Review of the NHS Complaints Procedure: Health Inequalities Impact Assessment

The final report of the Health Inequalities Impact Assessment of the changes proposed to the NHS complaints procedure.

3. Key findings

Overall, the stronger focus on early resolution was considered to have a potential positive impact on equalities groups. One underpinning principle of the model complaints handling procedure is to resolve complaints at an early stage, wherever that’s appropriate, to avoid prolonging the possible distress associated with submitting a complaint to a health provider. The revised procedure seeks to open communication channels at an early stage, acknowledging the needs of all protected characteristic groups in a non-discriminatory manner. This approach will support organisations to foster good relations with those who use their services. It will help to build relationships between people using services and those providing them, which will support services to make changes and improvements based on open feedback.

The sharper focus on communication and, where possible, resolution at an early stage does present challenges, particularly in relation to communications, which are recorded below in relation to various protected characteristics.

The new, model complaints handling procedure is intended to support a more consistent, rigorous and systematic approach to recording and reviewing complaints, with a view to acting on this feedback to improve services. If it is not effectively implemented, and the recommendations and action points effectively taken forward, there is a risk that health inequalities could increase, as services would reflect the voices only of those who felt able to complain

Age: Children and young people may prefer to contact services using social media. Older people with a cognitive impairment may require additional support to make a complaint.

Disability: People with a disability may need access to additional support to make a complaint.

Gender reassignment: Failure to recognise transgender people as the sex they identify as may impact negatively on the successful early resolution of their complaint.

Pregnancy and Maternity: Some people in this category, especially those living in rural areas, may be reluctant to make a complaint at all, due to concerns that this may impact on the future relationship with a care provider. Others may need additional reassurance that their concerns will be taken seriously.

Race and Ethnicity: No specific concerns were identified, although it was recognised that non-English speakers may face additional challenges in making their complaint at early resolution stage.

Religion and belief: The sex of the person making the complaint, and that of the person they are complaining to or about, may be an issue for some faith groups.

Sex: The procedure needs to accommodate people who may have had a negative experience with a healthcare professional of a specific sex and wish someone of the opposite sex to deal with their complaint. Aligned with this is the consideration of gender- based violence, and the need to ensure that the person dealing with a complaint is the appropriate sex.

Sexual Orientation: Staff attitude and behaviours, if not supportive, can be a barrier to LGBT individuals complaining. A particular positive impact was identified for this group, that the inclusion of anonymous complaints may make it easier for someone to complain.

Looked after (including accommodated) children and young people: A particular positive impact was identified for this group, that early resolution may help to relieve children’s concerns that their complaint will not be considered and acted upon. Children who are looked after and accommodated may find the new process of early resolution less intimidating than the previous system, and may therefore be more likely to engage with the NHS to raise a complaint.

Carers: Carers may find it hard to make time to engage, even at the early resolution stage. Child carers may be fearful their complaint will be dismissed.

Homelessness: A particular positive impact was identified for this group, that early verbal resolution may negate the need for written materials being sent to an address.

Involvement in the criminal justice system: The stronger focus on early resolution is intended to support prison health services to resolve complaints locally, improving wait times for prisoners. Prisoners may, however, experience difficulty accessing independent advice and support.


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