Policy AD-620 Complaint Resolution Process 2021-06-07

Purpose

The purpose of this policy is: 1) to create a process for handling and resolving complaints, 2) to ensure that all patients, family members, and visitors are treated with compassion and respect, according to Westside Family Healthcare’s mission and policies and procedures, 3) to provide opportunities for learning and continuous improvement for the benefit of patients and staff members, particularly in relation to safety and quality, and 4) to reduce the risk of future litigation related to a complaint.

Policy

Patients, family members, and visitors at Westside Family Healthcare (Westside) have the right to file a complaint when they feel that services have not met their expectations, using the processes described below. The appropriate Westside leadership and staff undertake investigation and seek resolution of all filed complaints, as outlined in the procedures below.

Scope

The complaint filing processes in this policy apply to all Westside patients, family members, and visitors. The complaint investigation and resolution procedures apply to all those at Westside receiving or addressing a patient complaint.

Definitions

None

Procedures

Filing of Patient Complaints  

• 1. Westside Family Healthcare (Westside) offers several options to file a complaint:
     1. Send or hand in a written complaint using the attached Patient Complaint Form,
     2. Call the Westside patient comment phone line (302-472-8632), or
     3. Submit electronically through Westside’s website on the “Contact Us” page.  
  2. The patient complaint options are noted in Westside’s marketing and patient education materials.
  3. If a person has a complaint regarding care or any interaction at Westside and is still present at a Westside facility, then a staff member strives to provide a resolution or involves the site Office Manager as needed.
  4. If the issue cannot be resolved at the time of service, the person is asked if s/he wishes to file a formal complaint. The person is offered the complaint options listed above.
  5. If the person wishes to file a written complaint, any staff member may provide the person with a Westside Patient Complaint Form, which is available on the Westside intranet website.  
     1. If necessary, the staff member provides the assistance needed to complete the form.

The written Westside Patient Complaint Form, or the message from the Westside patient phone comment line or the Westside website, is sent to the Associate Director of Site Operations, who will document the complaint.

• 1. When the Associate Director of Site Operations is not present, complaints are directed to the Director of Site Operations.

Initial Contact with Complainant

• 1. The Westside staff member who receives the complaint will inform the person who filed the complaint that it will be reviewed by an Office Manager, who will contact him/her within two (2) business days to discuss the complaint.

Patient Complaint Entry in Incident Reporting System

• 1. Data from the complaint is entered by the Associate Director of Site Operations into the electronic Westside incident reporting system as a “patient concern/complaint.”
  2. The incident reporting system is configured so that the following Westside staff members are made aware of the complaint as soon as it is filed:
     1. Director of Site Operations
     2. Director of Quality Improvement
  3. The electronic database for tracking incidents is also configured so that the following Westside staff members have access to the details of the complaints and can be notified as needed at the time the complaint is filed:
     1. Chief Operating Officer
     2. Chief Medical Officer
     3. Associate Medical Director(s)
     4. Director of Clinical Operations
     5. Associate Director of Clinical Operations
     6. Office Manager(s)

If the patient making the complaint believes someone has been subjected to discrimination on the basis of race, color, national origin, sex, age, or disability, they are notified that they may also file a grievance under Westside Family Healthcare’s AD-630 Patient Discrimination Complaints policy and the procedures contained therein.

Complaint Investigation and Resolution

• 1. The Director of Site Operations assigns the appropriate Office Manager(s) to investigate the complaint, and the Associate Director of Site Operations oversees the complaint resolution process.
  2. The Office Manager(s) investigates the complaint with the site clinical team.
     1. Input is received from the patient’s provider and any other employee(s) involved in the complaint.
     2. Information from the investigation is documented in the electronic incident reporting system.
  3. The Office Manager works with the clinical team to determine a resolution and will inform the Associate Director of Site Operations.
     1. The Associate Director of Site Operations communicates this resolution to the Director of Site Operations.  
     2. The resolution is documented the electronic complaint tracking database.

Final Resolution Decision

• 1. The Chief Operating Officer and/or the Chief Medical Officer (CMO) may review the suggested resolution and may make additional or different recommendations in a final resolution decision.
  2. The final resolution will be implemented within 30 days of the initial complaint. The appropriate resolution may involve one or more of the following measures:
     1. Clinical care and/or coordination
     2. HIPAA privacy/security follow-up
     3. Billing complaint resolution
     4. Staff member training
     5. Staff member disciplinary action
     6. Other action, as appropriate
  3. The Office Manager follows up with the person filing the complaint to inform him/her of the resolution.  
     1. If deemed more appropriate based on the nature of the patient’s complaint, follow-up with the person filing the complaint may be conducted by an administrative or clinical Director.
  4. If the person filing the complaint is not satisfied with the resolution, s/he will be advised that they may submit a letter in writing for the Chief Medical Officer’s or Chief Operating Officer’s review, depending on the nature of the complaint.

Data will be compiled from all complaints received and will be reported on a regular basis to the Quality Improvement Committee of the Board of Directors as well as the Westside leadership team.

References

1. Relevant Standard from The Joint Commission (TJC), Comprehensive Accreditation Manual for Ambulatory Health Care (CAMAC), January 1, 2021:
   1. RI.01.07.01 – The patient and his or her family have the right to have complaints reviewed by the organization.
      1. EP 1 – The organization establishes a complaint resolution process and informs the patient and his or her family about it.
      2. EP 4 – The organization reviews and, when possible, resolves complaints from the patient and his or her family.
2. Relevant HRSA Requirements:
   1. Chapter 21: Federal Tort Claims Act (FTCA) Deeming Requirements. Health Services Resource Administration (HRSA). Health Center Program Compliance Manual, August 2018.  https://bphc.hrsa.gov/programrequirements/compliancemanual/chapter-21.html#titletop
      1. Risk Management b: The health center has risk management procedures that address the following areas for health center services and operations: Documenting, analyzing, and addressing clinically-related complaints and “near misses” reported by health center employees, patients, and other individuals.
   2. Federal Tort Claims Act (FTCA) Deeming Requirements. Health Services Resource Administration (HRSA). Site Visit Protocol (SVP), May 27, 2021.  https://bphc.hrsa.gov/programrequirements/site-visit-protocol/federal-tort-claims-act-ftca-deeming-requirements

Element B: Risk Management Procedures (same language as above)