Complaints: Handling and Considerations

Mar 29, 2023

What is your understanding and your process around this subject?

If challenged, does your policy/ process support, and assist you in meeting your professional standards and regulations?

Do you know what these standards and regulations are?

If you are out of the business does your messaging illustrate this to clients or could they think you have missed your complaints timeframes?

Do you track complaints to look at trends and to then illustrate service changes and shared learnings from them?

There are key aspects which are crucial to consider when looking at your business. Considering your service: –

●  Does your complaints process include a “How to Complain” leaflet/email/information so that clients know what to do and expect?

●  What are your timeframes to acknowledge and investigate complaints?

●  If you are out of the business does your messaging illustrate this to clients or could they

think you have missed your complaints timeframes?

●  If you offer a gesture of goodwill, does your communication explain what this is, or does

it look like an admission of guilt?

Consider your responses to the above and then read on…

Are you confident that you have a clear and transparent process for all service users and stakeholders who make a complaint?

For physiotherapists: – The CSP Quality Assurance Standard 1  includes the statement: –” There is a clear and responsive procedure for making and dealing with complaints.”

For osteopaths, in Standard D Professionalism2 it states: –

D4 “You must have a policy in place to manage patient complaints and respond quickly and appropriately to any that arise.”

For chiropractors Principal F of The Code 3 stipulates that chiropractors must: –
“F5 listen to be polite and considerate at all times with patients including regarding any complaint that a patient may have.”

For HCPC registered professions: – The HCPC Standards of Conduct, Performance and Ethics4 standard 8 stipulates: –

8.2 “You must support service users and carers who want to raise concerns about the care, treatment, or other services they have received.5

8.3 You must give a helpful and honest response to anyone who complains about the care, treatment, or service they have received.”

The HCPC responded in support of the new complaints framework 6 which the Parliamentary and Health Service Ombudsman’s (PHSO) consulted upon in 2020 and then developed to address NHS complaints.

There often appears to be an assumption that the professional body is the best place to call to discuss a complaint. It can be prudent to remember this may not be true. e.g., In the case of Physiotherapy, “The CSP may not be the appropriate body to deal with your complaint. It is not the regulator for the physiotherapy profession and as a result its powers are limited. The strongest sanction open to the Society is the removal of membership from an individual and/or referral to the regulator, the health, and Care Professions Council (HCPC).”

The nature of the complaint provides the direction of travel.

●  If it relates to conduct or fitness to practise matters – the registering body is usually the

first contact e.g., HCPC.

●  In the NHS, complaints are handled at site level by contacting the Patients Advice and Liaison Service (PALS), who may then decide to involve the relevant registering body but will investigate first.

●  If the complaint could affect the reputation of the professional body, they would be the first point of contact. Understand the relationship between your professional body and regulatory body. For example: – “The CSP cannot stop a member’s ability to practise. We routinely review the outcomes of HCPC fitness to practise hearings and any CSP member who has been struck off the HCPC register will have their CSP membership terminated.”

If your concern refers to the professional competence of an employee, you need to discuss this with their employer. As an employer (or sole practitioner) you need to have a robust process in place and clear guidance for the complainant. They need to understand the process that will be followed. This includes timeframes for each step. Ensure any absence from the business is visible to ensure the timeframes are understood e.g., if on annual leave, do clients know this from your website/emails and that clearly it will impact upon the timeframes?

Your complaint management system is intended to:

●  enable a response to issues raised in a timely and cost-effective way.

●  boost a user’s confidence in the administrative process, and

●  provide information that can be used to deliver quality improvements in the services,

staff, and complaint handling.

In simple steps, good complaint handling means:

●  Getting it right.

●  Being customer focused.

●  Being open and accountable.

●  Acting fairly and proportionately.

●  Putting things right.

●  Seeking continuous improvement.

Complaints can happen but so much can be learnt from them, track what happened and what action was taken and how these actions were shared and audited to avoid a recurrence. When reflecting, they can sometimes provide a positive outcome.

References and additional resources: –

  1. Quality Assurance Standards for physiotherapy service delivery
  2. D. Professionalism Osteopathic Practice Standards
  3. The Code (GCC Chiropractic)
  4. HCPC Standards of Conduct, Performance and Ethics
  5. HCPC How to Raise a Concern
  6. HCPC Response to PHSO Complaints Framework
  7. Osteopathic Complaints and Concerns.
  8. Make a Complaint | GCC
  9. HCPC List of Professional Contact for Complaints and Concerns
  10. HCPC What We do if a Concern is Raised About You
  11. Fitness to Practise advice for registrants | GCC

We now invite you to revisit the initial four questions and now ask – can I answer these questions, and do I comply?

If it’s a no or you are still not sure, we are always here to help.

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