Complaints diagnostic for an NHS acute trust – compliance issues

Complaints diagnostic for an NHS acute trust – compliance issues

The client

An acute trust – Healthcare


Complaint Handling and Compliance Concerns.

An acute trust with a growing backlog of complaints and an impending visit from the Care Quality Commission (CQC) was concerned about its ability to meet national targets and CQC regulations. Our challenge was to find out why the backlog had built up and whether the trust needed to change the way it managed complaints in order to improve performance.


Robert Francis QC’s report into failings in care at Mid Staffordshire NHS Foundation Trust was published in February 2013. The report highlighted that complaints are potential warning signs of problems arising within a hospital.

The Government published its full response to the Francis report in November 2013. In its response, entitled ‘Hard Truths’, the Government announced that there will be greater senior staff involvement in complaints handling.

As part of the Government’s response to the Francis report Rt Hon Ann Clwyd and Professor Tricia Hart were commissioned by the Secretary of State for Health to lead a review into the NHS complaints handling process. Additionally, Professor Don Berwick, an expert in patient safety, was asked by the Prime Minister to carry out a review following the publication of the Francis Report.

Our complaints diagnostic assessment is based on our experience of working with trusts to clear backlogs of complaints and redesign systems that handle them. It also takes into account ‘best practice’ in complaints – taken from trusts who demonstrate strong systems and processes and high complainant satisfaction. The trust commissioned us to review their system given our experience and the climate of increased scrutiny on complaints handling.


Our team, Amber Sargent and Peter Killwick, used our complaints diagnostic tool to help the trust identify strengths and weaknesses in their system for managing complaints, target improvements, encourage learning and benchmark performance against peers.

The diagnostic assessment used a combination of targeted group discussions and one-on-one interviews to investigate performance across key indicators such as board recognition, staff engagement, complaints team design, learning, patient experience and system efficiency and quality. Our interviewees included the trust chair, representation form PALS, the head of complaints, the chief nurse and clinical services managers.

We reviewed board meeting minutes, patient experience reports, the complaints policy, the complaints team structure, evidence of compliance with CQC outcome 17, the complaints handling flowchart and a sample of complaints and their responses.

Our assessment was completed within two and a half days.


We were able to identify key areas in which the trust needed to focus its attention in order to improve its handling of complaints. We found weaknesses in trust processes for embedding change, governance and resourcing.

We also found that the trust was using an old version of a patient safety system which was hindering performance.

We found that in general complaints were being heard and changes were being implemented as a result.


Our recommendations involved encouraging a more systematic approach to handling and learning from complaints, as well as ensuring that a clear governance structure was put in place in order to provide an organisation-wide review of the way resourcing were being allocated within the complaints management system.


We calculated that with existing staffing levels, productivity levels and the rate of complaints, the trust would always have a backlog of over 130 complaints a year. We therefore recommended that the trust explored the use of the PALS service (in line with recommendations from the Clwyd review) and employed a part-time member of staff to clear the backlog and prevent future backlogs.