Data on Written Complaints in the NHS, 2021-22

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 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 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 only national HCHS totals are comparable with earlier years.

Within the HCHS data users may note a rise in the number of complaints received in 2021-22 compared to the 2020-21 year. However, these numbers are now much closer to those observed before the pandemic.

KO41b - Primary Care (GP and Dental) data:

Changes & Comparability

We would advise users to consider previous years findings when making any judgements on the data, particularly in relation to General Practice level data. This is due in part to returns using different modes of collection in recent years. GP data collected for the 2021-22 year used the same online collection method as the previous year, with the return featuring several improvements aimed at enhancing the user experience (please see Validation section below for further information). With the GP collection method now stable, we expect comparability to improve in the coming years.

It is further complicated by the data not being collected in 2019-20, during which time a consultation was run, and refinements were made to the data collected for 2020-21.

Within the data users may note a rise in the number of complaints received by dental practices when compared to the 2020-21 year. Although this rise has contributed to the overall increase to complaints received in Primary Care compared to the previous year, the numbers are in line with those observed before the pandemic.

Validation

Although the GP data collection system was moved to an online platform for the 2020-21 collection year, it did not contain some of the validation rules which had been present in previous years. For the 2021-22 collection, multiple validation rules were introduced to both allow users to sense-check their return and to improve the quality of the data being generated.

The absence of some rules in the 2020-21 GP collection resulted in several assumptions being made about which totals to accept and report on. These assumptions were clearly defined in this section of the report last year. For example, some totals were derived from the proportion of records submitted in certain sections of the return, as opposed to the sum of the raw data items.

The validation rules now in place cross-reference other sections of the return and have resulted in significantly improved data quality. We have therefore been able to move away from the proportions-based methodology employed last year. GP record level data was marked as ‘Unvalidated’ last year, this badging is no longer in place. 

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 as well as changes in collection methods are likely to have contributed to fluctuating rates. Response rates for General Practice have not returned to levels observed in earlier years, users may also note that the increased numbers of complaints received by General Practices for the 2021-22 year are not a result of an increased response rate.

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 publication 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:

• 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.

In 2021-22 the organisation level tables in the report, and the CSV files, for primary and secondary care are also presented by Integrated Care System area.

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 – September for the 2021-22 year. This allows for all the complaints during the year to be assessed and included in the returns and is broadly the same period as the previous year. The KO41b collection window had originally been scheduled to remain open for 6 weeks but was extended by a number of weeks as the period of national mourning was observed.  

For 2021-22, the KO41a (HCHS) data were collected for each quarter and made available as soon as possible after validation and compilation. Users should note that the frequency of collection and publication of the KO41a has now moved to annual (2022-23 onwards), in line with the KO41b, and will now be published as part of this single annual publication. Quarterly updates will no longer be published.

Accessibility

All data areas are published and available in this publication via Excel spread sheets and all site level data are in CSV files 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.