Recommendation 40

Focusing on complaint narrative

It is important that greater attention is paid to the narrative contained in, for instance, complaints data, as well as to the numbers.

The new approach to inspection introduced by the Care Quality Commission places a stronger focus on how care is delivered in practice and how it is experienced, rather than only on compliance with regulations. In line with this, it is now making greater use of the information that it holds on complaints.

The Care Quality Commission already uses a range of information about complaints to inform the timing and focus of its inspections. The information ranges from aggregated numbers and patterns of complaints, to individuals who contact the Care Quality Commission and tell inspectors about their experience. The Care Quality Commission will review how it makes best use of the complaints that it receives directly from individuals, and the individual stories in complaints as well as the aggregated trends, in light of Rt Hon Ann Clwyd MP and Professor Tricia Hart’s Review of the Handling of Complaints in NHS Hospitals.


The new inspection process being developed by the Care Quality Commission, working with the Patients Association, is to build an approach based on listening and focus groups, and an interview with the complaints manager. It may also involve looking through complaints file; in other words, looking at the whole complaints process.

The Care Quality Commission provider handbooks were published in October 2014 and include mandatory key lines of enquiry for use in all inspections. For complaints this means the inspection finding evidence to answer the questions – How are people’s concerns and complaints listened and responded to and used to improve quality of care? For staff concerns, evidence will be gathered to answer the questions – Is the value of staff raising concerns recognised by both leaders and staff? Is appropriate action taken as a result of concerns raised?

Over the next six months, the Care Quality Commission plan to further strengthen this approach through:

  • starting to design a set of training and support for inspection team members and other the Care Quality Commission staff that is likely to include issues such as understanding the legal framework, facilitating staff forums to ensure raising and acting on concerns is discussed, how to manage sensitivities in handling concerns such as confidentiality, use of inspection guidance and tool kits, identifying good and poor practice.
  • In terms of complaints handling, the Care Quality Commission plan in hospitals and other care sectors to carry out an audit of a randomly selected (by the Care Quality Commission) sample of closed files to understand if these have been handled in a way that matches the good practice they expect to see.
  • Interviews with senior management, including the Head of Human Resources or equivalent, will include questions about policies on and the practice of handling staff concerns.

There was a positive response when the Care Quality Commission engaged on their proposed approach with groups of people who have experience of making complaints, complaint advocacy services, staff who have raised concerns about services and national bodies. The Care Quality Commission have gathered, from their inspection activity, evidence of good and poor practice in the different sectors for a Chief Inspector of Hospitals report Complaints Matter, which was published in December 2014.

The Care Quality Commission is also undertaking a wide review of “customer experience” that will understand how they can improve the way they listen and respond to concerns and complaints and the providers they regulate. This will include looking at good practice in other service sectors. They are also carrying out a review of their own whistleblowing policies using external expertise.

The Care Quality Commission is building up the relationships it has with its strategic partners to reform the wider complaints system in order to align work on vision and standards, share good practice and consistency in messaging and on a joint vision for good complaints handling.