Data on Written Complaints in the NHS - 2020-21 Quarter 3 and Quarter 4

NHS Digital continues to review and evaluate the data to ensure that it is an accurate reflection of the number of complaints made to the NHS. Factors which could affect the numbers of complaints organisations record include:

• Whether processes are in place to resolve potential and verbal complaints before they escalate to written complaints. These include organisations making staff available to discuss and resolve issues. (Complaints made verbally should be included if they are recorded, investigated and a response provided).
• Staff making patients aware of services such as the Patient Advice and Liaison Service (PALS). This aims to ensure the NHS listens to patients, their relatives, carers or friends, and answers or resolves questions and concerns as quickly as possible. They provide information about the NHS complaints procedure and how to get independent help if a further complaint is being considered.
• The extent to which organisations highlight the complaints procedures/processes to patients. This can be through a variety of methods including leaflets, poster adverts and direct discussions with patients. Improved awareness of the written complaints process may lead to more patients making complaints.
• Interpretation of guidance as to which complaints to include on the KO41a may vary between organisations. These can include how informal complaints, concerns or withdrawn complaints are dealt with or recorded by organisations.

The changing nature of NHS organisations that provide NHS services means that care must be taken when comparing data at organisation level across a time series. NHS Digital produce a Data Quality Annex to accompany the monthly NHS workforce publications. This details issues that NHS Digital is aware of that may affect the monthly NHS workforce publications and could be useful in understanding organisation changes affecting NHS complaints data.

Independent Healthcare Provider – NHS England region allocation

Some Independent Healthcare Provider organisations offering NHS services are included within these data tables. These services may over time, be provided beyond the geographical area they have been assigned to in relevant tables. These data are kept under review and a decision of where to allocate such providers is taken at the beginning of each financial year. Where it is clear providers are offering services beyond one NHS England region these organisations may be reclassified as ‘Other’ rather than in a single geographical region.

Data items

Data are available at organisation and site level, and summarise new complaints received within the quarter by resolution status. New complaints are split into:

• Age band of patient
• Status of complainant
• Service areas
• Subject areas (including clinical treatment areas)
• Professional groups

The data is collected using NHS Digital’s Strategic Data Collection System (SDCS), a secure online data collection system. Automatic validations include:

• Checks on the validity of organisation codes
• Aggregation checks on ‘Overall numbers of complaints’ and internal consistency checks (Totals equal sum of parts for each section)
• A threshold test comparing Total Brought Forward data in the latest quarter to Total Carried Forward data from the previous quarter.

Further internal validations are also performed once data are received.

Aggregation (Analysis)

Every responsible organisation is required to publish an annual report which details;

• the number of complaints received;
• the number the organisation decided were well-founded;
• the number of complaints which have been referred to:

1. the Parliamentary and Health Service Ombudsman or
2. the Local Commissioner

• and summarises:

1. the subject matter of complaints received;
2. any matters of general importance arising out of those complaints, or the way in which the complaints were handled;
3. any matters where action has been or is to be taken to improve services because of those complaints.

The KO41a information is returned at an aggregated level by organisations. From this NHS Digital derive overall England and NHS England region totals. 

Due to the nature of the NHS (not all organisations offer the same services or serve equal catchment areas/populations) and patient choice, it is not possible to produce comparative information against provider population. 

Accuracy

The quarterly complaints data collection KO41a form is sent to every NHS organisation with patient responsibilities to collect details on written complaints they receive during the reporting period.

This report is based on responses from 396 organisations in 2020-21 Q1, 393 in 2020-21 Q2, 394 in 2020-21 Q3, and 392 in 2021 Q4. Due to ongoing NHS changes the number of organisations responding does vary. Data were received from all core NHS providers in 2020-21 Q1 to Q4.

If organisations do not provide data, no estimates are made due to the different services offered by organisations across the NHS.

The data for some organisations at site level include small numbers of complaints with service/subject/professional areas but no new complaints. This may occur when the detail of a single complaint covers multiple sites. As small numbers are involved and it only impacts at site level, data will be kept under review.

Carried forward / Brought forward

The number of complaints carried forward from one quarter should equal the number of complaints brought forward in the next quarter. However, the data show that this is not usually the case. Some differences are caused by data quality issues and some are due to updates between quarters (e.g. withdrawn complaints), which only become apparent when organisations compile data for the next quarter. A threshold test is in place within the collection system to alert trusts where these figures vary by more than a specified amount.

It was identified in 2018-19 Q2 that a small number of organisations provided cumulative data in the carried/brought forward data resulting in increasing numbers in those two fields. Therefore, caution needs to be used when using these two data items, as they are likely to over-estimate the true figure. NHS Digital will continue to try to improve data accuracy in this field.

Relevance

The NHS complaints procedure is the statutorily based mechanism for dealing with complaints about NHS care and treatment and all NHS organisations in England are required to operate the procedure.

This quarterly collection is a count of written complaints made by (or on behalf of) patients, received in each period, according to the April 2009 complaints arrangements. Although the 2009 regulations apply to complaints about the NHS and adult social care, these data only cover NHS complaints.

Data are used by the Department of Health and Social Care to answer Parliamentary Questions, press queries and are available to NHS organisations and the public.

Following the Francis report, an independent inquiry into the care provided by Mid Staffordshire NHS Foundation Trust, it was recommended that NHS organisations were required to have a more open and transparent complaints process and that complaints information was required to inform patient choice.

Comparability and Coherence

The introduction in 2015-16 of the changes to the categories means that data from 2015-16 are not directly comparable to previous annual publications.

Occasional breaks in time series data may occur when organisations do not supply data for a quarter (usually due to complaints system issues). Where necessary these are highlighted in organisation level tables.

In addition, the changing nature of organisations providing NHS services means care must be taken when comparing data at an organisational level across a time series.

Data are presented at national, NHS England region and organisation level. A csv file is available for a full dataset.

Organisations have a statutory responsibility to adhere to the 2009 regulations, which should ensure consistency on collection and reporting of written complaints.  NHS Digital has no authority or responsibility to audit organisations to ensure that they are capturing and recording correctly all complaints. Each organisation monitors and audits its own collection process. 

Detailed information on the collection along with instructions on validations and how to use the SDCS system are available on the NHS Digital website

Timeliness and punctuality

Complaints data are collected following the end of each quarter and are published as soon as possible after validation and compilation. Please refer to the Revisions and Issues section for amendments to the usual timetable below caused by Covid-19.

Accessibility

All data areas are published and available in this publication. Excel spread sheets and csv files are available via the NHS Digital internet site and data.gov.uk. Further detailed analyses may be available on request, subject to resource limits and compliance with disclosure control requirements.

Performance cost and respondent burden

Organisations have a statutory responsibility to collect the KO41a, and it is produced from existing administrative systems with minimal burden.

Confidentiality, Transparency and Security

The standard NHS Digital data security and confidentiality policies have been applied in the production of these statistics.

Comparisons with external data items

To add context to the numbers of complaints organisations receive, tables have been produced showing the number of new complaints compared with relevant data items for the following organisation types:

• Acute – Complaints for acute organisations compared to Finished Consultant Episodes taken from Hospital Episodes Statistics data.
• Ambulance – Complaints by ambulance trusts compared to the number of contacts ambulance trusts receive.
• CCGs, Community Providers and Other organisations – at present there is not a suitable measure for these organisation types. NHS Digital invites suggestions from users of this data.
• Mental Health – Complaints data for mental health organisations were compared to ‘Open referrals by reporting period’ from the Mental Health Services Data Set. However, feedback suggested this was misleading as some mental health organisations provide community services not included in this measure. Until more appropriate data is identified this comparator has been removed.
• Acute, Ambulance, Mental Health – for these organisation types staff numbers are used as an additional indicator of the approximate size of an organisation. This measure is not appropriate for CCGs or community provider trusts as not all have their staff allocated to the organisation in ESR. Staff numbers for the first month of each quarter are used.

These measures are only intended to show basic contextual comparisons and should be treated with caution. There are factors to be aware of such as incomplete or provisional data items that may affect a dataset. These datasets are used to demonstrate volumes of activity, but suggestions of alternative or more comparable data items are welcome. The tables show a brief set of footnotes in relation to the additional data used and more detail is provided below.

Finished Consultant Episode (FCE) data – Provided by Hospital Episode Statistics (HES), NHS Digital. The data is provisional and may be incomplete or contain errors for which no adjustments have yet been made. Counts produced from provisional data are likely to be lower than those generated for the same period in the final dataset. This shortfall will be most pronounced in the final month of the latest period, i.e. November from the April to November extract. It is also probable that clinical data are not complete, which may affect the last two months of any given period. There may also be coding inconsistencies that are yet to be investigated and corrected.

Ambulance Quality Indicators – NHS England publishes a range of Ambulance service data on a monthly basis. From August 2017 a new series of standards, indicators and measures has been introduced through the Ambulance Response Programme. The count of all ambulance control room contacts (A0) is used as the comparator. This provides a measure of overall demand upon Ambulance Services. It includes all telephone calls to 999/112 and cases transferred from NHS 111

Workforce – NHS Digital publish monthly NHS staff numbers reports available here

UK Home Countries

Written complaints data are published for the other UK home countries. However, these are not directly comparable with the England data in this bulletin due to:

• Wales – Regulations aimed at streamlining the handling of complaints about the NHS in Wales, referred to as Putting Things Right, came into force in April 2011.
• Scotland – There is a variation in recording practice across Scotland and some NHS Boards/organisations.
• Northern Ireland – have an integrated health and social care system, therefore figures include complaints regarding social care unlike England data.