Peter Fox wrote:
>
> We are setting up a new Coop in North Durham. Presently looking at how
> best to organise the complaints proceedures for it. Anyone out there in
> existing Coops with protocols for same willing to share their current
> system in dealing with the punters perceived problems?

You've no doubt already got your own protocol set up for your practice.
For a cooperative,  all you have to do is modify such a scheme
to allow for the peculiarities of a GP Co-op  c.f. a GP Practice :

1. Situations where the Cooperative seems to be directly responsible :
(a) Patients seen as T.R.'s or Immediately necessary Rx by
    a Co-op doctor but who are not yet registered with a member GP.
(b) Patients who contact a cooperative, are not registered with
    a local GP, who are unhappy with their contact with Co-op
    telephonist, disappear off to say hospital and then complain.

2. Need to establish line of complaint.
In normal circumstances, treatment or advice is provided by a Coop
doctor on behalf of a member GP.   If the patient makes a complaint
about the Co-op GP, you have to decide within your procedure who
takes / receives the complaint, how and by whom it is handled etc.
If the complaint is received by the Co-op should it be passed on to
the member GP and his / her Practice ?
My interpretation of the new system suggests that the member practices
are responsible for dealing with the complaints of their own patients,
and that the Cooperative should assist with their investigations where
the complaint involves a Coop doctor / Coop system. This would be
in keeping with claims and complaints of clients  vs. contractors and
their subcontractors.

I wholeheartedly agree with Graham Ross form A.L.e.R.T. who said :
> The single most common factor is that most doctors, whether
> through pressure of time and work or whatever, simply do not have (or
> may be do not choose to display) adequate personal communication skills
> when dealing with patients. Get those right and you reduce complaints
> and litigation.

The new system _does_ seem to be reducing complaints _and_ improving
communication;  but remember that we have been issued with guidelines
from the DoH.
GP's and their practices are required to carry out their own in house
complaints procedures to a reasonable standard.  Deviation from this could
detract from patient satisfaction and increase the risk of Health Authorities
proceeding further against practices.
The procedures need not appear to be difficult for the patient but are
necessarily complex for the individual practice, to ensure that procedures
are properly processed.
Complainants seek explanations, apologies and the reassurance that
they are being taken seriously.  This latter need can involve face to face
contact supplemented by written recording, reassurance and explanation.

What follows is a generic re-draft of our procedure in Leeds.
It is IMHO fairly complicated.  It looks slightly easier when viewed in a
VISIO flowchart !!!

==================================================

GP CO-OPERATIVE  IN HOUSE NHS COMPLAINTS PROCEDURE

As of 1st April 1996,  the cooperative organisations should have adopted
in house complaints procedures which conform with National guidelines.
The following notes are based on standard DoH documentation, with some
elaboration as necessary due to the particular requirements of a GP
cooperative.

The focus should be on using complaints as a positive rather than punitive
method of improving service.  The process until now has been  "all or nothing"
where patients have had to take a fairly confrontational view.  The new procedure
encourages much more sensible use of the complaints procedure to produce
general improvements in our services.

_Background_

Definition :  A complaint in an expression of dissatisfaction which requires a
response ; there is always an expectation that something will be done to
prevent the same thing happening again in the future.

Issues which commonly generate complaints :
- manner and attitude  (practitioners and staff)
- home visits

All complaints involve a lack of communication on both sides

What do complainants seek :
- an explanation
- an apology
- reassurance that they are being taken seriously

An apology need not be an admission of liability.
Litigation rarely motivates complaints
Objectives of the reforms to the complaints system :
- simpler, speedier complaints process
- easy access to the public, and greater publicity generally,
  of the system
- focus on attempting to satisfy the complainants' concerns,  while
  still being fair to the practitioners and their staff.
- increased emphasis on using information from complaints to improve
  service quality.
General features of the new system :
- one system for the whole NHS
- two stage process
- terms of service requirement to have a system
- separation of complaints from disciplinary process
- expansion of Ombudsman's role
The two stage process

1. Local resolution
Those providing services to the patient should resolve the complaint if
possible,  by immediate, often oral first line response,  followed by
investigation and or conciliation,  and then action by the practice to
resolve the problem.

2. Independent Review
Convenor  (Health Authority Complaints Officer) considers
- whether all practicable action already taken
- whether further action is possible at The Local Resolution Stage
- whether an independent Review Panel should be convened

Complainant has right of putting case to Ombudsman where Panel
is NOT convened

Changes to "Terms and Conditions of Service"
GP's are required to :
- have in place,  publicise  and operate a practice base system for
  dealing complaints
- co-operate with the health authority complaints procedure.
Time Limits :
Complaints can be logged
- within 6 months of Complainant becoming aware of cause for complaint,  or
- within 12 months of event giving rise to complaint,  whichever is the sooner
- complaint must be acknowledged within two days or receipt
- investigation must be completed an explanation to patient within
  10 working days of receipt of complaint (or inform patient if some delay
   is likely to be incurred)

_Implementation_

New system applies to all complaints made on or after 1st April 1996,
where the event giving rise to the complaint arose on or after 1st Jan 1996.

Prime objective of local resolution : To resolve complaints as quickly as
possible and as informally as possible within the practice.

The expectation is that Practitioners and their staff will do everything
practicable to prevent the complaint from progressing to the Independent
Review stage.


Should I Apologise ?
If appropriate why not ?
	"Sorry to hear about what's happened ?"
	"Sorry that's the way it came across  -  that wasn't what I intended. "
Remember : an apology is one of the things that most complainants seek


What's in it for the GP Cooperative :
- less expensive and stressful in the long run
- greater freedom to resolve problems in a manner which suits the organisation
- opportunity to improve services
- could remove the need for the health authority to become involved at all

Keeping track of complaints
- Coop based records, (separate from the call logging systems themselves).
- standardised documentation, facilitated by computer database
- copies of correspondence to be kept (separate from the call logging
  systems themselves)
- audit and review of complaints / procedure

Initial Contact
- stay calm,  be positive
- provide private location if possible
- listen carefully,   take relevant notes
- don't react with negative comments
- be wary of offering immediate responses to complex issues
- explain what happens next and when

Meetings
- arrange as soon as possible
- appointment with The Manager (and Medical Director if needed)
- sufficient time needed :  suggest allocate 1 hour
- relevant notes to be recorded on standard sheets
- explain what happens next and when


_The Protocol_

The initial portion of the complaints procedure is complex.  There are three
possible scenarios of responsibility and accountability  (and several possible
ways of handling a complaint depending on the wishes of the member GP /
practice involved) :
a) where the index patient is identifiably registered with a member GP
b) where the index patient has been seen by a Cooperative GP on the basis
of Immediately Necessary Treatment.
c) where the index patient is not registered with a member GP, and the
cause for complaint arose prior to the patient being registered by a member
GP (whether on a registration, temporary registration or Immediately
necessary treatment basis) : here the Cooperative has sole medico-legal
responsibility.

If a patient or their representative approaches the organisation enquiring about
or stating that they wish to make a complaint,  they should be given a copy of
our  "In House Complaints Procedure Information Sheet".   Verbal or written
complaints should normally be passed onto the GP principal with whom that
patient is registered  (or the Cooperative GP from whom they received
Immediately Necessary Treatment). The "Responsible" GP is obliged to carry
out the initial investigation. The "Responsible" GP may approach the
Cooperative Manager / Medical Director to carry out further internal enquiry
and investigation.  If the complaint concerns care delivered by a Cooperative
GP on the basis of Immediately Necessary Treatment,  the complainant
should be given the name and address of the GP and his / her practice.

Where a GP / practice passes on a complaint for the Cooperative's
internal investigation,  the Cooperative will normally report back to the
"Responsible" GP  unless the GP expressly wishes the Cooperative
to interview and / or report back to the complainant / patient.  The
Cooperative also reserves the right to interview complainants / patients
if it is felt that  this is essential for the satisfaction of the complainant
or where the interest of the Cooperative would be best served.

If there is no identifiable "Responsible" GP   e.g. an non-registered patient
calls,  requests a visit, then disappears off to hospital and subsequently
complains about the manner of the telephonist, or lack of speedy response
from the Cooperative,   then such an enquiry would have to be dealt with
internally by the Cooperative.  Much of the remainder of this protocol
relates primarily to this uncommon and unusual situation

If a patient wishes to make a complaint,  they should be asked whether
they wish to make this verbally (by referral immediately, or as soon as
practicably possible, to The Manager),  or in writing  (when they should be
given a complaints form, and an appointment to see The Manager). In the
absence of The Manager, the complaint should be dealt with by the
Medical Director .  The "complaints form" includes space for the patient to
sign appropriate consent where the complainant is not the patient.

The Manager will establish contact with the complainant and record all
details.  No response will be attempted at this stage unless the facts are
self-evident and the issues raised can be resolved.  The Manager will
explain the procedure to the complainant and ensure, where appropriate,
that the complainant understands the need to obtain the patient's consent.
It is quite possible that many complaints will be resolved at this very swift
and informal stage.

If the patient raises a written complaint (or if the complaint is judged by
The Manager to be significant),  an internal investigation will have to be
instigated by The Manager.  Any verbal complaint that cannot be resolved
on the initial contact,  and any written compliant, will be logged by The
Manager,  and the complaint will be acknowledged in writing to the
complainant within 2 working days of the complaint being raised.

The Manager will be given access to all relevant documentation and
to the staff and complainant. The Manager in conjunction with the
Medical Director will decide how best to report back to the complainant.

The procedure should be concluded with an explanation to the complainant
within 10 days. If this is not possible,  the Manager will contact the
complainant to explain the delay and give a revised timescale for the
conclusion of the procedure.

If following the Cooperative's (and / or own GP practice's) explanation,
the complainant remains dissatisfied,  he / she will be informed of
his / her rights to pursue the complaint via the Health Authority.

Information from interview sheets, database logging, and follow up
questionnaires will be fed back to Management Team and Committee
Meetings for review of systems, procedures and protocols.

=======================================================================
Dr Rob Pearson
General Medical Practitioner & RCGP District Faculty Tutor(East Leeds)
95 Moresdale Lane      (also ViceChairman of Leeds Doctors Cooperative)
Leeds
LS14 6BN                     South Seacroft One Stop Services :
Tel 0113 295 1200            Primary Medical Care, Social Services
Fax 0113 295 1210            Housing, CMHT, Community Benefits & Rights
=======================================================================




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