Completing the return

The KO41b should be completed with numbers of written complaints about primary care (GP or dental) services made directly to ICBs by, or on behalf of, patients in the period 1 April 2024 to 31 March 2025.

A written complaint is one that is made in writing to any member of staff or is originally made orally and subsequently recorded in writing. Once it is recorded, it should be treated as though it was made in writing from the outset. Oral complaints and comments/suggestions that do not require investigation should not be included.

If a written communication contains more than one complaint that requires separate investigation, then each should be recorded and counted separately. However, where a single complaint covers several aspects of care, it should be recorded once in the summary section (as a new complaint), with each aspect of the complaint also being recorded.

The detailed breakdown of information, including age of the patient, status of the complainant, and the subject and professional area of the complaint are only required for the new complaints received in 2024-25. They are not required for the complaints recorded as brought forward from the previous reporting period as these details will have been included in the previous year’s collection.

Investigations instigated by outside agencies, such as the police or coroners court, should not be included.

Where ICBs directly employ/commission doctors (or others) to provide an out-of-hours service then these complaints should be recorded on the KO41a so should not be included on the KO41b return.

From 1 July 2023, ICBs took over the management of complaints previously handled by NHS England, for those complaints made directly to ICBs regarding the primary care services they commission. Complaints relating to pharmacy and ophthalmic services are not included within the KO41b return.

Where the ICB has fully handled a complaint concerning primary care services, either GP or dental, then it should be recorded and submitted on the KO41b by the ICB. Where the complaint was transferred to the practice, and handled in full by the practice, it should be recorded by the practice.

It is acknowledged that the full handling of primary care complaints by ICBs may differ to secondary care complaints (collected via the KO41a), where complaints are usually passed to NHS trusts to handle. NHS trusts will have dedicated complaints handling teams, which is not the case at practice level.

ICBs are advised to use their existing mechanisms for capturing the complaints that they handle. The data items collected as part of the KO41b return are broadly similar to those in the KO41a. However, ICBs should note that the data submission method differs from the KO41a and that an online form is used for the KO41b data submission. See the Submitting Data section of this guidance for more details.

Guidance is available on extracting data from CRM for those ICBs using this to capture their complaints data. We have worked with colleagues producing this guidance to ensure alignment between these documents. A copy of the CRM guidance can be obtained by contacting the central complaints collection team.

ICBs are only required to submit a single return for their organisation, not a return for each practice within their footprint. If data are held at practice level by ICBs, they should be aggregated into a single summary line of data for the purpose of completing the return.

For the 2024-25 collection year we will be introducing a series of post-submission validation checks that have not been in place in previous years. The checks will take place once the submission window has closed as we are unable to include any extra validation checks within the collection form itself. These checks will include:

• identification of zero returns
• identification of outliers (unusually high or low numbers)
• significant variance from previous submissions

Where ICBs are flagged for triggering any of these validations we will contact them asking for clarification of the submission and offer the opportunity to revise submitted data. We intend to perform these validations immediately after receiving the data following the collection closing. This is usually around 2 weeks from the window closing.