New NHS complaints handling procedure: first year review

4. Appendices

4.1 List of NHS Boards and stakeholders visited

NHS 24
Scottish Ambulance Service NHS Forth Valley
NHS Greater Glasgow & Clyde NHS Fife
NHS Ayrshire & Arran NHS Dumfries & Galloway NHS Highland
NHS Grampian NHS Tayside NHS Lanarkshire NHS Lothian
Scottish Public Services Ombudsman Patient Advice and Support Service NHS Education for Scotland
Scottish Mediation Network

4.2 CHP Key Performance Indicators

1. Learning from complaints

2. Complaint process experience

3. Staff awareness and training

4. The total number of complaints received

5. Complaints closed at stage one and stage two as a percentage of all complaints closed

6. Complaints upheld, partially upheld and not upheld at each stage as a percentage of complaints closed in full at each stage

7. Average times

8. The number and percentage of complaints at each stage that were closed in full within the set timescales of 5 and 20 working days.

9. Number of cases where an extension is authorised

4.3 Internship project briefing

Scottish Government / Scottish Graduate School of Social Science Internship Scheme

Policy Context:

Scottish Ministers are committed to an integrated programme of measures to facilitate cultural change to achieve openness and transparency without blame in the provision of NHS health and social care services. Central to this is the revised NHS Complaints Handling Procedure, which came into effect on 1 April 2017.

The Openness and Learning Unit was established in September 2017 in the Scottish Government to work with stakeholders in developing an approach that is accessible and meaningful for front-line professionals and national bodies to support improvements in health and social care outcomes. The aim is to create an environment that uses knowledge to inform continuous improvement to services in a culture of openness without censure.

NHS Model Complaints Handling Procedures (CHP)

The new, standardised NHS Model Complaints Handling Procedure (CHP)^[1] was introduced across Scotland from 1 April 2017. The revised procedure is intended to support NHS Boards and their service providers to take a consistently person-centred approach to complaints handling across NHS Scotland. In particular, the aim is to implement a standard process, which ensures that NHS staff and people using NHS services have confidence in complaints handling, and encourages NHS organisations to learn from complaints in order to continuously improve services.

The new, model CHP introduced nine newly developed key performance indicators, by which NHS Boards and service providers should measure and report performance. These indicators are a mix of quantitative and qualitative measures, which taken together with reports on actions taken to improve services as a result of feedback, comments and concerns will provide valuable performance information about the effectiveness of the process, the quality of decision-making, learning opportunities and continuous improvement.

NHS Boards are required to review and report internally on complaints handling information quarterly, including any recommendations made by the Scottish Public Service Ombudsman (SPSO) in relation to the investigation of NHS Complaints, with a view to identifying areas of concern, agreeing remedial action and improving performance. Boards must then publish their complaints handling performance information annually.

Project details:

This is an opportunity to work closely with the Scottish Government policy team relevant stakeholders including NHS Boards, government analysts and potentially patients, taking a 360 degree view on the effectiveness of the new Complaints Handling procedure. The project will be focussed on reviewing and analysing the NHS Boards' annual reports (particularly the qualitative indicators) and meeting with relevant stakeholders to gain a deeper insight into the content of the reports.

The project aims to identify what difference the new CHP has made, whether it has been embedded into the NHS culture and to what extent has it influenced learning and service improvements. The project also aims to identify if there is consistency of patient experience of the CHP, to explore how effective internal communications of complaints information is across Boards and to highlight any good practice or particular areas of concern.

The project output will be a report focussed on the learning and patient experience, outlining the experience of the first year of the CHP, highlighting the challenges and developing some conclusions / potential recommendations for going forward.

Some useful reading for those considering applying for this post:

Listening and Learning report which informed development of the new complaints handling process (CHP) – Scottish Health Council -

www.scottishhealthcouncil.org/publications/research/listening_and_learning.aspx

Scottish Public Service Ombudsman report – making Complaints Work for Everyone

https://www.spso.org.uk/sites/spso/files/communications_material/Thematic_Reports/ MakingComplaintsWorkForEveryoneFinalWeb.pdf

The intern would be co-located within the Openness and Learning Unit and will work with other teams as needed, including the Person-Centred and Quality Unit.

Skills required:

This project would suit someone who is keen to apply their skills to an analytical research project. Knowledge of the health and social care landscape including complaints resolution would be useful but excellent analytical skills are more important than any prior subject knowledge. The following are required:

• Strong written and oral communication skills

• An ability to analyse and synthesise varied data and evidence;

• An ability to work independently and flexibly as part of a team.

Please detail the full range of your research and analytical skills in your application and indicate particular strengths.

Timing:

The timing of the internship will be agreed with the successful applicant.

4.4 Briefing email for NHS Boards regarding Scottish Government review on the first year of CHP

Dear Feedback and Complaints managers,

I am a research intern working with Linda Kirk in the Scottish Government. The project I am involved in is an analysis of the first year of the new model NHS Complaints Handling procedure.

The aim of the project is to find out how the implementation of the new CHP has impacted the learning and improvements, the process, and the culture around complaints. We would like to obtain a fuller account of feedback and complaints in your Board services especially on indicators 1-3. This is an opportunity for you to share your good practice and improvements but also to help us identify the challenges and barriers that still exist. For boards with prisons, we would also like to know more about the prisoners' complaints handling.

To gather this information, I would like to visit you and your teams in November. I will be getting in touch with each of you during this week to arrange this. Please allow at least two hours for the meeting.

The findings from reviewing your annual reports and these meetings will be compiled in a report outlining the experience of the first year of the CHP.

Thanks in advance for your cooperation. Looking forward to speaking with you soon. Kind regards,

Bernardette

Bernardette Bonello, Research intern | Openness and Learning Team | Planning and Quality Division | Directorate for Healthcare Quality and Improvement | Scottish Government | Room G. ER, St Andrew's House | Regent Road | Edinburgh EH1 3DG

T: 0131 244 9979

e-mail: bernardette.bonello@gov.scot

4.5 Topic guide for NHS Boards visits

1. Collecting feedback

Ways of collecting feedback and complaints

• Changes since new CHP Use of Care Opinion
• Staff engagement
• How learning is shared
• Challenges

Work with equality groups, advocacy and user and support services.

• Changes in how you work with them and
• Feedback from seldom heard groups

2. Complaints handling procedure

CHP implementation

• Clarity of concerns and complaints
• Difference in upheld complaints since new CHP
• Difference in complainants contacting SPSO
• Change in systems for capturing data
• Monitoring of CHP compliance
• Areas for improvement and support needed

Early resolution

• Experience of shift to early, local resolution
• Methods used to resolve complaints locally
• Staff confidence and compliance with stage 1 procedure
• How you ensure actions are taken and recorded
• Challenges

Stage 2 investigations

• Experience of getting information required for your investigations
• Meetings with complainants at onset of investigation (clarification)
• Meeting with complainants at the end of investigation (explanatory)
• Use of mediation
• Challenges

SPSO

• Change in relationship with SPSO
• SPSO observations – issues and improvements made
• Difference in premature complaints and complaints upheld by SPSO
• Support from SPSO

Adverse events

• Link with adverse events management
• Duty of candour lead
• Procedure for capturing learning from adverse events/duty of candour

Reporting and standardisation

• Changes in internal/external reporting
• Thoughts on indicators 1-3
• Consistency and sharing between boards
• Benchmarking
• Areas for improvements and support needed

3. Indicator 1 – Learning from complaints

Capturing learning

• How trends identified are used
• Experience of CHP for learning and improvement
• Challenges

Service changes

• Most significant service changes/improvements in the first year
• Involvement of patients and the public in identifying/reviewing service improvements
• Procedure for ensuring learning is identified and implemented

Sharing of learning

• Change in ways learning is shared with public
• Progress on increasing focus on learning and improvement
• Extent of internal communications on complaints and learning
• Extent of learning used by line managers and staff
• Extent of learning reviewed by senior management
• Challenges

Culture

• Progress in culture around complaints
• Changes in apologies
• Examples of culture change in the organisation
• Gap between organisation's learning intent and staff experience
• Difference in fear of repercussions amongst patients and staff
• Challenges

Supporting staff

• Support for staff being complained about
• Sharing of positive feedback

4. Indicator 2 – Complaint process experience

Patient experience

• Ways of collecting feedback on complaints procedure
• Satisfaction with: Ease of access to the process; How they were treated by staff; With empathy or apology offered, if any. Timescale in terms of updates/responses; Clarity of decision and clarity of reasoning.
• Response rate
• Areas for improvement and support needed
• Feedback from staff involved in complaints

5. Indicator 3 – Staff awareness and training

Training offered (if not covered in annual report)

• Staff awareness on dealing with complaints
• Any mandatory training on complaints
• Complaints as part of staff inductions
• Adverse events and duty of candour training
• Root cause analysis and human factors training
• Mediation training
• Internal communications on training

Evaluation of training

• Uptake
• Satisfaction with training
• Staff confidence in using knowledge

Performance objects

• Complaints in job descriptions or performance objects for senior managers

6. Overview of first year experience

• Summary of your first year experience
• Advantages and disadvantages of new CHP
• Progress on standardisation of complaints handling
• Listening and learning report observations

7. Contractors

• CHP reception
• Changes in contractors providing data
• Relationship with contractors
• Support needed

8. Prisons

• Difference in prison complaints since CHP
• Relationship with prison healthcare staff
• Complaints handling procedure in prisons
• Awareness and support for prisoners
• Prison staff training
• Learnings from prisons
• Areas for improvement