POLICIES
Complaints and Feedback Policy
Policy Title: Complaints and Feedback Policy
Author: Clare Connolly
Date: 16/04/2025
Review Date: 16/04/2026
1. Scope of Application
This Complaints and Feedback Policy applies to all patients and stakeholders interacting with the independent practitioner clinic. It provides the framework for addressing patient complaints, concerns, and feedback about the clinic’s services, ensuring that all issues are handled promptly, fairly, and transparently.
As the independent practitioner, you are responsible for managing and addressing complaints effectively, ensuring that patients feel heard, valued, and supported throughout the process. This policy also outlines how feedback is used to improve clinic services, ensure continuous improvement, and maintain a high level of patient satisfaction.
2. Purpose and Objective
The purpose of this policy is to establish clear guidelines for managing complaints and feedback in a manner that is respectful, efficient, and effective. The objectives of this policy are:
● Ensure Timely Response: Ensure that all complaints and feedback are acknowledged and addressed in a timely manner, in accordance with best practice guidelines.
● Maintain Patient Satisfaction: Ensure that patients feel heard and valued, and that their concerns are taken seriously. Address complaints with the goal of resolving issues to the patient’s satisfaction.
● Promote Continuous Improvement: Use feedback from patients, including complaints, to identify areas of improvement in clinic services and patient care, fostering a culture of ongoing improvement.
● Adhere to Regulatory Standards: Ensure that the clinic complies with relevant Care Quality Commission (CQC) regulations, Nursing and Midwifery Council (NMC) standards, and other legal frameworks governing patient care and complaints management.
3. Legal and Regulatory Framework
This policy complies with the following regulations and standards to ensure that complaints and feedback are managed effectively and in accordance with the law:
● Health and Social Care Act 2008 (Regulated Activities) Regulations 2014: This Act requires healthcare providers to have a clear, transparent process for managing complaints, ensuring that patients can voice their concerns and have them addressed appropriately.
● Care Quality Commission (CQC): The CQC requires healthcare providers to have an accessible, fair, and responsive complaints procedure. The CQC also expects healthcare providers to take feedback seriously and use it to improve the quality of care.
● Equality Act 2010: This Act mandates that patients should not be discriminated against when raising a complaint or providing feedback. The clinic’s complaints process must be fair, transparent, and accessible to all patients, regardless of their background, status, or personal characteristics.
● Nursing and Midwifery Council (NMC) Code (2018): The NMC Code requires nurses to provide compassionate, patient-centered care and to handle complaints appropriately, ensuring that patients are respected and their concerns are addressed in a timely manner.
● General Data Protection Regulation (GDPR): Any information collected during the complaints process must be handled in accordance with GDPR guidelines, ensuring patient privacy and confidentiality.
4. Complaints Procedure
The clinic is committed to ensuring that all complaints are addressed in a fair and structured manner. The complaints procedure is as follows:
Step 1: Acknowledgement of the Complaint
● Timely Acknowledgement: All complaints should be acknowledged within two working days of receipt. An initial response should include confirmation that the complaint has been received and is being investigated, as well as an outline of the process and timeline for resolution.
● Clear Communication: The clinic should inform the patient of the process involved in addressing their complaint, including the expected timeline for resolution and who will be handling their complaint.
Step 2: Investigation
● Thorough Investigation: Complaints should be investigated thoroughly to understand the issue fully. This includes gathering information from relevant parties, reviewing clinic records, and any other materials pertinent to the complaint.
● Impartiality: Ensure that the investigation is impartial, and that the patient’s complaint is reviewed objectively. If necessary, involve an independent third party for an unbiased assessment.
● Confidentiality: All complaints must be handled confidentially to protect the privacy of the patient involved. Ensure that the investigation respects the principles of GDPR, safeguarding patient data throughout the process.
Step 3: Resolution
● Timely Resolution: Complaints should be resolved as promptly as possible, with an aim to resolve the issue within 20 working days from the date of acknowledgment. In cases where this timeline cannot be met, the patient should be informed of the delay and the expected new timeline.
● Communication of Findings: Once the complaint has been investigated, the patient should be informed of the findings and any actions taken to address their concerns. This communication should include any corrective measures, changes to procedures, or steps taken to prevent similar issues from arising in the future.
Step 4: Follow-Up and Feedback
● Patient Satisfaction: After the complaint has been resolved, follow up with the patient to ensure that they are satisfied with the resolution. This also provides an opportunity for the patient to provide additional feedback on how the process could be improved.
● Continuous Improvement: Use feedback from the complaints process to evaluate and improve clinic services. Implement any necessary changes to procedures, staff training, or patient care practices to prevent recurrence of similar issues.
5. Handling Unresolved Complaints
In some cases, complaints may not be resolved to the satisfaction of the patient. If this occurs:
● Escalation Process: The patient should be informed of their right to escalate their complaint to the Care Quality Commission (CQC) or other relevant bodies. Provide the contact details for the CQC and explain the formal complaints process.
● Mediation: If the complaint remains unresolved, the clinic may suggest using an independent mediator to facilitate a resolution.
6. Feedback Mechanism
In addition to handling complaints, the clinic encourages all patients to provide feedback on their experience. This feedback helps to improve services, identify areas of success, and make necessary adjustments.
Feedback Channels
● Patient Satisfaction Surveys: Use patient satisfaction surveys to gather feedback on the quality of care, the clinic’s environment, and patient experience.
● Anonymous Feedback: Provide opportunities for patients to submit anonymous feedback, ensuring that patients feel safe to voice concerns without fear of retaliation.
● Direct Feedback: Encourage open communication, allowing patients to provide feedback directly during consultations or through follow-up calls or emails.
Using Feedback for Improvement
● Review and Action: All feedback, both positive and negative, should be reviewed regularly and used to inform improvements in clinic services. This may include revising treatment protocols, improving patient communication, or making changes to clinic operations.
● Transparency: Patients should be informed of any changes made as a result of their feedback, ensuring that they see the impact of their input on clinic services.
7. Confidentiality and Data Protection
Any information related to complaints and feedback will be handled with the utmost confidentiality and in accordance with the General Data Protection Regulation (GDPR). This includes:
● Patient Privacy: Personal details and information related to the complaint will only be shared with those directly involved in resolving the issue, unless the patient consents to broader disclosure.
● Secure Storage: All complaints and feedback documentation will be securely stored in compliance with GDPR regulations to protect patient data.
● Retention of Records: Complaints records will be retained for a specified period of time (as required by regulation or clinic policy) and securely disposed of when no longer needed.
8. Roles and Responsibilities
Independent Practitioner
As the independent practitioner, you are responsible for:
● Managing Complaints: Receiving, acknowledging, investigating, and resolving complaints promptly and fairly. Ensuring that patients are informed of the process and the timeline for resolution.
● Implementing Changes: Making necessary changes to clinic practices based on feedback and complaints, ensuring that patient care and services are continually improved.
● Maintaining Confidentiality: Ensuring that all complaints are handled confidentially, and that patient data is protected in line with GDPR guidelines.
Patients
Patients have the responsibility to raise any concerns, complaints, or feedback regarding their care. They should feel comfortable knowing that their voice will be heard, and that they will not face any retaliation for providing feedback.
9. Monitoring and Compliance
To ensure compliance with this policy, the independent practitioner will:
● Conduct Regular Reviews: Regularly review the clinic’s complaint handling procedures to ensure they are being followed and that patient satisfaction is being maintained.
● Audit Complaints and Feedback: Periodically audit complaints and feedback to identify recurring issues, patterns, or trends. This information can help to improve patient care and address systemic issues within the clinic.
● Staff Training: Ensure that all necessary staff members are trained in the complaints and feedback process and are aware of the importance of handling patient concerns with care and professionalism.
10. CQC Cross-Reference Table
CQC KLOE
Policy Section
Regulatory Reference
Safe (S1)
Patient Feedback and Handling Complaints
Health and Social Care Act 2008 (Regulated Activities) Regulations 2014
Effective (E1)
Ensuring Timely Resolution of Complaints
Care Quality Commission (CQC) Regulations
Responsive (R1)
Addressing Patient Concerns and Feedback
CQC Regulations, Equality Act 2010
Well-Led (W1)
Leadership in Complaints Management
CQC Leadership and Governance KLOE, NMC Code (2018)
11. References
● Health and Social Care Act 2008 (Regulated Activities) Regulations 2014
● Care Quality Commission (CQC) Regulations
● General Data Protection Regulation (GDPR)
● Nursing and Midwifery Council (NMC) Code (2018)
Chaperone Policy
Policy Title: Chaperone Policy
Author:Clare Connolly
Date15/04/2025
Review Date:15/04/2026
1. Scope of Application
This Chaperone Policy applies to all consultations, examinations, and procedures carried out at the independent practitioner clinic where the presence of a chaperone may be required to ensure the comfort, safety, and dignity of the patient. As the independent practitioner, it is your responsibility to offer a chaperone when appropriate and ensure the patient’s preferences and safety are respected. Since there are no staff members at the clinic, the role of the chaperone may be taken up by a trusted third party (e.g., a family member, friend, or legal guardian).
2. Purpose and Objective
The primary purpose of this policy is to ensure that patients feel safe and respected during clinical examinations or procedures, particularly in intimate or sensitive situations. The objectives of this policy are to:
● Provide Patient Comfort and Safety: Ensure that patients feel comfortable and protected during consultations or procedures that may require intimate examinations.
● Ensure Professional Conduct: Promote professional behavior during consultations, protecting both the patient and the practitioner from potential misunderstandings or false allegations.
● Comply with Regulatory Requirements: Ensure the clinic adheres to best practice guidelines set by professional regulatory bodies, including the NMC, GMC, and CQC.
3. Legal and Regulatory Framework
This policy complies with the following regulations and guidelines:
● The Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 – Requires healthcare providers to ensure that patients are treated with dignity and respect and that appropriate safeguards, such as chaperones, are in place during sensitive procedures.
● NMC Code (2018) – The Nursing and Midwifery Council (NMC) Code emphasizes the importance of maintaining patient dignity, providing professional care, and involving patients in decisions regarding their care, including the offer of a chaperone.
● GMC Good Medical Practice (2013) – The General Medical Council (GMC) guidelines recommend offering a chaperone during intimate examinations to ensure that patients feel safe and that professional boundaries are maintained.
● Care Quality Commission (CQC) – The CQC requires healthcare providers to ensure that practices like chaperoning are in place to support patient safety and well-being.
4. Chaperone Role and Responsibilities
What is a Chaperone?
A chaperone is a person who is present during a consultation, examination, or procedure to ensure that both the patient and the healthcare professional are protected, and that the patient feels comfortable. The chaperone's role is to:
● Provide emotional support to the patient during intimate or sensitive examinations or procedures.
● Observe the practitioner’s actions to ensure that they are professional, appropriate, and respectful.
● Provide reassurance to the patient and help them feel more comfortable during the examination.
When Should a Chaperone Be Offered?
A chaperone should be offered to patients during any consultation or procedure that involves intimate physical contact. This includes, but is not limited to:
● Examinations: Physical examinations of sensitive areas, including chest, abdomen, pelvic, or genital examinations.
● Procedures: Any clinical procedure that involves the intimate examination or treatment of the patient.
● Vulnerable Patients: Offering a chaperone to vulnerable patients, such as minors, individuals with cognitive impairments, or patients who may feel uncomfortable or unable to voice concerns.
Chaperone Options
● Patient's Own Chaperone: Since you are an independent practitioner with no staff, patients will be asked to bring a trusted individual (family member, friend, or guardian) to act as a chaperone during intimate examinations or procedures.
● Independent Practitioner as Chaperone: In cases where the patient does not have someone they trust to act as a chaperone, you, as the independent practitioner, should assess if it is possible to proceed with the procedure without one, or whether a referral to a clinic with staff should be considered.
5. Procedure for Offering a Chaperone
Offer to All Patients
A chaperone should be offered to all patients prior to any procedure or examination that may require intimate contact. The offer should be made clearly, and the patient’s consent should be obtained. The process should include:
● Ask: Ask the patient if they would like a chaperone to be present during the examination or procedure.
● Explain the Role: Explain the role of the chaperone to the patient, including the fact that the chaperone is there to ensure their comfort and safety, and to observe the examination for professional integrity.
● Obtain Consent: Ensure that the patient consents to the presence of the chaperone. If the patient refuses, this should be documented in their clinical records, and you should assess whether it is still appropriate to proceed with the examination without a chaperone.
Document the Offer
The offer of a chaperone, the patient’s response, and the details of the chaperone present should all be documented in the patient’s clinical records. This documentation ensures that the clinic can demonstrate that patient preferences were respected and that professional boundaries were maintained.
6. Chaperone Guidelines for Patients' Own Chaperone
When a patient chooses to bring their own chaperone, the following guidelines should be followed:
● Confidentiality: Ensure that the chaperone understands the importance of confidentiality and that any information related to the examination or procedure should not be shared with others unless permitted by the patient.
● Appropriate Conduct: The chaperone should be expected to remain neutral, respectful, and supportive throughout the consultation. They should not interrupt the examination or procedure, but should offer emotional support as needed.
● Sign in the Clinical Records: The chaperone’s identity and the fact that they were present during the consultation or procedure should be documented in the patient’s clinical records.
7. Chaperone for Vulnerable Patients
For patients who may be vulnerable (e.g., minors, individuals with cognitive impairments, those who may be at risk of exploitation), the practitioner must:
● Always Offer a Chaperone: A chaperone should always be offered, regardless of the nature of the procedure or examination.
● Consider the Patient’s Comfort: The practitioner should be particularly sensitive to the patient’s needs and ensure that the chaperone’s presence helps the patient feel safe and supported.
● Involve Parents or Guardians: For minors or individuals with cognitive impairments, it may be appropriate to involve a parent, guardian, or legal representative as a chaperone.
8. Roles and Responsibilities
Independent Practitioner
The independent practitioner is responsible for:
● Offering Chaperones: Ensuring that chaperones are offered during appropriate consultations and procedures, and that the patient’s consent is obtained.
● Training: While no staff are present, the independent practitioner should ensure that they themselves are trained in professional boundaries, patient communication, and maintaining safety during intimate examinations.
● Documenting Chaperone Use: Ensuring that the use of chaperones is documented in patient records, including the patient’s response and the chaperone’s identity.
Patient
Patients are responsible for:
● Making Their Choice Known: Patients should clearly communicate their preference regarding the presence of a chaperone.
● Understanding the Role: Understanding the role of the chaperone and how it contributes to their safety and comfort during the procedure.
9. Monitoring and Compliance
As an independent practitioner, it is essential to regularly monitor compliance with this policy by:
● Regular Audits: Conducting audits to ensure that chaperones are being offered appropriately and that patient preferences are being respected.
● Feedback: Collecting feedback from patients about their experiences with chaperones and ensuring that any concerns are addressed promptly.
10. CQC Cross-Reference Table
CQC KLOE
Policy Section
Regulatory Reference
Safe (S1)
Offering and Using Chaperones
NMC Code (2018), GMC Good Medical Practice (2013)
Caring (C1)
Patient Dignity and Comfort
Care Quality Commission (CQC) Regulations, GMC Good Medical Practice (2013)
Well-Led (W1)
Professional Boundaries and Documentation
CQC Leadership and Governance KLOE, NMC Code (2018)
Effective (E1)
Patient Safety and Comfort
Health and Social Care Act 2008 (Regulated Activities) Regulations 2014
11. References
● Health and Social Care Act 2008 (Regulated Activities) Regulations 2014
● NMC Code (2018)
● GMC Good Medical Practice (2013)
● Care Quality Commission (CQC) Regulations
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