. Annual Complaints Report 2017/2018
CCG Information Reader Box Document Purpose CCG Website Link Title Author For information www.easterncheshireccg.nhs.uk NHS Eastern Cheshire Clinical Commissioning Group: Annual Complaints Report 2017/2018 NHS Eastern Cheshire Clinical Commissioning Group Publication date 15 th June 2018 Target Audience Description Contact details The public, NHS Clinical Commissioning Group Executives & Governing Body, Patient & Public Representative Groups, Voluntary, Community and Faith Sector representatives, Healthwatch Cheshire East The Annual Complaints Report 2017-18 provides a review and summary of the complaints received and managed by NHS Eastern Cheshire CCG NHS Eastern Cheshire Clinical Commissioning Group 1 st Floor West Wing New Alderley Building Macclesfield General Hospital Victoria Road, Macclesfield Cheshire SK10 3BL T: 01625 663828 Email: complaints.nhseasterncheshireccg@nhs.net For recipients use
Contents 1. Introduction... 4 2. Role and Responsibilities of NHS Eastern Cheshire CCG... 4 3. Complaints Received... 6 4. Upheld Complaints... 9 5. You said, we did... 10 6. Parliamentary and Health Service Ombudsman (PHSO)... 12
1. Introduction The Local Authority Social Services and National Health Service Complaints (England) Regulations 2009 (hereon the regulations ) requires all NHS organisations to make arrangements for the handling and consideration of complaints. NHS Eastern Cheshire CCG receives and investigates complaints from: Anyone who is receiving, or has received, NHS treatment and services which are commissioned by NHS Eastern Cheshire CCG A relative, representative or friend of a person who is receiving, or has received, NHS treatment and services commissioned by NHS Eastern Cheshire CCG, if they have been given permission to act on the person s behalf Anyone who is affected by, or likely to be affected by, the action, omission or decision of NHS Eastern Cheshire CCG An elected official (such as a Member of Parliament or Local Councillor) who has been contacted by a constituent raising concerns, feedback or a complaint about either an NHS Eastern Cheshire CCG action, omission or decision and/or treatment of service commissioned by NHS Eastern Cheshire CCG A partner agency that has been contacted by a person with concerns, feedback or a complaint but advised and agreed with the person that it is more appropriate for NHS Eastern Cheshire CCG to co-ordinate the investigation and response. In accordance with the regulations, NHS Eastern Cheshire CCG is required to prepare an annual report that must: Specify the number of complaints received Specify how many of the complaints that were received were well founded (or upheld) Specify the number of complaints that have been referred to the Health Service Ombudsman Summarise the subject of the complaints and any matters of general importance that arose from the complaint or the way in which they were handled Outline the action that has been taken to improve services as a result of these complaints. This report details the information above from the complaints received by NHS Eastern Cheshire CCG for the period 1 April 2017 to 31 March 2018. 2. Role and Responsibilities of NHS Eastern Cheshire CCG NHS Eastern Cheshire CCG believes that the effective management of complaints plays an important role in ensuring that the quality of services provided to our patients continues to improve. This means that NHS Eastern Cheshire CCG endeavour to go above and beyond our statutory function of having processes to manage complaints, by holding the patient at the centre of everything we do while seeking out and listening to what they are telling us. To support NHS Eastern Cheshire CCG in meeting this aim, NHS Eastern Cheshire CCG has a dedicated Complaints, Concerns and Compliments team who are responsible for managing and co-ordinating NHS Eastern Cheshire CCG s response to concerns, feedback or complaints made by people registered with an NHS Eastern Cheshire CCG GP Practice (or their nominated representatives).
The Complaints, Concerns and Compliments team consists of the following members: Rosemary Kendrew Complaints, Incidents and Governance Manager Christopher Clegg Governance Officer Jo Hughes Governance Administrator Georgina Thomas Client Liaison and Business Advisor The Complaints, Concerns and Compliments team recognise that raising concerns, feedback or a complaint can sometimes be a difficult experience for patients and their families or carers. The Complaints, Concerns and Compliments team therefore work hard to ensure that both the Patient Advice and Liaison (PALs) and Complaints processes which respond to concerns, feedback and complaints are patient friendly. This means working with patients and individuals in a compassionate, sensitive and timely manner to resolve their concerns and identify what changes or learning can be implemented to prevent the situation from recurring. The Complaints, Concerns and Compliments team strive to ensure that the complaints it receives about NHS Eastern Cheshire CCG and the services it commissions are investigated thoroughly and supported by changes to prevent issues from recurring. To help achieve these aims, the Complaints, Concerns and Compliments team works towards meeting the Parliamentary and Health Service Ombudsman s Principles of Good Complaint Handling: 1. Getting It Right: All complaints receive a personalised and detailed response from a Senior Director at the CCG. 2. Being Customer Focused: All complaints are managed in partnership with the complainant, who is kept up to date and encouraged to remain in contact with the Complaints, Concerns and Compliments team throughout the investigation. 3. Being Open and Accountable: Patients are encouraged to complain to the CCG and all complaints are responded to in full, with the response explaining why issues occurred and what is being done to prevent them from recurring. 4. Acting Fairly and Proportionately: Complaints are subject to thorough investigations that involve input from multiple departments within the CCG and providers, where applicable. 5. Putting Things Right: Where failings are identified, the CCG is open and transparent in acknowledging mistakes and apologising for these, setting out what actions will be taken to rectify the issue. 6. Seeking Continuous Improvement: The intelligence gathered from complaints is regularly drawn upon to improve the design and delivery of our services. Further details of how the Complaints, Concerns and Compliments team address complaints raised to NHS Eastern Cheshire CCG are set out in the Complaints and Patient Advice & Liaison Services (PALs) Policy and Procedure. The Complaints, Concerns and Compliments team is overseen by the Complaints and Concerns Sub-Committee of the CCG Clinical, Quality and Performance Committee. The Complaints and
Concerns Sub-Committee meet monthly to review anonymised versions of all complaint responses that are sent by the CCG to hold the CCG to account for how it responds to complaints. Healthwatch Cheshire East has resumed attending this meeting during the 2017/18 financial year, which has included sharing stories and intelligence it has received. The Complaints, Concerns and Compliments team has also attended the fortnightly Operational Quality group meetings (QUAG) to share intelligence and emerging themes with colleagues at the CCG. Beyond the CCG, the Complaints, Concerns and Compliments team is part of the Greater Manchester Complaints Manager Network, which provides a peer network through which to discuss improvements and best practice in managing complaints, and is due to commence attending the Cheshire and Merseyside NHS Complaint Managers Network. 3. Complaints Received In 2017/2018, NHS Eastern Cheshire CCG received 123 complaints and pieces of correspondence from members of the public, MPs and other elected officials. 85 of these complaints came from members of the public while 38 pieces of correspondence were raised to the CCG by Members of Parliament and other elected officials acting on behalf of their constituents. Of the 85 complaints from members of the public, 19 were not formally investigated by the CCG.
This was due to: not receiving consent from the complainant in nine cases the investigation being led by an alternate NHS provider with the CCG being copied in for information in five cases the CCG not being the responsible commissioner in two cases the investigation being completed by NHS England into complaints about GP practices where the CCG were asked to monitor compliance with the recommendation to undertake a Significant Event Analysis (SEA) in two cases Of the 38 pieces of correspondence raised to the CCG by Members of Parliament and other elected officials acting on behalf of their constituents, six were responded to with advice that the CCG was not the responsible commissioner so was unable to comment on the issues raised. This means that the CCG investigated 66 complaints from members of the public and responded to 32 pieces of correspondence raised to the CCG by Members of Parliament and other elected officials acting on behalf of their constituents in the 2017/18 financial year, which is 98 in total. The majority of the 98 investigated complaints and correspondence raised to the CCG by Members of Parliament and other elected officials related to CCG actions or decisions. Subject of investigated complaints and elected official correspondence 13% 22% Both Provider and CCG Actions/Decisions CCG Actions/Decisions Provider Actions/Decisions 64%
Of the investigated complaints and correspondence raised by Members of Parliament and other elected officials that involved healthcare providers, the majority concerned Cheshire and Wirral Partnership NHS Foundation Trust, with East Cheshire NHS Trust the second most common and NWAS and GP practices the joint third. Providers involved in investigated complaints and elected official correspondence CWP ECT 5% 2% 2% NWAS 5% 5% 5% 37% GP Practice The Christie NHS Foundation Trust East Cheshire GP Out of Hours 7% Mid Cheshire Hospitals NHS Foundation Trust 7% NHS 111 Air Liquide 26% Stepping Hill Hospital NHS Foundation Trust
For the investigated complaints that related to actions or decisions taken by the CCG, the majority of these concerned the process and decisions made about whether individuals were retrospectively eligible for NHS Continuing Healthcare funding. The joint second most common themes were about changes made to the IVF commissioning policy and various prescribing commissioning policies. Concerns about Adult Mental Health Commissioning and the waiting times for children to receive Autism Spectrum Condition (ASC) and Attention Deficit Hyperactivity Disorder (ADHD) diagnoses were the joint third most common theme. Subject of complaints about CCG Actions/Decisions CHC Retrospective 1% 1% 1% 1% 1% 1% 1% 1% 1% 1% 1% IVF Policy Medicines Adult Mental Health Commissioning ASC/ADHD Waiting Times 2% 2% 4% 4% 7% 8% 29% 11% CHC Current IFR Process/Decision CAMHS Commissioning Podiatry Commissioning Primary Care Commissioning Talking Therapies Commissioning MSK Commissioning Monitoring of AIS compliance Cancer Commissioning Audiology Commissioning Cared For Children SALT/OT Commissioning 8% 11% Communications and Engagement Weight Management Commissioning Diagnostics Commissioning Freestyle Libre Commissioning Policy 4. Upheld Complaints
By the end of the 2017/18 reporting period, the investigation into 74 of the complaints and pieces of correspondence raised to the CCG by Members of Parliament and other elected officials has been completed. 19 of these complaints were upheld and 12 were partially upheld. The subjects of the upheld and partially upheld complaints are summarised in the below table: Subject of Upheld/Partially Upheld Complaints Percentage of Total CHC - Retrospective (Delays in processing/poor Communication) 23% Experience of care (ASC/ADHD Waiting Times) 16% Experience of care (Clinical care and treatment) 6% Experience of care (Delay in emergency ambulance) 6% CHC - Current (Delays in increasing care) 3% Experience of Care (Weight management pathway) 3% Experience of Care (Physiotherapy rehabilitation) 3% CCG Commissioning (Lynch Syndrome Testing) 3% Experience of Care (CAMHS transition and treatment) 3% CHC - Current (Communications and funding) 3% Experience of Care (Implementation of AIS) 3% CHC - Retrospective (Outcome) 3% Experience of care (NHS 111 care and information sharing) 3% Experience of care (Appointment timings compatibility with work) 3% Experience of care (Post-diagnostic autism services) 3% IFR (Decision) 3% CHC - Current (Advice re. recording of meetings) 3% CCG Commissioning (Cared for Children) 3% Experience of care (Audiology waiting times) 3% Grand Total 100.00% 5. You said, we did NHS Eastern Cheshire CCG is committed to ensuring that themes and issues identified in complaints are addressed and accompanied by changes that will prevent recurrence. The following examples demonstrate key changes and learning that have been implemented as a result of complaints in 2017-18. Learning implemented by the CCG NHS Continuing Healthcare Complaints: NHS Eastern Cheshire CCG receives complaints and correspondence from MPs and elected officials about the process of assessing individuals current eligibility to receive NHS Continuing Healthcare, as well as complaints about whether people were appropriately assessed for their eligibility in past periods (the majority of which took place before the CCG was a statutory body) which is known as the retrospective process. The fact that NHS Continuing Healthcare complaints remained the highest proportion of upheld complaints in the 2017/18 financial year shows some continuity from 2016/17 where this had also been the most common theme. NHS Eastern Cheshire CCG has however
seen a reduction in the number of upheld complaints about current assessments being undertaken of individuals current eligibility to receive NHS Continuing Healthcare. The Complaints, Concerns and Compliments team believes that this reduction in the number of upheld complaints for current assessments of individuals eligibility for NHS Continuing Healthcare is the outcome of the Service Transformation that was undertaken into the shared NHS Continuing Healthcare service delivered across the Cheshire and Wirral Clinical Commissioning Groups during 2016/17. This service transformation focused on ensuring that the process of assessing individuals current eligibility for NHS Continuing Healthcare was fully in line with national guidance. The Complaints, Concerns and Compliments team supported this service transformation by drawing upon previously upheld complaints findings to support with drafting new letter templates and a bespoke patient information leaflet to address common queries. Since these have been introduced, there have been far fewer upheld or partially upheld complaints about the standards of communication from the team responsible for assessing individuals current eligibility to receive NHS Continuing Healthcare. As it is not possible to change what took place in the past, the Complaints, Concerns and Compliments team expect that complaints about whether people were appropriately assessed for their eligibility in past periods will continue to be a common theme throughout the 2018/19 financial year. The Complaints, Concerns and Compliments team are however working closely with the team responsible for managing these retrospective claims to ensure that appropriate remedial actions are implemented to address these past failings, as well as sharing any findings from these retrospective cases that may be relevant to the team responsible for current assessments. ASC/ADHD Waiting Times: The waiting times for children to receive appointments for diagnosis of Autism Spectrum Conditions (ASC) and Attention Deficit Hyperactivity Disorder (ADHD) were the second highest number of upheld complaints. While this had been a common theme in the 2015/16 financial year, the CCG noted a reduction in the number of complaints about this area in the 2016/17 financial year after the investment approved in September 2015 led to an initial reduction in the waits. Unfortunately during 2017/18, the waiting times have increased again which has led to concerns raised by parents understandably worried about the impact that these delays are having on their children and wider family. In response to these complaints, the CCG has explained the reasons for the increased waiting times which have resulted from higher than planned numbers of new referrals, as well as difficulties in achieving the required staffing process. The CCG has also set out the plans it has to support the transformation of the wider Child and Adolescent Mental Health Service (CAMHS) which it hopes will address the waiting times for ASC and ADHD assessments. This has included the Associate Director of Commissioning holding meetings with complainants to listen and understand their experiences so these can inform the CAMHs transformation programme. Communicating changes to commissioning policies: During 2017/18, the CCG made changes to many of its commissioning policies. This resulted in a number of complaints about the changes made to its IVF policy. In response to these complaints, the CCG explained the rationale for why the changes had been made, as well as detailing the public engagement that had taken place prior to the changes to ensure that individuals were aware
of, and able to provide their opinions on the proposal. While recognising and empathising with the impact that these changes had on many patients, the CCG did not uphold the complaints as it felt its decision making process to amend the policy was open, transparent and in line with the appropriate process. The complaints investigations did however highlight an opportunity to supplement the Subfertility Policy with a two page Key Facts guide to support patients and clinicians in quickly understanding the revised eligibility criteria. This was therefore produced and published by the Complaints, Concerns and Compliments team on our website. Learning implemented by our providers Our providers have also implemented the following learning in response to concerns raised to the CCG: Audiology Waiting Times: East Cheshire NHS Trust acknowledged that demand for the Audiology service has led to prolonged waiting times which they are seeking to address by employing additional audiologists to increase the service s capacity. Awareness of Acute Kidney Injury (AKI): The East Cheshire GP Out of Hours Service held a presentation and training session for its staff about Acute Kidney Injury to support the service s knowledge and learning about this clinical presentation. Importance of clarifying medical terminology: East Cheshire NHS Trust has reminded staff on the paediatric ward to clarify the contents and diagnosis recorded on the discharge sheet with the child and their family to avoid any confusion or concern that may be caused when different medical terminology is used for the same condition. Delays in answering emergency ambulance calls: The North West Ambulance Service has recruited additional staff to answer 999 calls and is working with British Telecom to ensure 999 calls are answered promptly during periods of high demand 6. Parliamentary and Health Service Ombudsman (PHSO) If a complainant is dissatisfied with NHS Eastern Cheshire CCG s management of their complaint or feels that NHS Eastern Cheshire CCG has not resolved the issue, they have the right to refer their complaint to the Parliamentary and Health Service Ombudsman (PHSO). In 2017/18, NHS Eastern Cheshire CCG was not advised of any new referrals or investigations into its management of complaints by the PHSO. This compares to NHS Eastern Cheshire CCG being advised of two complaints being partially upheld and one complaint being upheld in the 2016/17 reporting period.