Review of the NHS Complaints Procedure: Health Inequalities Impact Assessment

5. Taking action

5.1 All staff need to have an understanding of how to deal with complaints at the early resolution stage, and the appropriate knowledge and skills to do so effectively. This includes being aware of how to make a meaningful apology where appropriate. Investigative staff must also have the skills and training to effectively investigate and reach robust decisions on more complex complaints. It is for each NHS body (including NHS Boards and service providers) to identify the training needs of appropriate staff to ensure they have the skills and confidence to implement the procedure effectively.

5.2 The Scottish Government has published a NHS model complaints handling procedure, and an accompanying public-facing document, by means of a Director’s letter on 3 October, six months ahead of the proposed implementation date. This is available online at http://www.sehd.scot.nhs.uk/details.asp?PublicationID=5911. These documents have been provided as templates for NHS Boards and service providers to adapt and adopt. The implementation guide that accompanies the documents provides information about the advice and support that is available from the SPSO (including on the ‘Valuing Complaints’ website at www.valuingcomplaints.org.uk), NHS Educations for Scotland and NCPAS in preparing for implementation.

5.3 The SPSO’s training unit provides training courses on complaints investigation and complaint handling skills, such as listening, problem solving and conflict resolution. Other resources on relevant topics including carer awareness and LGBT good practice, and tools such as Emotional Touchpoints and Accessible Information Standards ( SAIF), are freely available to NHS staff.

5.4 The Scottish Government is supporting NHS Education for Scotland ( NES) and the CSA to jointly develop a programme of training and events as well as awareness-raising materials to support implementation of the model complaints handling procedure. This will complement the existing e-learning modules, which cover skills for frontline staff and complaints investigators and which are freely available for all staff providing NHS services.

5.5 The NHS Complaints Personnel Association Scotland ( NCPAS) provides a forum for complaints practitioners to share their experiences and learning from complaints handling. NHS Education for Scotland is working with NCPAS to explore the potential to jointly develop an online learning resource for NHS complaints handlers in Scotland, which will include a links to relevant training resources and materials, and an open forum for consideration of live issues.

5.6 Scottish Government has opened discussions with NHS 24, to explore the potential to develop a shared NHS resource of accessible information, to reduce the cost and burden on individual boards. Early discussions have focussed on the production of key information about people’s rights to give feedback and make a complaint, and the provision of these materials online in a range of languages and formats, including film clips in British Sign Language. NHS Inform has recently launched a new resource called ‘Info for Me’, which can be used alongside the translation tool, Browsaloud, to translate additional materials as required.

5.7 As part of this work, the Scottish Government will explore with NHS 24 the potential to update the two easy read guides on giving feedback and making complaints about NHS services, which were developed by Health Rights Information Scotland in collaboration with a range of equalities groups, to reflect the new procedure.