Complaints Resolution
Independent complaints resolution
Verita is a specialist consultancy that works with regulated organisations in the private and public sector in the UK and overseas. We have over 15 years of experience, an extensive pool of expert advisors and the assurance of tried and tested methodologies. We specialise in supporting organisations to support complaints processes through independent review.
Verita is experienced in dealing with all areas of complex complaints. Our complaints resolution process falls under a number of headings:
- Acting as a (Stage 3) reviewer of complaints for organisations such as the Arts Council, British Council, Sport England and the National Lottery Community Fund
- Carrying out annual reviews of complaints processes and proposing improvements for organisations such as the Civil Aviation Authority and General Medical Council
- Supporting organisations to remove complaints backlogs (on an ad-hoc basis)
- Providing training in complaints processes
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As an independent reviewer of complaints, we take referrals of issues that have exhausted the internal processes of organisations. Typically, we produce a report which is sent to both parties giving our evaluation. We provide advice on any flaws in how the complaints process was carried out.
Verita provided an annual independent customer complaint review service to the General Medical Council for four years. In this role, we reviewed the quality and consistency of complaints handled by the GMC about its service, including failure to meet service standards. In this time, we provided the GMC with outputs that were fit for purpose, proportional to the needs of the organisation and provided targeted and actionable improvements. We identified areas where improvements could be made to aid the GMC in delivering the best possible service to its customers. We are pleased to see that a significant number of improvements have been implemented in subsequent years following our suggestions. We worked closely and efficiently with the GMC to deliver work of a consistently high standard to required deadlines.
We have extensive experience of complaint resolution within NHS trusts, with many hundreds of individual complaints across multiple organisations now cleared, many of which were extremely complex and dating back months or even years. We reviewed trust’s complaints systems and suggested new models of working to improve the efficiency and quality of their systems. We have done this with the use of Verita’s bespoke ‘Complaint Handling Diagnostic Tool’, which provides a robust, repeatable basis for ensuring consistency and completeness in our reviews.
Why use a team rather than an individual?
Independent complaints adjudication can be carried out by teams or individuals. Verita has put together a highly skilled team to work on complaints adjudication. We believe that there are compelling reasons why it is best to use an organisation which can field a team for this kind of role, particularly when potentially contentious issues are involved. The reasons include:
- The benefits of a ‘Peer Review’ process – all Verita reports are reviewed by a senior colleague before completion. The process may challenge fundamentals (such as whether the report’s analysis is valid), or simply whether the argument is clear and easy to follow. It is difficult for someone who is steeped in the evidence of a case to retain the perspective of someone reading it fresh. In our experience, no report fails to be improved by this checking process.
- Resilience of the process – using a team approach means that our work can continue despite holidays or illness. Our approach would also enable us to increase the number of complaints we can review if there is a rise in cases. We have the capacity to deliver reviews of an increased number of cases if the need should arise.
- The ability to talk through difficult issues with teammates – in our experience complaints often raise difficult issues on which different perspectives are possible. Only by talking through the issues with colleagues can all perspectives be understood, and issues considered in the round.
Essential Elements of Independent Complaint Handling – the Verita View
Experience of complaints management – as our corporate CV sets out, we have extensive high-level experience of the independent review of complaints and of testing processes and making recommendations for improvement. Verita is a trusted partner in this field across government, regulated organisations and the private sector.
Knowledge of the principles of good governance and good administration – organisations such as government departments and public bodies have appointed us to review and advise their governance processes because of our deep knowledge of governance and administrative principles.
Understanding of the views, and delivering services to, a diverse range of users – across Verita’s work we engage with service users, managers and staff. For example, we have extensive experience of carrying out sensitive investigations in the NHS, often working with bereaved families who have concerns about the care received by their relatives or with professional staff who work in sensitive roles.
In our complaints handling work we are used to working with a wide variety of complainants. Making them feel that they have been listened to is a key part of the process and essential if it is to have any value – it is not possible to guarantee a finding that it acceptable to the complainant, but essential to make them feel that they have had a fair hearing.
Experience of driving continuous improvement and promoting change – in our experience it is rare for there to be a complaint, but no learning. This applies to complaints that are rejected just as much as those that are upheld. For a customer to feel that they need to complain is a strong indication that something is not right.
Even if the complaint is based on a misunderstanding, that suggests that communication could be clearer. Our portfolio of investigations and reports demonstrates our understanding that the ultimate purpose of this process is to deliver a better service.
Proven leadership and management skills, and experience of reporting at Board level – Verita’s reports often deal with the most sensitive and important issues. We frequently have to make difficult decisions on the interpretation and analysis of evidence and subsequently present the outputs at the highest level – whether to Boards, regulators or government departments. We manage our projects carefully to ensure that they meet the requirements of clients as to issues such as timeliness and budget.
Strong analytical, critical reasoning and judgement skills – much of our work deals with complex issues. We have a track record of weighing the most complex evidence to pull out the key issue and make reasoned judgements. For example, we recently carried out a review of a governance issue for the NHS. When it was read by the then chief executive of the NHS he asked that it be disseminated across the organisation so that the lessons could be fully understood.
Proven strong interpersonal, ambassadorial, and negotiating skills – complaints can provoke a lot of emotions, whether in the person complaining or in the organisation being complained about. We have a great deal of experience of working with people in difficult circumstances to enable them to tell their story and feel that they have been heard.
The outcomes of our work often deliver a result that differs from what they wanted. Being able to persuade those involved nonetheless is something we take particular pride in.
Proven ability to communicate clearly with a diverse range of people – it is an essential part of a fair complaints process that all those involved feel that they are able to have their voice heard, whatever their background. Within the health sector we have dealt with a full range of cases, some of which involve people with learning disabilities.
In other cases we have dealt with issues relating to discrimination – whether relating to race, sex or sexual orientation. We have a long record of making people feel that we understand what they are saying and will give them a ‘fair hearing’.
Demonstrable commitment to promoting equality, diversity and inclusion – fairness lies at the heart of a complaints process. That means giving all parties the opportunity to put their case. For all kinds of reasons people may need support in order to do that.
Our track record demonstrates ability to do that. We believe that this is also a benefit of team working – no two people have the same life experience, so the challenge of colleagues can help to ensure that the process is fully inclusive.
Knowledge of the wider Ombudsman landscape and the regulatory framework – in our work for lottery providers we stand as an intermediary level of appeal between internal mechanisms and the Parliamentary & Health Service Ombudsman.
If the complainant is unhappy with our findings they retain the right to appeal to that Ombudsman and a number of our reports have been subject to that review. We therefore strive to ensure that our work meets their standards. Over the 10 years we have carried out this service, we have never been criticised by the Ombudsman.
Key Staff
We take a team approach to the investigation of complaints. Our practice is to appoint a lead investigator, with their work peer reviewed by another member of the team before being issued. Team members include:
Peter Killwick
For the last 25 years, Peter has worked in consulting covering a variety of strategic and operational issues in a wide range of sectors including healthcare, automotive, financial services, manufacturing, retail, telecommunications and government. Peter has extensive complaints handling experience and was the designer of Verita’s Complaint Handling Diagnostic Tool. He is the primary contact for the British Council contract, and so plays a key role in developing their process improvement actions, screening referred complaints for suitability for independent review and then leading the work for those complaints that we investigate. A company director of Verita, Peter Killwick would have overall responsibility for the contract and oversee all aspects of the work. He will act as the primary point of contact for Frontline if you choose to commission Verita for this work.
Kieran Seale
Prior to joining Verita he had a varied career including working in the planning department at London Transport, in local government and in the private sector. Kieran spent five years working in governance roles NHS commissioning in Primary Care Trusts and Clinical Commissioning Groups (CCGs), which included management of complaints processes. Legally qualified, he has wide experience of delivering solutions to governance issues in the NHS and outside. Kieran leads Verita’s complaints work with organisations including Sport England, Arts Council and Heritage Lottery Fund. He has been guest speaker at a number of complaints conference and has designed and delivered complaints management training for NHS bodies.
Chris Brougham
Chris is one of Verita’s most experienced investigators and has conducted some of its most high-profile investigations and reviews. As head of training, Chris has developed courses on how to carry out a systematic incident investigation for serious incidents and complex complaints. Chris has delivered these courses across a range of organisations and sectors and consistently receives excellent feedback.
David Scott
David Scott is an experienced human resources director, having worked at Board/Executive level for more than 20 years, including senior positions at British Telecommunications plc, HM Prison Service and United Utilities plc. David has worked on a number of high profile investigations with Verita including an independent review into an NHS trust’s disciplinary process of a nurse and an independent review into the conduct of a nurse for NHS England.
Nicola Salmon
Nicola is a senior consultant having worked at Verita for four years. Nicola has conducted patient care reviews for acute and mental health NHS trusts and investigated human resources and governance issues for clients such as Public Health England, NHS England and The Open University. She has also carried out complaint audits for the GMC and the CAA. She has worked with Ed Marsden and Kate Lampard on a review of an immigration removal centre for G4S.
Informal resolutions
The Verita Process
When carrying out complaint investigations we follow a rigorous process to ensure that outputs are independent and of high quality.
Initially we assign an investigating officer to evaluate the complaint and determine whether there is a case to answer. The investigating officer reviews the information available and speaks to the complainant to ensure that we have a full understanding of the issue. Typically, we evaluate the eligibility of a complaint against a set of agreed criteria and use a proforma to determine if an investigation is within the scope of our mandate and in the interests of all parties to investigate. This decision is reviewed internally by a senior manager to ensure consistency and objectivity.
If the complaint proceeds to investigation, we will draft Terms of Reference for agreement, we will then gather further evidence by requesting documentation or interviewing those involved (the extent of the investigation carried out depends on the complexity of the individual case).
As complaints are identified with areas of specialism we will ensure the chosen investigator has the relevant experience for the case. Where cases require investigators to have specialised training such as bullying and harassment or sexual harassment, an appropriately trained investigator will take on the case. This ensures that the investigation is thorough, and that the complaint is dealt with appropriately. We will complete these evaluations and investigations in a timeframe to be agreed with the client.
We believe that we have the experience and the knowledge to deliver an open and impartial independent complaint review service that treats both parties fairly and in accordance with the law and the principles of natural justice.
Accommodating Differences
We have conducted many cases where accommodating differences was necessary. We always ensure that reasonable accommodations and adjustments are made to meet any additional requirements.
As an example, a recent complaint investigation involved a complainant who had special requirements including difficulty with responding in writing. Face to face meetings were not included in the normal scope of work, however, in this case, we identified that a meeting would be a reasonable adjustment for this complainant and agreed with the client that we would do so. By accommodating differences within our scope of work, we were able to adjust our practice and meet the complainant in her home. Offering the complainant an opportunity to meet face to face led to a positive working relationship throughout the process.
Given that much of our work is in healthcare, we often work with people with physical or mental health requirements. We understand the importance of listening and responding to the needs of others and accommodate appropriate changes and adjustments where possible.
Commercial Considerations
Verita is transparent at all stages of an assignment with regards to costs. We only charge for the things that we do and do not surprise clients with large hidden costs. If in any given year we do not conduct any investigative work, the cost will be zero. If over the course of an assignment expenses are incurred, we will comply with internal policies. At the outset of every assignment, we will assess the scope of work and provide an estimate of fees for that assignment.
Verita provide a complaints handling training course for organisations, where we will come to your offices to conduct the training.
If you need independent support with resolving complaints within your organisation, please contact Verita founder Ed Marsden at [email protected]
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If you would like to read more about the work that Verita has done in relation to complaints resolution, please click on the additional articles below: