Data on Written Complaints in the NHS, 2023-24

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

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.

The 2022-23 collection year saw the frequency change back from quarterly to annual aimed at reducing burden on submitters. This change was discussed with data submitters and suppliers of IT systems used for complaints data capture in advance to help understand any problems that may arise from the change. Although most organisations were able to make a full submission a small number were unable to do so despite extensions to the collection window.

All core NHS organisations, including all ICBs, made a KO41a return in 2023-24.

KO41b - Primary Care (GP and Dental) data quality issues:

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. However, the GP collection method is now stable following several improvements implemented from 2021-22, including moving to an online collection tool.

No data were collected from primary care providers in 2019-20 as part of burden reduction measures during the COVID-19 pandemic. During this time a consultation was run, and refinements were made to the data collected for 2020-21.

Following the introduction of ICBs in July 2023, they are now responsible for collecting and submitting complaints made directly to them about the primary care services they commission. This reporting was previously the responsibility of NHS England. NHS England submitted data for the April to June period in 2023-24, with ICBs assuming responsibility for data submission from this point onwards.

Consultation

NHS England carried out a consultation regarding the KO41b collection in early 2021 while the collection was paused. Acting on feedback received, the following changes were made;

• Reducing the number of Age Categories a patient can be reported under
• Reducing the Patient Status categories options
• Removing the Service Area category from the return
• Moving from the spreadsheet-based system used in 2018-19 to an online collection method from 2020-21

Validation

Although the GP data collection system 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. The absence of these 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 2020-21 report. 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.

For the 2021-22 collection onwards, multiple validation rules were introduced for the GP data collection to both allow users to sense-check their return and to improve the quality of the data being generated. The validation rules now in place cross-reference other sections of the return and have resulted in significantly improved data quality since the issues observed in 2020-21.

Some validation rules have been tightened for the 2023-24 KO41b collection of dental practice data. This has resulted in the removal of duplicates where identical data were submitted by single practices covering multiple contracts.

Response Rates

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

We would advise caution if making direct comparisons of the response rates in recent years due to the impact of factors such as COVID-19 (which resulted in the 2019/20 collection being paused) and changes in the data collection method for the GP return.

Data quality issues relevant to the KO41a (HCHS) and KO41b (Primary Care) collections:

Relevance

The NHS complaints procedure is the statutory mechanism for dealing with complaints about NHS care and treatment, which all NHS organisations with patient responsibilities in England are required to comply with. All NHS organisations should also complete the complaints data collection (KO41a or KO41b) and these 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 for that year.

For primary care (KO41b), data are presented for the latest Integrated Care Board (ICB) areas. This is because data are returned by individual organisations (GP or dental practices) and then aggregated for the ICB areas in which they are located, as at the end of each reporting period.

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.

Timeliness and punctuality

The collection of the annual KO41a and KO41b complaints information was during May – August for the 2023-24 year. This allowed 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. 

Accessibility

Data are published and available in this publication via Excel spreadsheets or CSV files on the NHS England website. 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 England data security and confidentiality policies have been applied in the production of these statistics.