Data on Written Complaints in the NHS, 2020-21

Accuracy and Comparability

All NHS organisations with patient responsibilities should complete the complaints data collection (KO41a or KO41b).

Impact of Covid-19

In March 2020 NHS England and NHS Improvement announced an optional pause to the NHS complaints process due to Covid-19 to allow health care providers to prioritise their response to the pandemic. Patients and the public were still able to make a complaint, and these would be acknowledged and recorded by providers. This optional pause lasted until June 2020. Therefore, it is likely that the complaints data recorded for 2020-21 are affected by this pause.

In February 2021 NHS England and NHS Improvement announced further measures to relieve ongoing pressures caused by the pandemic. This included allowing providers longer than the usually required 6 months to respond to a complaint and was in place until 30 April 2021.

NHS Digital are unable to estimate the impact each of these issues will have had on overall complaints data. However, it can be seen from the data that the overall volume of complaints fell considerably during 2020-21 when compared against previous years data.

KO41a – Hospital & Community Health Service (HCHS) data:

Following a public consultation in 2014 the KO41a collection was revised to include more relevant data items about complaints (service/subject and profession) and complainants. The frequency was also altered to quarterly (from annual) and data was collected at site level for each organisation. Because of these changes data are classed as Experimental Statistics from 2015-16 meaning only national HCHS totals are comparable with earlier years.

Prior to April 2011 Foundation Trusts (FTs) only supplied data on a voluntary basis (although most did supply this information). In the last year (2010-11) of FTs supplying the data voluntarily 29 did not submit data. Table 1 of the data tables shows the number of FTs by year who did not supply information.

KO41b - Primary Care (GP and Dental) data:

Changes & Comparability

Comparability remains an issue for the KO41b collection. This is due in part to each of the last three returns using a different mode of collection for General Practices. It is further complicated by the data not being collected in 2019-20, during which time a consultation was run, and further refinements made to the data collected for 2020-21.

Validation

Unlike previous years, no at-source validation was carried out on the GP aspect of the KO41b collection during the 2020-21 year. Post-collection analysis on the raw GP data showed that over half (56%) of records would have failed at least one of the validations present the last time collection was run in 2018-19. Whilst it has been possible to make a small number of corrections where there were clear errors (keying errors, or missing organisation totals which were supported by matching totals in other areas of the return, for example), the data should be viewed as unvalidated. As General Practices have not had chance to validate their data, aside from the small number of records where clear errors have been corrected, we have not imputed records on the behalf of individual General Practices.

The NHS England & Improvement and Dental components of the KO41b return are not affected by these issues.

Data Tables and CSV

Due to the absence of validation on the GP data return, some national and region/CCG level totals have been derived from the proportion of records submitted in certain sections of the return, as opposed to the sum of the raw data items. This is the case for:

• Numbers of Complaints Upheld, Partially Upheld and Not Upheld in Tables 1b, 1c, 9, 9a and 14
• Age Category component data in Table 10
• Complainant Status component data in Table 11.

Overall national and region/CCG component data have been derived for these three sections due to their incompleteness in GP organisation level returns as follows:

Complaints Upheld, Partially Upheld and Not Upheld have been derived by using the Total Resolved Complaints submitted by practices as the denominator. The Resolved components (Upheld/Partially Upheld/Not Upheld) were then aggregated to derive proportions. This proportion was then applied to the denominator (Total Resolved Complaints) to generate overall England and region/CCG figures for the component parts.

Age Category and Complainant Status have been derived by using the Total New Complaints submitted by practices as the denominator. The submitted components were aggregated to derive proportions. This proportion was then applied to the denominator (Total New Complaints) to generate overall England and region/CCG figures for the component parts.

This method has been used as analysis showed the proportions of the breakdowns to be broadly representative of the data that were submitted. As a result of these calculations some numbers of complaints contain decimals.

Tables 12 and 13, which present data by Subject and Staff Areas do not employ this technique as organisations could submit against more than one category in these fields. However, the national and region/CCG figures given are derived from the sum of the components for these sections, as opposed to the submitted totals within the return.   

Users of the Data on Written Complaints in the NHS 2020-21 Primary Care KO41b - Org Level (GP_UNVALIDATED).csv file should be aware that for the following fields, the sum of the data submitted by practices does not therefore match the totals presented in the data tables;

• Number Upheld
• Number Partially Upheld
• Number Not upheld

The CSV file is labelled as GP_Unvalidated to alert users to these issues.

Impact

Whilst we would encourage caution when making judgements based on the data in this publication, the techniques employed (as described above) are designed to allow users to get maximum value from the data.

Although the General Practice KO41b raw data is largely unvalidated we still believe that it is broadly representative, though we have avoided making comparisons with previous years findings when considering the KO41b primary care data. The continued designation of these statistics as Experimental, acknowledges the issues outlined with collecting and presenting unvalidated data and that improvements are scheduled which are aimed at improving the quality of the data.

Response Rates

From 2013-14 onwards KO41b data has been collected from individual GP and Dental practices and return rates are:

Owing to the number of issues raised within this report, we would discourage users from making direct comparisons of the response rates presented above. The impact of Covid-19, changes in collection methods, and many dental practices providing an urgent only service for large parts of 2020-21 are likely to have contributed to fluctuating rates.

General issues

Organisations have a statutory responsibility to adhere to the 2009 Complaints Regulations. NHS Digital has no authority or responsibility to audit organisations to ensure that they are capturing and correctly recording all complaints. Each organisation monitors and audits its own collection process.

Relevance

The NHS complaints procedure is the statutory mechanism for dealing with complaints about NHS care and treatment. All NHS organisations in England are required to operate the procedure. This survey collects data from all NHS organisations. The data have been published annually since 1997-98.

This annual collection is a count of written complaints made by (or on behalf of) patients, received between 1 April and 31 March under the April 2009 Complaints Regulations. Although these regulations apply to complaints about adult social care and the NHS, this publication only includes NHS complaints.

The Francis report, which was an Independent Inquiry into Mid Staffordshire NHS Foundation Trust, made recommendations that included the requirement for NHS organisations to have a more open and transparent complaints process and that complaints information is required to inform patient choice.

Factors affecting numbers of complaints

Factors affecting the numbers of complaints organisations receive include:

• Organisations having processes to resolve potential and verbal complaints before they escalate to written complaints. These include organisations making staff available to discuss and resolve issues.

• Staff making patients aware of services such as the Patient Advice and Liaison Service (PALS), which aims to listen to patients and their representatives, to answer questions and resolve concerns as quickly as possible. PALS provides information about the NHS complaints procedure and how to get independent help if a further complaint is being considered.
• Organisations have a responsibility to highlight the complaints procedures and alternatives to patients. Better awareness of the written complaints process may lead to more patients complaining.

Organisation mapping

KO41a and KO41b NHS England region data are aggregated to the latest regional structure to enable comparison at this level.

At an organisation level, HCHS (KO41a) data are presented for the organisation which recorded and returned the data. This means some organisations that closed or merged during a year may be present in organisation level KO41a data tables for that year.

For primary care (KO41b), data are presented for the latest Clinical Commissioning Group (CCG) areas. This is because data are returned by individual organisations (GP or dental practices) and then aggregated for the CCG areas in which they are located.

Upheld data

• From 2015-16 the KO41a (HCHS) data no longer has an upheld category against each service/subject area. Each organisation records a single figure for the overall number of upheld/partially upheld/not upheld complaints. Comparisons with earlier year’s data below the overall total are not possible.
• The KO41b (Primary Care) collection used to record an upheld category against each area but from 2016-17 like the KO41a it only provides overall upheld figures for each organisation. Comparisons with previous year’s data below the overall total are not possible.

It should be noted that there is variation in the recording of the resolution status of complaints across England. Some organisations classify all complaints as upheld upon their receipt while most organisations record a resolution status depending on investigation of the complaint.

Contextual data – Population

To add context to the numbers of complaints received, overall complaints have been compared with ONS resident population data in tables 1 and 1a of the data tables. This measure is only intended to show a basic contextual comparison and should be treated with caution.

Timeliness and punctuality

The collection of the annual KO41b complaints information was during August – October for the 2020-21 year. This allows for all the complaints during the year to be assessed and included in the returns. This falls outside the previous collection windows which have run in May to June and was extended from 6 to 12 weeks to allow as many provider organisations as possible to make a submission.

The KO41a (HCHS) data are collected for each quarter and made available as soon as possible after validation and compilation. 

Accessibility

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

Performance cost and respondent burden:

The KO41a and KO41b require organisations to provide data they already collect. It is extracted 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.

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.