HQIP External Complaints policy
Reason for this policy
Although the vast majority of feedback about HQIP's work will be positive, and any issues of concern that emerge will normally be dealt with informally, HQIP has a duty to respond in a meaningful way to any formal complaint raised against the quality of its work, or how it has handled customers or stakeholders. HQIP wishes to express that it takes complaints seriously, takes complainants seriously, and is keen to address any matter raised by putting in place an appropriate review and any remedial action that may be needed.
This policy covers the following domains:
- The process for making formal complaints
- How HQIP will handle complaints and take action, as needed
The principles behind this policy are:
- Stakeholders, consumers or funders of HQIP, or any other party affected by our work have the right to raise complaint about our work and should know how to do so
- HQIP is committed to review of the complaint in a meaningful, confidential, substantial and transparent way
- HQIP is committed to addressing the issues raised in a meaningful and substantive form and communicating that we have done so
- Complainants may initially raise the complaint with a third party if they feel that HQIP should not assess the complaint internally.
This policy covers formal handling of complaints. Obviously we hope that formal complaints will not emerge and any concerns will be dealt with through informal channels. Any persons with more generalised concerns, or who wish not to invoke formal procedures, may choose to raise issues with senior staff or board members at any time. HQIP will also undertake periodic general reviews of stakeholder opinion through surveys, which also enable views to be shared and offered. HQIP has also created an external advisory group, at senior level, which will be a channel for issues and suggestions. Lastly our patient liaison group enables regular dialogue with service users.
1. How formal complaints can be made
Anyone affected by our work who wishes to make a formal complaint has two options; they may raise the complaint directly with HQIP; or if they wish, raise the matter with our funding bodies, the primary one being the Department of Health in England.
The ability to raise the matter directly with our funding body will be identified clearly on our website. The process by which they do so is up to the complainant, but we will draw attention to the appropriate point of contact to help the complaint reach the relevant section as quickly as possible.
HQIP will set out on its website the means by which people can make direct complaint to HQIP in line with this policy. We will normally ask that complaints are made in writing, and email will fulfil this requirement. Verbal complainants will be advised of the complaints policy. In the circumstances of lack of ability to make written complaints special arrangements will be made.
2. Responding to complaints
HQIP will send an acknowledgement in regard to the complaint within seven working days of receipt. A substantive reply will be made within 22 working days of receipt. Both periods may be telescoped wherever possible with a single final reply sent within a shorter period than 22 working days.
No details of complainants will be made to any third party (other than HQIP's legal advisors) unless they sanction this; other than where complaints are assessed as being malicious or vexatious where they may be discussed in general terms with the funding body in confidence for collective handling.
2.1 Investigation of complaints
All direct complaints to HQIP, or complaints channelled through the funder to HQIP (including anonymous ones) will be delivered in the first instance to the relevant team manager for the issue raised, but always copied to the CEO. Complaints about the CEO will be channelled to the Chair of the Trustees.
The team manager or CEO will have responsibility for the investigation of the complaint. They will review the issues raised and discuss with the CEO.
The process of review will depend on the nature of the complaint made but will involve full consideration of the issues raised and with discussion with any individual staff member, or team, to whom the complaint relates. This will be done promptly with appropriate handling by which no assumption of responsibility is made until the full facts are considered. Documentary or corroborative evidence will be sought and considered, not least of all to raise or identify examples of similar issues that have occurred but which have not led to complaints. Any evidence that staff have hidden or not passed on complaints discovered as part of the review may result in disciplinary action, however.
Where appropriate, the CEO will refer the matter to the Chair for their consideration and involvement in consideration of the issues. They in turn may involve other board members. The CEO will also notify the Chair about any specific significant complaint they feel they should be aware of but in which the Chair will not be involved in handling.
Complaints may be referred on to the funding bodies by HQIP if it is felt they are of substantial nature, even if they were not originally channelled through that route.
Collectively a decision will be made about how to respond and whether there is a substantive issue which requires corrective action. The team manager or CEO (or chair) will have responsibility to respond within the 22 working day period.
2.2 Responding to the issues raised and communicating this to the complainant
After considering the complaint and issues of responsibility and severity, HQIP managers will have responsibility to consider what remedial action needs to be taken to address the complaint made and to communicate the handling to the complainant or to the funding body to reply to the complainant themselves.
The handling will depend on the nature of the complaint but may include a wide range of responses dependent on severity and ease of response. Minor complaints may need limited remedial action. Action may range from no action at all through to substantial overhaul and change to HQIP's operating procedures and potentially disciplinary action against staff, the process for which is set out in HQIP's staff handbook. The response may be limited to the behaviour of a single staff member and how that can be improved, or to collective, organisation wide responses. In the latter case all team managers would be involved and the matter discussed collectively.
On occasion, where thought appropriate, HQIP staff will invite the complainant to a meeting to discuss the matter.
When the review is complete managers will formulate a report setting out a judgement on the issue raised and set out an agreed action plan to address it if required. A summary of this report will be issued to the complainant or to the funding body within the 22 working day period. It will include reference to the appeal process set out below and their rights to refer the matter to the third party funding body. Only in exceptional cases where the review cannot be completed within the specified time will the period be extended, and if this is the case then a note to that end, citing the reason, will be sent to the complainant within the 22 day period.
Internally, following the complaint, the CEO and team manager/s will review the action plan for the issue raised and monitor its effectiveness over time. It may result in subsequent action at a later stage. This may be individual, or collective.
The complainant may not be satisfied with the response and may choose to make continued complaint if they feel the matter has not been dealt with appropriately. Their right to appeal will be clearly communicated on our website.
Any appeal will initially be considered by the CEO and relevant team manager who will review their earlier response and decide whether the matter should be referred on or a further reply given. Once again a meeting may be offered to talk through the issues raised.
If the decision is to consider the matter dealt with as fully as possible in the first response, the CEO will write to the complainant saying so, and explain why they think this is the case. Once again the complainant's right to raise the matter with the funding body, or the chair of HQIP, will be identified. After this, if the complainant continues to raise the issue, it will be dealt with by those bodies directly, although in all likelihood they will discuss the matter with HQIP staff. HQIP staff will be as helpful as they can in responding to such further review and supply such evidence as is requested, along with the handling of the first complaint.
4. How this policy will be monitored
HQIP will assess the effects of this policy through measuring the following:
- The volume of complaints and appeals and where they emerge from and what they relate to
- External feedback on competence
- Regular review of organisational skills and competency
- Annual training needs analysis
HQIP will report collectively on complaints to its trustee group.
This policy is the responsibility of the HQIP CEO to review and monitor
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Policy date: Dec 2011
Policy author: Robin Burgess
Policy owner: HQIP CEO
Policy review date: Dec 2013
Linked policies: Internal grievance procedures (in 1); Information governance (12)