Complaints and Concerns Annual Report. Garry Perry - Patient Relations Manager

Transcription

1 ENC No. 11 Meeting Trust Board Date 27 August 2015 Title of Paper Lead Director Author Complaints and Concerns Annual Report Amir Khan Medical Director Garry Perry - Patient Relations Manager PURPOSE OF THE PAPER 1. To advise the Trust Board on the number of Complaints/Concerns received by Division and theme 2. The number of Complaints received in relation to inpatient activity 3. Complaints referred to Ombudsman 4. Complaint response times 5. Lessons learned/outcomes SUMMARY OF THE KEY POINTS 379 formal complaints were received in 2014/15, compared to 389 the previous year 2471 informal concerns were raised in 2014/15, compared to 1553 the previous year. The increase is due to dissatisfaction with outpatient services 7 cases were referred to the PHSO during 2014/15, 1 upheld, 4 not upheld, 2 partially upheld Lessons learned are shared throughout the organisation via the quality system, bulletins, monthly Complaints and Concerns reports to the Board and a quarterly CLIPs report. RECOMMENDATIONS The Trust Board is asked to note the report.

2 LINKS Strategic Objectives Safe High Quality Service Annual objectives Safe High Quality Service Monitor / CQC / Regulatory Requirements CQC includes a standard for management of complaints NHSLA Standard 2.3 Local Authority Social Services and NHS Complaints (England) regulations 2009 IMPACT Patient Experience High high numbers of complaints will adversely affect the quality of patient experience Quality & Safety High Complaints about treatment can be indicators of inadequate clinical and nursing care Financial Moderate - Workforce n/a Equality & Diversity n/a Estates n/a IM&T n/a Communications / Engagement RISKS Clinical Risks Business Risks Finance & Performance Risks Reputation Risks External standards PREVIOUS CONSIDERATION Quality & Safety Committee, 20 th August 2015 Moderate risk of adverse publicity and poor patient experience

3 REPORT TO THE TRUST BOARD 27 AUGUST 2015 ANNUAL COMPLAINTS & CONCERNS REPORT 1. Introduction The purpose of this report is to provide details of the complaints and concerns received by Walsall Healthcare NHS Trust during 2014/15. The report identifies numbers and themes of formal complaints and concerns by Division and provides an overview of lessons learned and complaint response times. This is in line with good practice as identified in the review of NHS Complaints Handling undertaken by the Right Honourable Ann Clwyd, MP and Professor Tricia Hart, A review of the NHS hospitals complaints system: Putting patients back in the picture (October 2013). 2. Activity Complaint type Formal Complaint Informal to formal complaint Informal concern Formal to informal Compliment Comment/suggestion 18 6 MP letter 8 4 TOTAL Total activity is similar to the previous financial year apart from the significant rise in informal concerns being raised. Deeper scrutiny shows that this rise is mainly attributable to the dissatisfaction with outpatient appointments. 3. Formal Complaints This section details Formal Complaints received during 2014/15.

4 Access Admission Appointments Attitude Clinical Communica Consent Diagnosis Discharge Environment Equipment Food/bever Health Information Lost Property Medication Privacy/dign Staffing Transfer 3.1 Formal Complaints by Division There were a total of 379 formal complaints (including 33 informal to formal conversions). The Divisions of Medicine and Long Term Conditions (MLTC) and Surgery generated the greatest number of complaints, with Accident and Emergency (MLTC) and Trauma & Orthopaedics (Surgery) accounting for a third of letters received. The Divisional Quality Teams continue to monitor the progress of complaint investigations and the implementation of remedial action Total Estates And Facilities Medicine And Long Term Conditi Surgery Womens, Childrens And Clinical Total Figure 1 Formal Complaints by Division 3.2 Formal Complaints by Complaint Category During 2014/15, the over-riding theme emerging from formal complaints was clinical care, assessment and treatment, with underlying themes of quality of nursing or medical care, pain management and follow up Total Total Figure 2 Formal Complaints by Category

5 3.3 Formal Complaints per 10,000 spells In the most recent data available, NHS Choices shows that in 2012/13, Walsall Healthcare had the following rates of complaint in comparison with neighbouring organisations: Organisation Inpatient /10,000 continuous spells Outpatient /10,000 attendances Walsall Healthcare Royal Wolverhampton Sandwell & City Dudley Heart of England University Hospitals North Midlands University Hospitals Birmingham n/a Burton Maternity /10,000 care spells 3.4 Response Times We have been working towards achieving 70% of all formal complaints having a completed response within 30 working days. During the first six months of the year, this was not achieved, however following changes to processes and increased support to the Division, during the latter six months, the standard has been achieved in 5 out of the last 6 months. The overall average for this time period is 86.2%. The percentage for the whole year April-March was 60.4%. 3.5 Lessons Learned The monthly complaints reports and quarterly Complaints, Litigation, Incidents and PALS reports to the Board detail summaries of lessons learned as a result of formal complaints received. Examples include: An SBAR (Situation, Background, Assessment, Recommendation) based patient transfer form has been developed in order to ensure consistent and update information is passed on when patients are transferred. Improved information regarding the role of the Swift Discharge Suite (SDS) is now published. This includes a letter which will be given to patients and relatives about the SDS as well as a poster giving information about the unit. The ward notice board now includes information regarding care pathways on discharge from hospital. A&E staff now make electronic referrals to District Nursing teams to ensure patients' receive their appropriate and timely visits. Cardiology waiting list initiatives being completed due to long delays within the department.

6 A notification to be sent to Imaging when referring patients who are at high risk of falls. All Midwifery Led Unit attendances and patient drug charts to be entered and scanned onto BADGER system prior to being filed in the hospital records. Lead Dietician has reviewed dietary training for Housekeeping/Catering staff, and a series of training sessions has started in order to improve their knowledge of what is expected. AMU will develop an information booklet for all new patients and care of IV infusions is now included in the AMU competencies to ensure that lines are not disconnected unnecessarily. 4.0 Parliamentary and Health Service Ombudsman (PHSO) Cases During 2014/15, a total of 7 cases were referred to the PHSO. 6 further cases were closed which were received in the previous year 2013/2014. There are no current cases open from either time period. Year Total cases Upheld Not Upheld Partially Upheld 2014/ / Themes emerging included: Concerns highlighted with regard to clinical care assessment and treatment, poor communication, inadequate pain management and poor nursing care. 4.1 Lessons Learned from PHSO cases closed Staff education regarding terminal illness and care of the dying patient. Amber Care model introduced onto ward from September Rolling this programme out to additional staff members. Lack of Initial and on-going pain assessment for cancer patients. Adapted version of the Brief Pain Inventory to be used daily at 14.00hrs to assess the effects of analgesia in the present and previous 24 hours Education of medical and nursing team to change in times of regular medication. all consultants including palliative care team re the change in times. Print on handover document. Changes to times. Signage over bed to indicate opioids. Patient stated that they failed to pass urine post - trial without catheter (TWOC) whilst on one surgical ward. Ten Message campaign Management Post Catheter Removal was discussed at the ward meeting and the 10 messages displayed on the staff notice board Complaint that on one ward an observation chart ( systolic) blood pressure excess 200 not monitored/ and concerns not escalated. As a result the early response team undertook ward based teaching session on the deteriorating patient. Ward staff to receive training/reminder on the implementation of SBAR

7 5.0 Informal Concerns This section details informal concerns received during 2014/ Informal concerns by Division There were a total of 2471 informal concerns (including 23 formal to informal conversions) Total Corporate Estates And Facilities MTLC Other Surgery WCCSS A significant number of informal concerns were generated by the Division of Surgery and the majority of concerns were related to outpatient access and delays in follow up. The organisation has an Outpatient Improvement Plan in the process of being implemented to overcome the problems that have been experienced. 5.2 Lessons Learned Following a concern about A&E security. Several risk assessments have been carried out over the last few years in relation to the inability to reduce access and lock down the department. Restricted access to the department along with improved CCTV coverage of all corridor areas of the Emergency Department has been implemented thereby improving security of an extremely busy environment. Following concerns regarding waiting times to see a spinal surgeon a Locum Consultant has been recruited in order to assist with bringing waiting times down to an acceptable standard. Following concerns regarding the availability of a drug to treat myelofibrosis a new drug agent called Ruxolitinib is now available to the Haematologist and which can improve symptoms and splenic enlargement in patients of with this condition.

8 6.0 Patient Relations Service Developments Patient Relations delivered Complaints Handling training to the FYI and FY2 doctor s. The format utilised a patient story with the patient attending themselves to share their experience and participate in the lessons learned discussion. Training was also delivered to the Therapies team for Planned Care and the newly employed nurses. This is in addition to the regular customer care slot at Trust induction. 10,000 Pt Relations Leaflets have now been delivered which will ensure full access to information across all wards and clinical areas these have started to be rolled out. The next phase will include role out to GP surgeries and community sites. In addition a small number of National Complaints leaflets have been received published by the DoH. These leaflets are intended for patient bedsides and we are in discussion with the Patient Experience Group as to how best to implement this. The team have introduced a complaints handling quality assurance checklist which is currently being used to audit against a set of standards monitoring compliance with the recent complaints matters CQC audit and the PHSO user led vision for complaints handling. We were audited by the information governance and the corporate project manager against the CQC Complaints Matters standards. The audit demonstrated that the Patient Relations Team have robust systems and processes in place but are reliant on divisions providing updates and sending all relevant documentation in order for it to be saved on the Safeguard database. Divisional teams have been reminded that it is essential that completed complaint responses are returned to the PRT with all relevant statements, the quality assurance checklist and final risk rating. The Trust Complaints and Concerns Policy has been revised and the PHSO User Led Vision has been embraced. Recommendations have been approved for the implementation of a Complaints Review Panel supported by the CCG and patient representatives. Terms of reference have been drawn and the inaugural meeting will take place during the summer. A review of our complaints procedures was undertaken with a gap analysis against national recommendations and an aciton plan that has almost been implemented with the exception of recommended training (Appendix 1). There remain some partially compliant aspects that are being addressed. 5.4 Recommendations

9 Complaints Co-ordinators (IO s) to identify themselves to complainant as a named contact Develop and introduce a Complaints information pack and an Easy Read leaflet. Opportunity for organisational membership of the Patients Association Inclusion of information on complaints feedback on the website

10 Appendix 1 WALSALL HEALTHCARE NHS TRUST Complaints and Concerns Review of Local Policy Against National Recommendations Introduction In 2011, Walsall Healthcare NHS Trust implemented new procedures to handle complaints, concerns and issues from patients, relatives and carers which aims to be less rigid and process driven, bringing it into line with the Local Authority Social Services and NHS Complaints (England) Regulations The underlying principles of this complaints system are aligned to those of the Parliamentary Health Service Ombudsman: To get it right To be customer focussed To be open and accountable To act fairly and proportionately To apologise and to put things right To seek continuous improvement The policy has been written in accordance with the Local Authority Social Services and National Health Service Complaints (England) Regulations 2009 and Walsall Healthcare NHS Trust will also make reference to the DoH Guidance in Complaints Handling Listening, Responding, Improving and the Parliamentary Health Service Ombudsman Principles of Good Complaints Handling and Principles for Remedy Policy Refresh As a result of recommendations arising from the investitgations into the failings at Mid-Staffordshire NHS Foundation Trust, Robert Francis QC commented on complaints in his report to highlight that they are a warning sign of problems in a hospital. He stated: A Health Service that does not listen to complaints is unlikely to reflect its patients needs, and; A complaints system that does not respond flexibly, promptly and effectively to the justifiable concerns of complainants not only allows unacceptable practice to persist, it aggravates the grievance and suffering of the patient and those associated with the complaint and undermines the public s trust in the service. The Rt Hon Ann Clywd MP and Professor Tricia Hart were commissioned by the Secretary of State for Health to lead a review as part of a response to the Francis Report. Their subsequent report Putting Patients Back in the Picture looks at how complaints about care in NHS hospitals made by patients, their carer s and representatives are listened to and acted on by hospitals.

11 This report and the Government s response to the Francis Inquiry Hard Truths prompt a fresh review of the organisation s complaints handling processes. In summary, there are several areas where developments to our processes are required: Board level scrutiny of complaints. A monthly report on complaints action taken including an evaluation of the action Sharing of complaints information Attention to narrative data in complaints reports Promotion of our desire to learn from comments and complaints Arms length investigation of complaints in certain circumstances True independence of clinical and lay advice where there are complaints of serious failings Support for complainants Development of professional behaviour in the handling of complaints Action taken as a result of a complaint should recorded and checked with the patient that it meets with their expectation Training for all staff who are involved in dealing with complaints Active encouragement of patient feedback In addition, the CQC has commented on our Complaints Policy and suggested that there are aspects that could be improved: Appropriateness of the 30 day target response date for all complaints regardless of complexity. A key action of the 2009 Regulations was removal of the 25 working day target to provide greater flexibility for minor complaints this could encourage much quicker responses, whilst accepting that longer timescales will be needed for the most complex/severe. Ensure it is clear that complaint documentation should not be held in patient case notes Clarify how complainants are assured they will not be discriminated against a result of raising their complaint Clarify if complaints are assessed as upheld or not (in line with the regulations) Describe the availability of literature and posters for patients/relatives and carers (in line with CQC Outcomes) Describe the process for redress as there is no mention within the policy, whether this be financial or otherwise (linked to PHSO principles) Process for monitoring completion of remedial actions Complainant satisfaction surveys Whether complaint handling reviews/audits, for example the Patient Association Peer reviews set up at Mid-Staffs are carried out

12 Gap Analysis Source Requirement Status 1. Hard Truths: 1.1 Methods of registering a comment or complaint must be readily accessible and easily understood. Multiple gateways need to be provided to patients, both during their treatment and after its conclusion, although all such methods should trigger a uniform process, generally led by the provider trust. Policy for formal and informal complaints handling clearly states the methods by which comments or complaints may be made. Leaflets and posters are widely available in the hospital as well as invitations for patients and the public to Have your say Additional work is required to ensure that service is publicised in the wider community Leaflets distributed to all GP surgeries and community health venues, our details are published in Healthwatch material including newspaper adverts and leaflets. Includes articles in Trust Membership Matters Magazine. 1.2 Lowering barriers actual or intended litigation should not be a barrier to the processing or investigation of a complaint at any level. It may be prudent for parties in actual or potential litigation to agree to a stay of proceedings pending the outcome of the complaint, but the duties of the system to respond to complaints should be regarded as entirely separate from the considerations of litigation. 1.3 Provider organisations must constantly promote to the public their desire to receive and learn from comments and complaints; constant encouragement should be given to patients and other service users, individually and collectively, to share their comments and criticisms with the organisation. 1.4 Patient feedback which is not in the form of a complaint but which suggests cause for concern should be the subject of investigation and response Presentations to community groups inc retired unison members, PPG Forum, Church Groups and ia the Trust Community Leaders Forum. We currently continue to investigate complaints where the complainant indicates that compensation is being sought We are currently compliant with external requirements on promoting feedback from patients and the public We have conducted In your shoes to obtain feedback and are about to repeat the exercise Latest patient survey indicates that people know how to give feedback Chief Executive and other staff feature in Have Your Say posters around the hospital This depends on where and how the concern arises. If a patient or carer raises an issue with the Patient Relations department, it will be

13 investigated, even where the person raising the concern indicates that he/she just wanted to make us aware. Where the concern is raised on the Choices website, through social media etc. an investigation will also be conducted There is no assurance that concerns raised and dealt with locally are captured and shared, work to assess this aspect is required. 1.5 Comments or complaints which describe events amounting to an adverse or serious untoward incident should trigger an investigation. 1.6 Investigations Arms-length independent investigation of a complaint should be initiated by the provider trust where any one of the following apply: A complaint amounts to an allegation of a serious untoward incident; Subject matter involving clinically related issues is not capable of resolution without an expert clinical opinion; A complaint raises substantive issues of professional misconduct or the performance of senior managers; A complaint involves issues about the nature and extent of the services commissioned. 1.7 Support for complainants. Where meetings are held between complainants and trust representatives or investigators as part of the complaints 1.8 Learning and information from complaints Subject to anonymisation, a summary of each upheld complaint relating to patient care, in terms agreed with the complainant, and the trust s response should be published on its website. In any case where the complainant or, if different, the patient, refuses to agree, or for some other Verbal Action form is available Staff do investigate locally and refer on to Pt Relatioins if a formal response is required or our input into resolution. Compliant, specific in Incident and Complaints Policies Partially compliant Policy updated external investigations/opinions are sought in certain circumstances and examples of this can be provided. PHSO guidance pushes for local resolution first WM Complaints Manager Forum discussed this no uniform approach currently in place Compliant. The Patient Relations Team support all complainants before, during and after meetings. We have a guide for both complainants and staff on what to expect and how to conduct these meetings and also advise on advocacy services that are available Partially-compliant Q&S/Board Report available on the website. Needs clearer link to Pt Relations. Discussions with Comm s regarding a specific web page for Pt Relations. Ack letter updated advising that anonymised complaint data may be shared.

14 2. Clwyd: Improvements in the way complaints are handled reason publication of an upheld, clinically related complaint is not possible, the summary should be shared confidentially with the Commissioner and the Care Quality Commission. 2.1 Attention needs to be given to the development of appropriate professional behaviour in the handling of complaints. This includes honesty and openness and a willingness to listen to the complainant, and to understand and work with the patient to rectify the problem. 2.2 Staff need to record complaints and the action that has been taken and check with the patient that it meets with their expectation 2.3 Complaints are sometimes dealt with by junior staff or those with less training. Staff need to be adequately trained, supervised and supported to deal with complaints effectively. 2.4 Trusts should actively encourage both positive and negative feedback about their services. Complaints should be seen as essential and helpful information and welcomed as necessary for continuous service improvement. 2.5 Every Chief Executive should take personal responsibility for the complaints procedure, including signing off letters responding to complaints, particularly when they relate to serious care failings 2.6 There should be Board-led scrutiny of complaints. All Boards and Chief Executives should receive monthly reports Complaints report shared with CCG. Ack letter template Sept 14.docx Policy promotes open and honest complaint handling. Pockets of compliance across the Trust, but also pockets of partial compliance. Duty of Candour/Being Open training has taken place. Specific Complaints Handling Training to be sought. WM Complaints Forum identified a trainer (Understanding Modern Gov) used by other Trusts with positive feedback. Requires audit. Evidence of noncompliance arising from recent complaints Training programme required Specific Complaints Handling Training to be sought. WM Complaints Forum identified a trainer (Understanding Modern Gov) used by other Trusts with positive feedback. We are currently compliant with external requirements on promoting feedback from patients and the public We have conducted In your shoes to obtain feedback and Trust have repeated the exercise Latest patient survey indicates that people know how to give feedback Chief Executive and other staff feature in Have Your Say posters around the hospital Compliant Monthly report to Board implemented, but continues to be developed.

15 on complaints and the action taken, including an evaluation of the effectiveness of the action. These reports should be available to the Chief Inspector of Hospitals. 2.7 Every Trust has a legislative duty to offer complainants the option of a conversation at the start of the complaints process. This conversation is to agree on the way in which the complaint is to be handled and the timescales involved Requires further work on action taken and evidence of compliance with same. Complaints Committee is being established. Pt Relations working with Divisons on tracking of Lessons Learned and Actions Implemneted. MLTC and Surgery have developed an audit spreadsheet to track progress. Complaint where contact details are provided audit tool implemented to check against this. Ack provides contact details for discussion where only address given 3. Clwyd: Greater perceived and actual independence in the complaints process 2.8 Where complaints span organisational boundaries, the Trusts involved should adhere to their statutory duty to cooperate so they can handle the complaint effectively 2.9 There should be proper arrangements for sharing good practice on complaints handling between hospitals, including examples of service improvements which result from action taken in response to complaints 3.1 Hospitals should offer a truly independent investigation where serious incidents have occurred 3.2 When Trusts have a conversation with patients at the start of the complaints process they must ensure the true independence of the clinical and lay advice and advocacy support offered to the complainant 3.3 Patient services and patient complaints support should remain separate so patients do not feel they have to go through PALS first before they make a complaint PRT Quality Assurance Checklist.d Compliant The Trust s monthly complaints is published on the external web site. The Patient Relations Manager is a member of a regional peer group and actively promotes sharing We have started to commission arms length investigations see above 1.6 Partial Compliance: We interpret this recommendation as applying to serious complaints. As they are currently investigated internally, we cannot ensure true independence Independent advocacy support is offered and leaflets/contact details provided. Staff frequently direct patients to the Patient Relations Service as a first response to concerns being raised Advocacy details for Healthwatch and Vocieability are promoted across Walsall and referrals are received directly from them before contact has initially been made with

16 3.4 Patients, patient representatives and local communities and local HealthWatch organisations should be fully involved in the development and monitoring of complaints systems in all hospitals the Trust. Complaint Monitoring Panel has been set up. ToR developed. PPG representation sought and inaugural meeting took place in July CQC comments 3.5 Board level scrutiny of complaints should regularly involve lay representatives 4.1 Appropriateness of the 30 day target response date for all complaints regardless of complexity. A key action of the 2009 Regulations was removal of the 25 working day target to provide greater flexibility for minor complaints this could encourage much quicker responses, whilst accepting that longer timescales will be needed for the most complex/severe. 4.2 Ensure it is clear that complaint documentation should not be held in patient case notes 4.3 Clarify how complainants are assured they will not be discriminated against a result of raising their complaint 4.4 Clarify if complaints are assessed as upheld or not (in line with the regulations) 4.5 Describe the availability of literature and posters for patients/relatives and carers (in line with CQC Outcomes) 4.6 Describe the process for redress as there is no mention within the policy, whether this be financial or otherwise (linked to PHSO principles) 4.7 Process for monitoring completion of remedial actions Draft Terms of Reference.docx The monthly complaints report is presented at Public Board Updated policy reflects changes. Single issue complaints to be resolved within 15 working days Moderate harm or multi-issue complaints to be resolved within 30 working days Resolution date for major or catastrophic or complex medical complaints should be agreed with the complainant, taking into consideration the timescale for an independent investigations It should be noted that 1. and 2. account for the majority of complaints. Revised policy provides clarity Revised policy provides clarity Revised policy provides clarity Revised policy provides clarity Revised policy provides clarity Revised policy provides clarity 4.8 Complainant satisfaction surveys Revised policy provides clarity 4.9 Whether complaint handling reviews/audits, for example the Patient Association Peer reviews set up at Mid- Staffs are carried out survey letter.docx Patient Relations Complainants Survey. Revised policy provides clarity Complaints Panel to assist with this.

17 Action Plan Item Action Responsibility Completion Policy review and refresh to reflect Policy/procedure changes to be made PH/GP Complete recommendations Formal launch of new procedures Patient Relations Conference GP Date TBC Audit of compliance with policy Compliance and Complete Risk Team Response Times Agree revised complaint response times Exec Team Complete at 3 levels dependent on severity/complexity of the complaint: 1. Single issue complaints to be resolved within 20 working days 2. Moderate harm or multi-issue complaints to be resolved within 30 working days 3. Resolution date for major or catastrophic or complex medical complaints should be agreed with the complainant, taking into consideration the timescale for an independent investigations It should be noted that 1. and 2. account for the majority of complaints. Access to Patient Relations Service Ensure all public spaces within Trust PRT Complete buildings have signposting PRT involvement with Information Centre PRT Complete Publicise with posters and leaflets externally to Trust buildings GP GP surgeries and health centres Publication of upheld complaint responses Subject to consent and anonymisation, a GP Pt stories inc in Annual Complaints Report Quality & Safety Committee August 2015 AK/GP/PH 17

18 summary of each upheld complaint relating to patient care, in terms agreed with the complainant, and the trust s response will be published on its website Subject to consent, inclusion of the Monthly Patient Stories to Trust Board on the website Complaint Reports/monitoring Establish Complaints Committee Continue to develop monthly complaints report Review processes to develop a robust audit mechanism to ensure complaints are reviewed on a regular basis at Executive/Director level to ensure completeness of investigation, openness and lessons are shared and learnt across the organisation. Determine method for complaint handling reviews/audits, for example the Patient Association Peer reviews set up at Mid- Staffs are carried out Training for staff to address changes to policy, Develop training package complaints complaints investigation, record keeping, handling for staff, to ensure different responsiblities in relation to complaints and levels according to staff responsibility concerns handling and openness and honesty Schedule training programme in conjunction with the learning centre Overview training to be delivered to AMDs and HoNs Ensure all CDs, matrons, senior sisters and department managers attend training PH/GP GP GP/DD PRT AK/KH board paper minutes available on web site. Development of web page to include more specific reference. Complaints Monitoring Panel to assume these functions. First meeting set for the 29 July /10/ /10/ /10/ /3/2015 Annual Complaints Report Quality & Safety Committee August 2015 AK/GP/PH 18

19 session Redress arrangements Agreement required on system of redress (to comply with PHSO principles) Involving patients, patient representatives and local communities and local HealthWatch organisations in the development and monitoring of complaints systems in all hospitals Ensuring independence of serious complaint investigations Consider the development of a Complaints Review Panel to meet quarterly. Consider quarterly reports to Healthwatch and Health Scrutiny panel Strengthen the relationship with Healthwatch and explore options for a partnership agreement for complainant support, advocacy and mediation Consider the involvement of patients, voiceability, Healthwatch and a representative of the Health and wellbeing board of a Complaints Review Panel to meet quarterly Agreement to be reached on methodology for carrying out arms length investigations Arms length investigation of serious complaints to be implemented (definition used by Hard Truths Exec Team Policy provides guidance Exec Team Exec Team GP Exec Team Exec Team PRT Complete Complete 30/09/2014 1/11/2014 Annual Complaints Report Quality & Safety Committee August 2015 AK/GP/PH 19