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Complaint Management Policy

Australia’s Medical Termination Provider




We take this seriously. All complaints, no matter how trivial they may seem to be, must be dealt with according to this policy, and our Medical Board must be notified of all complaints and their resolution.


How we deal with complaints

Ideally, most complaints should be dealt with directly and quickly at the point where the problem arises – with as little formality as possible. Often, no changes to procedures are required – most complaints involve an acknowledgement of the patient’s perspective and an explanation. If the complaint is made to staff at the point of service, they should first assess whether they can deal with it themselves (informal or straightforward complaint) or whether they need to refer it to the practice manager or the complaints manager (a more formal, serious or complex complaint). It is important to listen carefully to what the patient is saying to make sure you understand what the problem is.


Staff need to know what action they can take to resolve complaints. For example:

  • Give an explanation of what happened – but ONLY if they do know why it happened.
  • Offer an apology if warranted. This acknowledges that the patient has been listened to.
  • If it is a problem relating to a clinical issue, notify the doctor. If the patient is still not satisfied, they can lodge a complaint.
  • The nurse must inform the doctor about the complaint.

Immediate follow up and feedback to the patient can avoid an escalation of the complaint.


Recording

Even if a complaint is resolved, the complaint and action taken must be recorded on an incident form.

Sometimes complaints are quickly resolved – you may feel there is no time to record the complaint. For a minor matter it may not be warranted and you will need to use your discretion about this. Nevertheless, in general, all staff should record complaints as often as possible for quality improvement purposes. This will enable monitoring of similar complaints in the future. Recorded complaints are given to the complaints manager to collate – a seriousness assessment is made.


When to refer a complaint on

Complaints should be referred to the complaints manager if they:

  • are unresolved,
  • involve serious consequences,
  • involve complex medical issues,
  • need action that is beyond the responsibility of the staff,
  • need to be dealt with by someone with more authority.

Complaints needing investigation

The complaints manager is responsible for coordinating complaints referred by other staff and written complaints made by patients, as well as complaints that have come from the Health Services Commissioner.

The steps involved in complaint handling are as follows:

  • Step 1: Assessment
  • Step 2: Information gathering
  • Step 3: Resolution/outcome
  • Step 4: Implementation

Some complaints may be dealt with quite quickly, with minimal need for investigation. For complaints requiring any degree of investigation, it is important to keep the patient informed throughout the process.


Step 1: Assessment

The seriousness of the complaint or problem needs to be assessed by the complaints manager. The seriousness assessment will determine who will deal with the complaint, and who needs to be notified.

As much as possible, complaints should be dealt with by the unit involved, with support from the complaints manager. However, for more serious matters or those with broader implications for the organisation, senior management and the Board will need to be notified at least and possibly also participate in the resolution. At some point, depending on the type of complaint, it may be necessary to alert the Practice insurer or even obtain legal advice. However, this should not interfere with the aim of resolving the complaint quickly and amicably.


Step 2: Information gathering

Information gathering The purpose of investigating a complaint is to establish what happened by gathering information, prepare a report where warranted and formulate resolution options. This may include recommendations for changes to clinical, management, administrative or environmental systems to minimise the likelihood of a similar incident occurring in the future.

Approach

It is important to keep an open mind when gathering information, not make assumptions about what has happened and not to draw conclusions until all the information is assembled. The complaints system is non-punitive. When analysing what went wrong or why there is a problem, systems should be examined to see how changes can be made and how individuals can be supported to prevent recurrence.

Talk to the patient

The person dealing with the complaint first needs to ensure they have full information about the complaint and desired outcome. Talk to the person who has made the complaint to ensure that there is clear understanding of all aspects involved and of what the complaint is about. An incident form should be filled in – this can be done by the staff member if necessary and checked with the patient. It is important at this stage to make sure that you have the patient’s ‘story’ as they present it.

Take it down as they say it, without filtering or interpreting the information. This is so that you have a complete picture of the patient’s perspective and the context of what happened. You can then ask questions to clarify or expand on what they have told you.

The patient should also be given the chance to ask questions. The person taking the complaint has a responsibility to explain to the patient how the complaint procedure works – what will happen next, who will get back to the patient, and how long it is likely to take. In some cases it may also be useful to refer them to a support/advocacy group. When talking to the patient it is important for the staff member not to be defensive and to maintain a courteous and professional approach.

Keep the patient informed

When dealing with a complaint that involves some investigation and gathering of information, keeping in regular contact with the patient is important. If there are a number of different personnel to get information from, this may take time. If so, contact the patient, by telephone if possible, to let them know what is happening and where the complaint process is up to. Be direct and as honest with them as possible. Most people understand that delays are inevitable, but they need to know that action is being taken. Even if there is no progress, a regular telephone call can go a long way towards establishing good faith and will help resolve the complaint in the long run.

Talk to the staff

Ensure that all relevant people are consulted about the complaint, while protecting the confidentiality of those involved. It is important to keep accurate records of the steps in the investigation, including all discussions, information gathered and conclusions reached.

A successful investigation is conducted objectively, with an open mind and without bias. This means focusing on the facts of what happened, rather than relying on people’s feelings or interpretations. However, remember that any staff members involved may be feeling a degree of anxiety or stress about what has happened, depending on the circumstances. This will be helped by giving them the opportunity to explain their perspective fully and clearly. Staff needs to be listened to and supported. Sometimes information received from different staff members will be inconsistent. It is common for different people to have different perceptions of the same event. The person investigating the complaint needs to bear this in mind.

Be efficient

Try not to let the investigation drag on. Timely resolution is good for both staff and patients. Set timelines at the outset and try to stick to them. Support for staff is an important part of investigating complaints.


Step 3: Resolution/Outcome

Resolving a complaint should be seen as a joint problem-solving exercise. Once all the relevant information is to hand, discuss options for resolution with staff and the patient.
These may include:

  • meetings between the patient, their family and staff, more than one meeting is needed.
  • an explanation– giving information to patients can go a long way towards resolving complaints and is consistent with open disclosure principles. Ensure the explanation is factual and understood by the patient.
  • an apology– staff do not need to be afraid of apologising for mistakes – an apology is not the same as an admission of liability and it can be a powerful aspect of complaint resolution.
  • an undertaking to review policies and procedures with a view to improving outcomes.

It can be helpful to analyse what happened and why by gathering together key staff members. This will help identify resolution options and any policy or procedural changes needed. It is most important that staff be involved in complaint resolution and given the opportunity to suggest outcomes.

The organisation will decide what it considers a realistic outcome, balancing the needs of the patient against the needs of the organisation as a whole. Take into account what the patient wants, while recognising what is reasonable. Use the complaint to make practical changes that will benefit all patients.

Outcomes involving individual staff

Although the focus is on systemic issues, the role of the staff cannot be ignored. The individuals concerned should be encouraged to talk about what is happening and offered support if needed. There is help available for professionals who are having problems at work, e.g. medical defence organisations offer counselling, communication training etc. If there are concerns about the professional conduct of an individual, consider also the need for referral to the relevant registration body.

Plan for successful resolution:

  • Do not become defensive.
  • Be flexible and problem-solving in approach.
  • Approach it as a joint problem.
  • Identify the patient’s key issues and concerns.
  • Identify any constraints to your power.
  • Look for outcomes that will satisfy both parties.
  • Try to establish objective principles, without rigidly rejecting the patient’s subjective concerns.

Step 4: Implementation

Ensure that the outcome is clearly communicated to the patient, staff and management, and that it is integrated into quality improvement systems.

The following should be done:

  • Enter the resolution/outcome into the relevant complaints data collection tool.
  • Implement any actions decided on as part of the resolution.
  • Provide information to quality improvement teams, risk managers and managers of relevant training programs.
  • Provide information on complaints and outcomes to senior management, including the Board of management.
  • Monitor effectiveness of outcomes.

It is also important to report back to the patient, family member or friend who made the complaint. Make sure the patient is told about any specific changes that the organisation has made as a consequence of their complaint and how the effectiveness of outcomes will be monitored. In addition, we will ensure that any changes identified by quality or risk management teams are communicated adequately to staff and are implemented and monitored.