relevant NHS bodies and health service providers ensure feedback etc. is handled promptly and appropriately. It also makes it a requirement for such bodies and providers to demonstrate that feedback, comments and concerns are monitored and used to identify areas of concern, improve performance and identify and share best practice.

2.2 Definition of feedback, comments and concerns

2.2.1 It should be noted that feedback, comments and concerns are not complaints. Complaints must be handled in accordance with the process outlined in Part 3.

2.2.2 It is therefore necessary for staff to be able to distinguish between and identify issues that constitute a complaint using their judgement and discretion and to make the person aware of the options and the distinct process for dealing with complaints. Individuals should have an opportunity to consider whether the issues they are raising should more appropriately be handled as a complaint. Arrangements should be made to ensure that patients, carers, families and visitors are aware of the procedures for providing feedback, comments, concerns and complaints and have access to the relevant supporting patient information leaflets such as "Making a complaint about the NHS"¹⁵ which will help to support them if they want to make a complaint rather than provide feedback.

2.2.3 The patient information leaflets produced by HRIS are available in accessible formats such as large print, audio, CD rom, ethnic minority languages and web based information. This, and from 1 October 2012, the Patient Charter and any other necessary local information which will help improve accessibility should be provided free of charge and in an accessible format to any person who makes a request for it.

2.2.4 Feedback - may be in the form of views expressed orally or in writing as part of a survey, patient questionnaires, through PASS, or initiatives such as patient experience or via stakeholder electronic portals. The feedback may describe the patient or carer's individual experience of using services and may include suggestions on things that could have been done better or identify areas of good practice.

2.2.5 Comments - may be comments, compliments or observations offered orally or in writing by visitors, patient, relatives for example on ward or hospital suggestion cards or through PASS, which reflect how someone felt about the service.

2.2.6 Concerns - may be expressed to staff or through PASS in relation to:

• proposed treatment (for example where someone has been referred to a consultant and is concerned about what this means). Patients may need reassurance or further explanation and information to help them understand why the healthcare provider is suggesting a particular course of action. Patients need to have access to the appropriate advice in order to ensure they are involved in and are equipped to make informed decisions about their healthcare but are often unsure of what they are allowed to ask. Staff should be alert to this and ensure that explanations are given and advice on additional support services is available and accessible to everyone. Staff should familiarise themselves with the additional information available for patients. This might include leaflets such as Its OK to ask.¹⁶ a Scottish Government publication aimed at engaging patients in their healthcare management; or
• any aspect of the service, from timing of appointments to getting to hospital for the proposed treatment or the actual treatment received. It will be particularly important for staff to use their discretion and judgement in supporting service users to decide whether this should be escalated to a complaint. There could be circumstances where the nature of the concern is sufficiently serious to warrant full investigation and if staff members are in any doubt they should seek advice from their line manager or the complaints and feedback officer.

2.3 Staff Support

2.3.1 Feedback, comments and concerns may be given to any member of staff, it is therefore important that all frontline staff are trained to welcome and encourage feedback, comments and concerns from patients, carers and families. It is important that staff see this as an opportunity to improve local services.

2.3.2 Staff should be empowered to respond to feedback, comments and concerns where appropriate and know how to report them through a known and consistent system.

2.3.3 Where staff are unable to deal with the feedback, comments or concerns personally they should provide re-assurance that it has been listened to, understood and outline how this will then be handled. The Complaints Directions place the onus on the relevant NHS body and in turn the health service provider to ensure training and support is available to staff.

2.4 Volunteers

2.4 1It is also important to recognise that there are currently over 5,000 volunteers who participate in volunteering opportunities across NHSScotland and any one of them could potentially be the first point of contact. As a matter of best practice, it is therefore important that they are aware of where to direct patients or the public in these situations.

2.5 Support people to give feedback

2.5.1 There is also responsibility on the relevant NHS body and in turn their health service providers to ensure that its patient feedback, comments, concerns and complaints procedures are well publicised and easily accessible. It is important that patients, carers, families and visitors are aware of how they can provide feedback, make comments and raise concerns as well as the advice and support that is available to help them do so from:

• frontline staff;
• NHS inform;
• complaints staff/patient involvement staff; and
• additional support services such as PASS, communication, interpreting, and advocacy services.

2.6 Handling the feedback, comments and concerns process

2.6.1 Approach

2.6.1.1 The emphasis for all forms of feedback, comments and concerns should be on early and local resolution. Staff should always respond positively and appropriately to anyone who provides feedback, comments or concerns and:

• acknowledge the feedback, comment or concern in an open and honest way demonstrating sensitivity and understanding
• ensure that the patient's immediate health care needs are being met as appropriate before dealing with the issue
• clarify the nature of the feedback, comment or concern using the appropriate method of communication for the situation and the individual whilst demonstrating that the information has been listened to and understood
• establish the expected outcome of the person providing the feedback comment or concern
• discuss the matter of concern with the patient, encouraging them to speak freely; and
• provide an honest and objective response.

2.6.2 Response

2.6.2.1 Reponses may be given verbally or in writing depending on the circumstances of the situation. It may not always be appropriate or necessary to provide a response and indeed in some situations the feedback, comment or concern may have been given anonymously. Staff should make a judgement on appropriate action and on the response required based on their assessment of the situation, the nature of the feedback, comment or concern, and their knowledge of any previous similar situation(s). In some cases it may be appropriate to give an oral response on the spot or, where this is not possible, best practice would be to provide a response within 7 working days or within a timescale agreed with the patient. The response should include an explanation, an apology where appropriate and indicate any improvement that has been identified at this early stage. Any oral or written response about a clinical matter must be agreed with the relevant clinician.

2.6.2.2 Where staff feel unable to respond themselves they should call on the support of an appropriate senior member of staff, or offer the option of discussing the matter with someone not directly involved in the care of the person providing the feedback. The emphasis should be on avoiding any non essential escalation which could cause anxiety to those involved. As before it is essential to provide re-assurance that the feedback, comment or concern has been listened to, understood and outline how this will be handled via escalation.

2.6.2.3 If the person is raising concerns and remains unhappy after receiving an oral or written response, staff should explore the possible further options with them. They should consider whether a meeting with a senior manager might be appropriate or whether the person raising the concern should more appropriately be lodging a complaint. Feedback and Complaints handling staff will be able to assist. Further guidance on the handling of a complaint is contained in Part 3 of this document.

2.6.3 Record keeping

2.6.3.1 In accordance with their monitoring obligations under the Complaints Directions, relevant NHS bodies and their health service providers are to have procedures in place for collecting, recording and disseminating the information, themes and good practice gained from patients' views and experiences to ensure they are used to improve service quality. In the case of relevant NHS bodies these procedures should be applied consistently across the whole service area. Local service managers and health service providers should be encouraged to share this information where appropriate and seek staff feedback and suggestions for further improvement.

2.6.3.2 As a matter of best practice details of the feedback, comment or concerns and a copy of the written response should be sent to the relevant NHS body's or health service provider's feedback and complaints officer where the local recording systems do not automatically allow for this.

2.6.4 Monitoring, Learning and Improvement

2.6.4.1 The extensive nature of views expressed in feedback, comments and concerns provides a wealth of management information that can be used to inform service improvement, share good practice, increase patient safety and in turn reduce in the number of complaints. It is essential that this information is recorded and acted on locally via robust governance processes and procedures.

2.6.4.2 In accordance with the monitoring obligations set out in the Complaints Directions, relevant NHS bodies should make arrangements to monitor how they or those providing health care on their behalf deal with the feedback, comments and concerns they receive. Monitoring should be undertaken with due regard to patient confidentiality and to the principles of equality and diversity in terms of the person providing the information and the content of the feedback. In so doing the relevant NHS body should identify areas for action in relation to improvement. Feedback, comments and concerns received via PASS should also be monitored and action taken as appropriate.

2.6.4.3 Relevant NHS bodies have a responsibility to gather information on their own services and the health service providers within their area on an annual basis in relation to feedback, comments and concerns and those providers have a duty to supply this information to their respective relevant NHS body as soon as is reasonably practicable after the year end (31 March).

2.6.5 Publication

2.6.5.1 In accordance with the Complaints Directions, relevant NHS bodies must publish annually details summarising the action which has been or is to be taken to improve services as a result of feedback, comments and concerns received in the year. The information required in relation to complaints statistics is described in Part 3.