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How we’re building a new Complaints Standards Framework

Assistant Director of Strategy and Partnerships

Earlier this month, we held our second Health and Social Care Regulators' Forum working group meeting. We shared updates on progress towards creating an NHS-wide Complaints Standards Framework.  

Working with partners

Once again we had a great turnout from across the health and social care sector, including most of the attendees who joined us last time. This time we also welcomed the Patients Association, the Carers Federation and HealthWatch, representing the patients’ voice. We were struck by how positive everyone was, and by their energy and enthusiasm for this initiative. 

I updated delegates on our work since April, including how we have engaged with the Scottish Ombudsman, and the advice and advocacy sector. I also shared our research into complaints policies and frameworks from health organisations, the higher education sector and the Scottish Ombudsman.

Research findings

Our main finding was that the Framework should include the core stages of making complaints or giving feedback. Each stage should form a chapter, with a detailed framework that sets out our expectations for that stage. The Scottish Ombudsman uses a similar model for their Complaints Standards Authority, producing common complaints policies that are flexible enough to support local processes.

Before we discussed our findings in groups, we presented our suggested stages. The four stages are broken down like this:

Stage one: Engaging and responding to feedback

This includes: 

  • seeking out feedback
  • engaging with service users and staff
  • reporting on feedback to improve services
  • supporting staff
  • making sure staff know they can raise concerns safely.

Stage two: Carrying out an investigation

This includes: 

  • showing that concerns will be taken seriously
  • managing expectations
  • explaining how decisions will be made
  • maintaining accurate records of investigations.

Stage three: Delivering outcomes

This includes:

  • discussing provisional views with everyone involved in a meaningful manner
  • empowering staff to be open when things go wrong
  • providing an evidence-based response
  • ensuring clear signposting to PHSO if the complainant is still unhappy at the end of the process.

Stage four: Reflecting and learning 

This includes:

  • expectations that all staff will create a culture of welcoming and seeking out feedback
  • expectations for how organisations ensure feedback and complaints are used to improve services 
  • expectations for how organisations will share learning, insight and best practice in feedback and complaints.    

Feedback from the working group

In discussions about each stage, delegates told us that the Complaints Standards Framework should be driven by values and behaviours. The group suggested a high-level framework should focus on principles. In practical terms this means how frontline staff apply the framework, and what boards can do to help their organisations embed learning. 

It was clear that no one wanted to introduce new processes. Listening and responding were seen as more important. There was a lot of support for staff – both those handling complaints and those being complained about.

There were also some interesting suggestions about how we might change the language we use when talking about our work. 

Some of the delegates told us about how their organisations use insight from our final investigation reports. They also gave us comments about our next steps, and some suggestions on how we might talk to and involve frontline complaint handlers and service users. 

Finally, we were pleased to hear from the Department of Health and Social Care (DHSC) representative about ministerial interest in a Complaints Standard Framework, and how it supports a just culture within the NHS. This will be at the heart of DHSC strategy. 

Next steps for the framework

It’s great to be making such good progress on developing the new framework, working with patient representatives and partners across the sector.

A Complaints Standards Framework will also support the professionalisation of the workforce. It will help develop high-level skills in people who deliver the complaints service and who are at present under-valued. 

At the next working group meeting, we will present our draft framework before we send it to regulators. It will then go for public consultation.

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Read more about good complaint handling.