MindMapFocus Limited recognises that there will be times when patients, their families or carers, staff members and others are dissatisfied with aspects of their treatment and services provided. RTN Medical Limited is committed to dealing with any issues that may arise as quickly and effectively as possible.
The potential effects on patients, relatives, and staff members, when things go wrong, can be devastating. Duty of candour, implemented under the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014: Regulation 20, outlines the principles that staff members should use when communicating with patients, relatives and/or carers following an incident where harm has occurred, or where there is a risk or possibility that the incident could lead to or result in harm. It underpins a culture of openness, honesty, and transparency, and is a duty on the organisation, as well as individual staff members working within the organisation. (For more information on duty of candour, see the separate Duty of Candour Policy).
By making sure that concerns and complaints are dealt with in a timely manner the risk of escalation is minimised and the opportunity of finding a satisfactory resolution to the problem is maximised.
At the same time, compliments are an important means of identifying areas of good practice, and MindMapFocus Ltd will seek to ensure that feedback on good practice is shared with employees to motivate and encourage staff members and ensure standards of care are improved wherever possible.
MindMapFocus Ltd will ensure that the complaints procedure is fair and accessible to all.
2. Policy Statement
All concerns and complaints will be treated seriously and investigated promptly in accordance with the procedures outlined in this policy. Staff members will receive training in dealing with concerns and complaints and will ensure that all persons have access to guidance on the procedures for raising a concern or making a complaint. MindMapFocus Ltd is committed to ensuring that no-one is prevented from highlighting concerns or complaints.
MindMapFocus Ltd will ensure that all lessons learned from feedback are used as a means of improving the quality of services provided. Any recommendations made Complaints and Compliments.
MindMapFocus Ltd will ensure that all lessons learned from feedback are used as a means of improving the quality of services provided. Any recommendations made Complaints and Compliments Policy, V1.0 ©2023 Page 3
MindMapFocus Ltd
because of feedback will be shared at 1:1 supervision sessions, in order that changes can be considered business-wide and implemented where appropriate.
RTN Medical Limited recognises its legal responsibility to respond appropriately and effectively to complaints (e.g., through the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014).
3. How to Submit Feedback
Compliments and concerns can be given verbally or in writing to any staff member. The Company Lead for compliments and complaints is Angela Jackson. Complaints must be submitted in writing (via email or letter) to the Complaints Lead (or the Managing Director, Toni Lancaster if the complaint relates to the Complaints
Lead). This is to ensure clarity of the full and specific details of the complaint. Where the complainant is unable to submit a complaint in writing, they should raise the complaint with the Complaints Lead, who will then record the complaint.
Comments on social media websites will not normally be deemed to be formal complaints unless submitted in writing via one of the means outlined above.
MindMapFocus Ltd will ensure full information is provided about this Policy on the Company website. The information will be available in different styles and languages where this is required.
4. Compliments Management Process
All compliments received in writing should be documented. They should also be circulated amongst relevant staff members so that they are aware of the number of compliments received, and the specific topics which are raised.
There is no requirement to record compliments which are received verbally, but this is encouraged wherever possible.
No formal acknowledgement of compliments is necessary, however where this is deemed appropriate, it should be encouraged.
5. Concerns Management Process
Many concerns arise out of a lack of information or understanding, and very often the matter can be resolved via the provision of further information, advice, or an apology.
This means they can often be dealt with at the time of their raising with a front-line staff member. On other occasions it may be that staff members can take swift action to resolve a concern straightaway or find the most appropriate person to help. Staff members should feel empowered to deal with concerns promptly and informally without the need for a more in-depth investigation.
On receipt of a concern staff members will:
Ensure that the immediate health care needs of the person affected by the concern are being met (where the person affected is still in MindMapFocus Ltd Care).
Make sure that the person raising the concern does not wish to make a formal complaint.
Undertake any enquiries required to resolve the matter, respond to the person raising the concern with the appropriate information/advice/apology and/or explain what has been done to resolve the matter.
Offer the person raising the concern the opportunity to discuss their concern further.
However, concerns are handled, staff members should aim to ensure that they are resolved as soon as possible after being raised. Excellent communication at this stage is essential to prevent the concern from escalating into a formal complaint. It is recommended that verbal communication be used primarily at this stage, either face-to-face or via telephone. However, if preferred by the person raising the concern, this can also be in writing, via email or text. All concerns must be recorded on the Central Monitoring Log. The record will include details of the concern, how it was resolved, and any further actions required.
Where the concern cannot be resolved in the above manner, it should be forwarded to the Complaints Lead. The Complaints Lead can discuss the issue with the person raising the concern and initiate the formal complaints process outlined below if required.
6. Complaints Management Process
Once a complaint has been received, it should be recorded on the incident management system and formally acknowledged within 3 working days of receipt. The acknowledgement should normally be in writing but can be given verbally if appropriate.
The Complaints Lead will then either investigate the complaint fully themselves or nominate a ‘Lead Investigator’. If a ‘Lead Investigator’ has been nominated, this will be done so within 5 working days of receiving the complaint and the complainant must be informed with the name and contact details of the nominated person.
The person investigating the complaint will ensure that it is handled in a way to ensure that it is resolved without undue delay. Complainants should ordinarily receive a written response within 15 working days from the date of receipt. It is important that the right balance is struck between a timely response and one that is informed by comprehensive investigative action, as this will provide the best response to the complainant and the best opportunities for learning within the business.
The complainant should be sent regular updates on the progress of the investigation and likely timescales for receiving the formal response. If agreed timescales cannot be met, it is essential that the Lead Investigator informs the complainant of the reason for the delay and that new timescales are mutually agreed. In conducting the investigation, the Lead Investigator may undertake any of the following:
Contact the complainant to identify the outcome that they are seeking.
Provide the complainant the opportunity to give their account and views of what took place.
Review the relevant documentation, checking for evidence regarding the issues raised.
Interview any staff members involved in the incident.
Develop a timeline of what happened.
Identify any shortfalls in level(s) of care provided.
When appropriate, using a Root Cause Analysis, identify the causes/contributory factors/validity of the concerns that have been raised.
Identify clear and assigned actions to prevent recurrence and to improve care quality.
The Lead Investigator will then:
Decide whether the complaint should be upheld in full, upheld in part or not upheld.
Make a record of the details of the investigation, outcomes, and actions to be taken on the Central Monitoring Log.
It is essential that every stage of the investigation is based on the best available evidence. The formal response from the Lead Investigator should be structured as follows:
MindMapFocus Ltd
Outline how the complaint has been considered.
Explain how conclusions have been reached in relation to the complaint and whether it was upheld in part, in full or not upheld.
Describe how any action needed because of the complaint has been taken, or is proposed to be taken.
Explain that if they are not happy with the findings, an internal appeal is possible.
Provide details of external escalation, should the complainant still be unhappy and wish for their complaint to undergo external review.
The Lead Investigator should ensure that the full written response is filed alongside the initial complaint on the Central Monitoring Log. If, after receiving the formal response, the complainant is not happy with the outcome, they may write to the Senior Leadership Team to request an internal appeal.
7. Internal Appeal
Upon receipt of an appeal the Senior Leadership Team will:
Take the time to understand the details of the initial investigation and outcome.
Contact the complainant to understand the reason(s) why they are not happy with the initial investigation outcome.
Appoint a different, appropriate and independent unbiased individual within the business to carry out the appeal investigation.
Provide the complainant with the name and contact details of the Independent Investigator.
The Independent Investigator will:
Review the initial investigation and outcome.
Meet with or contact the complainant to discuss their continuing concerns.
Carry out further investigation, if necessary.
Decide whether the initial investigation outcome should be upheld.
Provide the complainant with relevant feedback and inform them of the appeal outcome, including a response to the continued reasons for dissatisfaction. Once completed, the Independent Investigator will ensure that the Central Monitoring Log is updated with comprehensive details of the appeal, including actions taken and outcome. They will also report their findings to the Senior Leadership Team. Complaints and Compliments Policy, V1.0 ©2023 Page 7
RTN Medical Limited
8. Independent Review
Once a complaint has been fully dealt with by RTN Medical Limited, if the complainant remains unsatisfied with the outcome of the internal appeal, they can refer the complaint to:
NHS Patients:
Parliamentary and Health Service Ombudsman
(https://www.ombudsman.org.uk/)
The Parliamentary and Health Service Ombudsman now only looks further into the more serious complaints about the NHS. They do not look into the following:
Delays with complaint responses.
Matters which are likely to resolve themselves within the next few weeks or months.
Delays in service delivery which are non-critical and are the result of an organisation coping with COVID-19.
If a patient wishes to escalate a non-serious complaint, they can do so through the below pathway.
Private Patients:
Independent Sector Complaints Adjudication Service (ISCAS) - Details are available at Complaints process – ISCAS (cedr.com)
Complaints can also be escalated to the appropriate professional body where the issue puts into question a healthcare professional’s appropriateness to practise. Although, MindMapFocus Ltd ask for the opportunity to investigate the matter first. Our service is registered with and regulated by the Care Quality Commission (CQC).
The CQC cannot get involved in individual complaints about providers but is happy to receive information about our services at any time. The CQC can be contacted at:
Care Quality Commission,
National Correspondence,
9. Monitoring and Learning from Complaints
MindMapFocus Lts regards all forms of feedback as an opportunity to improve the levels of care offered to patients. MindMapFocus Ltd operates within the ‘just culture’ framework. This means that staff members are not apportioned unconstructive guilt or blame for genuine mistakes, but that they always remain accountable for deliberate policy deviations. The culture within MindMapFocus Ltd is a supportive one. Where areas of learning are identified following the receipt of feedback, these will be addressed.
To ensure that the rest of the business is equally able to learn from feedback received, details of the lessons learned will be shared across the business. The Registered Complaints Manager will then be responsible for discussing the most appropriate method of sharing proposed service improvements with the Senior Leadership Team.
Issues arising from complaints should be a standard agenda item for discussion at the Senior Leadership Team meeting and the Registered Manager should ensure that themes, trends, and lessons learned are shared with staff members.
10. Unreasonable Complainant Behaviour
Many complainants are angry and feel very aggrieved, sometimes with good cause. Although most complainants behave appropriately, a small number may make complaints that are vexatious or malicious. This may involve making serial complaints about different matters or persisting with the same complaint when nothing further can be done to assist them.
It is important to distinguish between people who make several complaints, because they genuinely believe something has gone wrong, and people who are simply trying to make life difficult.
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