1. NHS Model Complaints Handling Procedure:
Adaptation for Community Pharmacy use
Adam Osprey
Community Pharmacy Scotland
Introduction
Results
In April 2017, new legislation which dictates the way in which complaints are received, processed and reported upon in the NHS and its contractors came into force.
Community Pharmacy Scotland (CPS) was made aware of this change at a late stage. Concerns were raised about the complexity of the national guidance provided and the considerable administrative burden placed upon individual contractors.
As the organisation which represents and supports community pharmacy owners in every aspect of their working lives, it was decided by the Board to commission support from the policy and development team in this matter.
The adapted guidance document produced as part of this project was deemed to be fit for purpose by the Scottish Public Services Ombudsman. The intended audience of community pharmacy contractors have provided feedback indicating that the guidance is concise and straightforward in comparison to the national guidance, supporting them to understand their duties and to establish systems and processes to ensure legal compliance.
The supporting materials produced have also received positive feedback, these are detailed below in Figure 1:
Once signed off by the CPS Board, the suite of resources was published on Community Pharmacy Scotland’s public website, enabling open access to the materials. This release was accompanied by sustained social media activity and a blog to maximise awareness and uptake.
Template letters to be used in communication with the complainant
Concise public-facing materials for display in pharmacies
Template complaint form designed to capture all necessary fields
Spreadsheet designed to produce all data required for quarterly reporting on entry of minimal information about complaints received
Standard reporting statements to ensure legal compliance
Aims
Community Pharmacy Scotland sought to interpret and distil the information provided by the Scottish Government for the benefit of pharmacy contractor owners and teams in order that they understand and are able to discharge their duties under the Patient Rights Act with as little impact upon service provision as possible.
Methods of reducing the administrative burden of recording and reporting were to be investigated.
Figure 1. Supporting Materials
Methods
All materials were taken to the CPS Board for signoff.
These were tested with dummy complaints data to ensure that the output was legally compliant in advance of the legislation’s go-live date in April 2017.
The regulations and directions were then used to create a suite of support materials to support day-to-day implementation of the new procedures whilst ensuring legal compliance.
This was then taken to the Scottish Public Services Ombudsman (who were involved in the development of the regulations and the national guidance) to ensure that it was fit for purpose and there were no omissions or errors in the information retained and rewritten.
Once this was completed the resultant document was tested for clarity in a small user group whose feedback was used in producing the final version.
The regulations and directions were used to adapt the national implementation guidance for community pharmacy use, removing sections which were deemed to be surplus to legal requirements and distracted from relevant content.
The new Patient Rights (Feedback, Comments, Concerns and Complaints)(Scotland) regulations and directions were sourced.
Conclusions
The adapted guidance and support materials enable contractors to capture all legally required information and was well received by the community pharmacy network and the Health Boards which they operate in.
The first cycle of complaints recording under new legislation is now complete, and views on ease of use will be sought from contractors and Health Board colleagues once the reporting deadline has been reached.
The guidance and support materials will then be modified in line with feedback given where possible and republished for use in future cycles.
By producing these materials, CPS have succeeded in minimising the administrative burden placed on the community pharmacy network by legislative changes.
Acknowledgements
Scottish Public Services Ombudsman
CPS User group