Policy responses and statements
- Name of organisation:
- Northern Ireland Department of Health, Social Services and Public Safety
- Name of policy document:
- Complaints in the Health and Personal Social Services
- Deadline for response:
- 23 February 2007
Background: Complaints in the HPSS provides a unified and streamlined complaints procedure which applies equally to all HPSS organisations, including Family Practitioner Services, HSS Boards and Trusts, Special Agencies and Out of Hours Services. As such, it is designed to provide a simple, consistent approach for staff handling complaints and for complainants in raising complaints across all health and personal social services.
The new proposals seek to raise the standard of complaints handling by removing the barriers to access, strengthening local resolution, clarifying roles and responsibilities and emphasising the importance of learning and improving. In addition the new proposals aim to improve support services by encouraging conciliation and advocacy and ensuring appropriate training is provided.
COMMENTS ON
NORTHERN IRELAND DEPARTMENT OF HEALTH, SOCIAL SERVICES AND PUBLIC SAFETY COMPLAINTS IN THE HEALTH AND PERSONAL SOCIAL SERVICES
The Royal College of Physicians of Edinburgh is pleased to respond to the Department of Health, Social Services and Public Safety on its consultation on Complaints in the Health and Personal Social Services.
The College supports fully the Department in their aim of raising the standard of complaints handling by removing barriers to access, strengthening local resolution, clarifying roles and responsibilities and emphasising the importance of learning from mistakes.
1. The College welcomes, in particular, the emphasis on learning and development,ensuring that complaints are viewed as an opportunity to improve services. From the clinician's point of view, this must be a key aspect. Achieving the aim of a more positive culture of complaints handling requires that staff be trained and empowered to deal appropriately with complaints (4.13). It is important that individuals function effectively in this role and that HPSS organisations fulfil their responsibility to create an environment where learning can take place (page 21).
As outlined in Section 6 (page 31), these issues must be addressed at the level of H&SS Boards, Trusts, the RQIA and DHSSPS itself. Links to, and involvement with, the activities of the National Patient Safety Agency and its reporting system also need to be further developed so that Health & Care systems in Northern Ireland have the opportunity to contribute to, and to learn from, national and international Quality Improvement and Patient Safety Initiatives.
2. It is of course essential that, where a complaint involves clinical issues, the draft findings and response must be shared with relevant clinicians, not just to ensure factual accuracy of any clinical references, but also so that Clinicians are able to support what goes back to the complainant (paragraph 4.26, page 23).
3. Robust systems are included in the draft guidance relating to unreasonably demanding or persistent complaints (page 16). Although a Vexatious Complaints Policy should only be used as a last resort, it is the experience of both clinicians and those in medical management that there are a small number of individuals who pursue complaints inappropriately, and often through multiple channels, including involvement of public representatives and/or the media. It should be made clear that, where an effective Complaints Policy is in place and being applied, other such activity is unacceptable.
4. Section 5 (page 28) relates to Children Order representations and complaints. It is unclear how this will sit in relation to the remainder of the document. Is this a parallel process, or are the two to be merged?
5. Although satisfactory resolution of complaints should save the service from the costs of future errors and even litigation, the more immediate costs to the service of handling complaints should not be ignored. Much staff time is used even in relatively simple investigations. The 20 day response deadline is demanding and has the potential to impact on meeting other targets and deadlines. If independent review is removed it is likely that more cases will go to the Ombudsman’s office. We do not know the likely volume of work or the ensuing cost. The use of conciliators is untested within the service. For them to be effective, it is likely that conciliators will be reasonably senior staff whose time will be relatively expensive.
Copies of this response are available from:
Lesley Lockhart,
Royal College of Physicians of Edinburgh,
9 Queen Street,
Edinburgh,
EH2 1JQ.
Tel: 0131 225 7324 ext 608
Fax: 0131 220 3939
[23 February 2007] |
