Complaints and Problems Overview

This overview aims to simplify the recording and management of complaints and problems. For the purpose of this overview, complaints and problems are all called 'Events'
An individual Event Record (G 110A) is created for every Event
A log is made of every Event Record in the Event Register (G 110B). Note that you may decide to file patient complaints records, logs and related documentation separately from other Event records
A complaint is any expression of dissatisfaction by a patient (or their representative) about a dental service or treatment. Complaints can be verbal or written and can be about any part of the service you provide. All complaints must be logged internally, even if the complaint was verbal and resolved within 24 hours.
A problem is any untoward incident that occurs at the practice including staff complaints, late deliveries, repeated laboratory errors, management mistakes and equipment breakdowns
An Event, for the purposes of this Overview, is something untoward that happens in your practice (to a team member, patient or the practice) that has an impact, good or bad. These will be an unusual event rather than an everyday occurrence.
Make sure that your procedures comply with the GDC Standards and are in line with the current regulators in your region. If in doubt consult your professional indemnity organisation

Managing Complaints

Complaints manager

Practices must appoint a complaints manager and include their details in the Patient Complaints Procedure (G 110C or G 110CW). Complaints should be managed following the Patient Complaints Procedure, Complaints Handling Policy (M 233-COM) and this overview on Patient Complaints Management.

The Complaints Handling Policy and Patient Complaints Procedure should be reviewed regularly by the practice and all new team members must be trained on complaints management at their Staff Induction (M 225A). Complaints can be audited with Optional Audit of Patient Complaints (G 180-APC).

Complaints principles

Practices should develop a framework for managing complaints and feedback based on these principles:

All patient feedback is important to us
We want to make it easy for patients to raise a concern or complain, if they need to
We follow a complaints procedure and keep patients informed
We will try to answer all patient questions and any concerns raised
We want patients to have a positive experience of making a complaint
Patient feedback helps us to improve our service

These principles were developed by a working group consisting of professionals from 28 organisations including representatives from Agilio. The aim of these principles is to help practices and patients to get the most from feedback and complaints.

A poster and leaflet showing these core principles are available for display on walls and in waiting areas. It is not a requirement to display the poster, but it is considered best practice.

Display and publishing of complaints procedure

The Patients Complaints Procedure (G 110C or G110CW) must be clearly displayed in the practice where patients can easily see it. GDC standards require that the complaints procedure is available on your website.

Handling and resolving complaints

Acknowledgement

Most complaints must be acknowledged in writing within a specific time:

In England complaints must be acknowledged within 3 working days

A copy of the Patient Complaints Procedure (G 110C or G 110CW) should be enclosed with the acknowledgement.

Local early resolution

Simple verbal complaint will be resolved easily within 24 hours there is no requirement to write to a patient. If a verbal complaint cannot be resolved within 24 hours a written copy of the complaint must be created and sent to the complainant along with an acknowledgement letter. A full and accurate record must be kept of the complaint.

Recording complaints

All complaints must be recorded on an Event Record (G 110A) and also be logged in the Event Register (G 110B). Complaint Records must be treated as confidential, kept separately from clinical records and only be accessible by authorised persons. Any correspondence or investigation records about the complaint must also be stored with the Record and Register.

Handling manner

Patient complaints should be handled politely, showing consideration, by listening to patients and by involving them fully in the process of resolving the complaint.

Timescale of resolution

Aim to resolve a complaint as quickly, effectively and smoothly as possible. Speed is a top priority when handling complaints. The longer you leave a complaint unresolved, the more dissatisfied the patient may become.

GDC Standards for the Dental Team states:

"5.3.4 You must respond to complaints within the time limits set out in your complaints procedure
5.3.5 If you need more time to investigate a complaint, you should tell the patient when you will respond
5.3.6 If there are exceptional circumstance, which mean that the complaint cannot be resolved within the usual timescale, you should give the patient regular updates (at least every 10 days) on progress."

Complaints from patients must be resolved within a specific time:

In England, for written complaints and those that require investigation, a full response must be provided in writing as soon as is practical. Generally, practices aim to resolve complaints within 10 working days

If a response to a complaint is likely to take longer than anticipated, or if there are any other delays, the patient must be informed about the reasons for the delay and the expected date of the full response. In case of a delay, the patient should be given regular progress reports.

Response to complainant

In a response to a complainant, all the points of their complaint should be addressed and practical solutions offered for each point if possible. In particular, you should try to meet the outcomes requested by the patient. An apology should also be given when appropriate.

The complaints manager may propose practical solutions to the patient in the first response. This can be done by telephone so long as full records of the conversation are kept. If responding verbally, the patient is sent a follow-up letter confirming the details of the telephone conversation with a copy of the Patient Complaints Procedure (G 110C or G 110CW). In the full response the patient should be invited to a meeting to discuss any suggested solutions and any other aspects of the complaint.

Closing the complaint

Once the patient is satisfied and the complaint has been resolved the Event Record should be signed to show that the matter is closed and the entry in the Event Register should also be signed off.

Apology

The majority of complaints can be resolved if there is a sincere apology. This can avoid lengthy, costly and stressful disputes. An apology does not mean admitting responsibility. It may be necessary to apologise that something has gone wrong, as a way of showing concern and understanding. The GDC Standards for the Dental Team states:

"5.3.8 You should offer an apology and a practical solution where appropriate."

Timescales for patients to make complaints

In England complaints should normally be made within 12 months of the date of the event, or when the problem first came to the attention of the patient.

Note: Overall patients have 10 years to raise issues related to treatment under general litigations rules. This is why it is recommended to keep clinical records 10 years or more. See the Overview on Record Retention (M 215)."

Who to complain to and escalation

Private patients

Private patients should contact the practice manager. If they are not satisfied with the response they can contact GDC's dental complaints service within 12 months of the treatment or within 12 months of becoming aware of the issue.

Professional indemnity

When a complaint appears to be escalating or is serious, it is best to contact your professional indemnity organisation to help you to handle it.

Learning from complaints

Practices in all countries are required to analyse and learn from their complaints. The Event Record (G 110A) can be used to help practices record their findings. Where appropriate, the results of complaint analysis and any resulting actions should be shared with the team at practice meetings. Regulators will look at this aspect of compliance management during inspection.

Practices can use the 'Task' feature in the software to schedule any follow-up actions.

Managing Problems

Managing problems

A problem is any untoward incident that occurs at the practice including staff complaints, late deliveries, management mistakes and equipment breakdowns. Each practice must decide which problems to record to suit its circumstances; otherwise problem reporting could get out of hand. An appointed member of staff such as the Practice Manager should have the authority to determine if a problem needs to be recorded and whether it needs further Significant Event Analysis. For each problem an Event Record (G 110A) is created and recorded on the Event Register (G 110B). When the problem has been resolved the Record is closed and the Register entry signed off as closed.

Repetitive or difficult problems

Problems are normally reviewed during the Practice Audits and at the iComply Annual Management Review (G 170-TM2) each year. However, if there is a repetitive problem, e.g. a supplier continually delivers late, you may decide to carry out significant event analysis. Problems are considered closed when the issue has been explored, corrective actions have been taken and any necessary preventive actions put into place. This may involve changing practice procedures, giving individual training or having a group discussion at a practice meeting.

Online Reviews

Regulators, such as the CQC, will investigate a practice before carrying out an inspection. This can include looking at online review sites such as Google. Agilio recommends investigating negative online reviews where necessary.

The following approach has been developed by Agilio for dealing with online reviews:

Appoint a team member to regularly check for and respond to online reviews
Respond to all reviews, both positive and negative, thanking the patient for the feedback
If a review is negative, explain that that you take complaints seriously, but never address the complaint directly online or mention confidential details
Express that you are sorry that the patient felt their expectations were not met and invite them to use complaint channels (if they haven't already)
Use the opportunity to discuss positive aspects of the practice
Report and investigate internally using an Event Record (G 110A)

Here is an example of a good response where a patient hasn't left their name:

'Thank you for your feedback. It's great to hear you have had a good experience with one of our dentists and we are disappointed this hasn't been the same with our reception team. How our patients are treated in all areas of the practice is very important to us and we regularly carry out annual team training in customer service skills. If you could take the time either write a letter with the details of the issues you faced and address it to the manager, or call us on 01409 254 354, we can investigate the problems and provide our staff with any appropriate training to ensure your experience is more pleasant in the future.'

Further information

References

England