The experience of people whose cases we have reviewed, as well as the feedback given by a wide range of public sector staff within this report, provide a clear view that more must be done to support and strengthen the quality and consistency of frontline complaints handling within the NHS and our wider public sector jurisdiction.
More needs to be done to make sure demand on the complaints system is met effectively, that concerns are resolved and remedied quickly, and that the experience of users is captured and acted on to learn and improve public services. There are several practical steps we will take to make that happen.
Public consultation on the Framework
We are carrying out a public and stakeholder consultation on the draft Complaint Standards Framework. No framework on complaints can be credible without significant public, user and complainant contribution to its construction.
Upon completion of our public consultation, we will act on the submissions and feedback we receive to revise and improve it. We will then launch the final version of the Framework as quickly as possible, with an initial focus on supporting the NHS staff embedding it, while clarifying expectations around the standards of service they should expect for the public.
Embedding the Framework into our work
We are committed to ensuring the Framework is used constructively and proportionately within our own casework when holding both the NHS and (eventually) UK Government Departments to account for the quality of their complaints handling.
In parallel, the Framework should be used by NHS Commissioners and Regulators in their assessment of the effectiveness of how NHS organisations approach complaints handling.
The Framework would inform, as far as possible, how NHS Regulators measure and assess performance on complaints of NHS organisations, and how NHS Commissioners hold NHS providers to account regarding learning from complaints.
As the Framework is embedded, we expect organisations to begin to capture and report on data that demonstrates how they are meeting these new expectations. This should be done in a way that does not create onerous new reporting requirements. We invite feedback on how embedding the Framework and monitoring it could best be achieved as part of the public consultation.
During the consultation, PHSO will also explore how we can identify trends in implementation to help organisations place the Framework at the heart of their approach to listening to – and learning from – feedback from service users. In this way, the Framework can be developed as a living document of direct relevance to the public.
As part of embedding the Framework, every NHS organisation should ensure that staff subject to a complaint have access to a member of staff who can provide advice and emotional support. This would mirror the support that should also be available to all complainants through the statutory advocacy and other services that are in place.
Supporting staff through high quality complaints handling training
Working with key stakeholders, PHSO will develop a core learning and development programme on complaints handling that provides staff delivering NHS services with access to high quality training and development aligned with the Framework’s expectations. Ultimately this approach can lead to externally accredited training and professional qualifications in complaint handling.
Developing and co-ordinating delivery of training on such a scale is ambitious. It constitutes a revolution of expectations. If it is to be achieved, there will need to be support from Parliament and relatively modest investment from Government to realise the scale of ambition required. We will make a clear and realistic assessment of what resources will be required to achieve this as we look to develop our new corporate strategy for 2021-4.
Piloting how the Framework will work in practice
Ensuring that the Complaint Standards Framework works for all NHS service users and staff will be vital. We will therefore run pilots following the Framework’s launch. These will focus on working with service users and a small number of NHS organisations that represent the different areas of healthcare.
The pilots are expected to last 12 months to make sure that we can identify any challenges to embedding the Framework, and to make sure that the training we design is relevant and meets everybody’s needs.
Capturing complainant feedback on how the Framework benefits them
We will develop a robust approach to seeking feedback from complainants on the impact of the Framework as part of the piloting phase.
The Complaint Standards Framework owes a debt to My Expectations, which sets out a user-led vision for what complainants expect to experience when they want to raise a concern or complain about health and social care providers. We will work with our partners to carry out a review of My Expectations, to ensure it continues to reflect modern user needs and is expanded to cover making a complaint about UK Government departments.
This review will also explore how NHS organisations and others can incorporate feedback from complainants into their consideration of how effectively the Complaint Standards Framework is embedded in their organisation. Similarly, it will consider how this feedback can be incorporated into the reporting that organisations should do to demonstrate how the Framework has been embedded into their approach to handling complaints.