COMPLAINTS AND CONCERNS POLICY
Aligned with NHS Wales “Listening to People” arrangements and Wales General Ophthalmic Services (WGOS)
Purpose
This policy sets out how the practice receives, records, investigates, responds to, and learns from patient concerns, complaints, comments, and feedback. It is designed to ensure that people are listened to, treated with dignity and respect, and supported to raise concerns about their care without fear that this will adversely affect their treatment.
The practice will follow the principles of NHS Wales “Listening to People” guidance and the requirements of Wales General Ophthalmic Services (WGOS), including the relevant WGOS service manuals, Local Health Board arrangements, and NHS Wales processes for concerns, incidents and redress. Where a concern relates to care provided by another organisation, such as a hospital eye service, another NHS provider, or a Local Health Board pathway, the practice will help the patient identify the appropriate route for raising the issue.
Scope
This policy applies to all concerns raised by patients, relatives, carers, representatives, visitors, or other people affected by the ophthalmic services provided by the practice, including private services and NHS Wales General Ophthalmic Services. It applies to concerns raised verbally, in writing, by email, through the practice website, in person, or through another suitable communication method.
A concern may include a complaint, comment, suggestion, expression of dissatisfaction, patient safety issue, incident, or request for an explanation about eye care, sight testing, spectacle dispensing, contact lens care, low vision services, urgent eye care, referral refinement, monitoring, independent prescribing optometry services, mobile services, or other WGOS-related activity.
For the purposes of this policy, WGOS includes the WGOS Eye Examination, urgent eye problem examinations, low vision assessments, referral refinement and monitoring pathways, Independent Prescribing Optometry Service activity where provided, and mobile services for eligible patients who are unable to attend the practice.
Policy Statement
The practice is committed to a person-centred, open, fair, and compassionate approach to managing concerns. We will make it easy for people to speak up, acknowledge concerns promptly, offer a listening discussion, seek early resolution where appropriate, investigate fairly when required, and provide clear outcomes in plain language.
All staff must respond to concerns respectfully and must never treat a patient differently because they have raised a concern. The practice will use feedback and complaints as opportunities to improve care, access, communication, safety, and patient experience.
Responsibilities
The Practice Manager or nominated complaints lead (Paul Darlington) is responsible for maintaining this policy, ensuring concerns are acknowledged and recorded, coordinating investigations, monitoring timescales, and ensuring learning is shared. The contractor and performers providing WGOS services are responsible for ensuring that concerns relating to NHS ophthalmic care are reviewed by an appropriately qualified optometrist, dispensing optician, contact lens optician, independent prescriber, or other responsible clinician, depending on the nature of the concern.
All staff, including clinical, dispensing, reception, administrative, mobile service and delegated staff, are responsible for recognising concerns, responding courteously, attempting immediate resolution where safe and appropriate, and escalating concerns to the Practice Manager, nominated complaints lead, senior optometrist, contractor, or practice owner/director without delay.
Where the concern relates to a WGOS clinical pathway, referral, monitoring arrangement, eligibility issue, record, claim, or service requirement, the practice will ensure the matter is reviewed against the applicable WGOS manual, Local Health Board guidance, and NHS Wales contractual or administrative requirements.
How Patients Can Raise a Concern
Patients may raise a concern with any member of staff. Concerns may be raised in person, by telephone, in writing, by email, through the practice website, or through a representative. Where a representative acts on behalf of a patient, the practice will usually require the patient’s consent unless there is a lawful reason to proceed without it.
Information about how to raise a concern will be made available at reception, on the practice website where applicable, and in alternative formats or languages when reasonably required.
Acknowledgement and Listening Discussion
The practice will acknowledge formal concerns within five working days wherever possible. The acknowledgement will explain who is handling the concern, what the next steps are, and how the person can access support or request communication adjustments.
The practice will offer a listening discussion by telephone, video call, or in person. The purpose of this discussion is to understand the person’s experience, clarify the issues raised, identify the outcome they are seeking, explain the process, and agree how the concern will be managed.
Early Resolution
Where appropriate, the practice will seek to resolve concerns quickly and compassionately through early resolution, normally within ten working days. Early resolution may include an explanation, apology, practical action, correction of records where appropriate, a meeting, or another agreed response.
If a concern cannot be resolved through early resolution, or if the matter is complex, serious, involves potential harm, relates to a WGOS referral or monitoring pathway, or raises questions about eligibility, clinical records, claims, or service delivery requirements, the practice will move to a proportionate investigation and will keep the person informed.
Investigation and Response
Investigations will be fair, objective, proportionate, and focused on understanding what happened, why it happened, and what can be done to put things right or prevent recurrence. Relevant clinical records, WGOS records, referral information, dispensing records, contact lens records, low vision records, mobile service records, claim forms, electronic referral records, and communications with the Local Health Board or hospital eye service may be reviewed where relevant.
The practice will aim to provide a written response within 30 working days where a full investigation is required. If this is not possible, the practice will explain the reason for the delay and provide an updated timescale. Outcome letters will be clear, accessible, and written in plain language.
Openness, Apology and Redress
The practice will be open and honest when responding to concerns. Where something has gone wrong, the practice will provide an explanation and apology where appropriate. An apology is not an admission of legal liability; it is part of a compassionate and transparent response.
If a concern may involve qualifying harm, clinical negligence, possible redress, patient safety, referral delay, incorrect WGOS pathway management, or a contractual or claims-related issue, the practice will escalate the matter in accordance with NHS Wales arrangements and seek advice from the relevant Local Health Board, NHS Wales Shared Services Partnership Primary Care Services, professional body, indemnity provider, or other appropriate body.
Support, Advocacy and Accessibility
The practice will offer reasonable adjustments and communication support for people who need help to raise or understand a concern. This may include accessible information, interpretation, translation, large print, Easy Read, or support for people who are digitally excluded.
Patients may be signposted to Llais, the independent statutory citizen voice body for health and social care in Wales, for advocacy and support when raising a concern.
Confidentiality and Records
All concerns will be handled confidentially and in accordance with data protection requirements. Information will only be shared with those who need it to investigate and respond to the concern, unless there is another lawful basis for disclosure.
The practice will maintain a complaints and concerns log recording the date received, summary of issues, acknowledgement date, listening discussion offer, actions taken, outcome, learning identified, and date closed. Where relevant, the log will identify whether the concern relates to WGOS, private care, dispensing, contact lenses, referrals, claims, mobile services, or another service area. Records will be retained in line with the practice’s information governance and records management requirements.
Learning and Improvement
The optometry practice will review concerns to identify themes, risks, and opportunities for improvement across WGOS and other services. Learning may be shared at practice meetings, clinical governance discussions, significant event reviews, staff briefings, contractor or performer updates, or training sessions. Actions will be monitored to ensure that agreed improvements are completed.
Examples of learning may include changes to WGOS triage, eligibility checks, patient information, clinical record keeping, referral refinement, monitoring processes, urgent eye problem pathways, low vision assessment processes, Independent Prescribing Optometry Service arrangements, mobile service procedures, spectacle dispensing procedures, contact lens aftercare, electronic referral use, claims administration, staff training, accessibility arrangements, or administrative procedures.
Escalation and Further Review
If a patient remains dissatisfied with the practice response, they will be advised of the appropriate escalation route. This may include the relevant Local Health Board complaints team, NHS Wales Shared Services Partnership Primary Care Services where the issue relates to WGOS listing, claims or administrative arrangements, or the Public Services Ombudsman for Wales, depending on the circumstances and stage of the process.
Training and Awareness
All staff will be made aware of this policy and their responsibilities when receiving or responding to concerns. Staff involved in WGOS delivery must understand the relevant WGOS service requirements, including mandatory training, delegated duties, clinical pathway responsibilities, referral requirements, record keeping expectations, and the duty to escalate concerns promptly. New staff will be introduced to the policy during induction, and refresher training or briefings will be provided when guidance changes or learning identifies a need.
Practitioners who deliver WGOS must complete the required WGOS mandatory training hosted by Health Education and Improvement Wales on the Y Tŷ Dysgu platform before providing WGOS care. Where applicable, practitioners must also hold the required Eye Health Examination Wales accreditation and any additional qualifications or approvals needed for the WGOS level or pathway they provide.
All staff colleagues who assist with WGOS delivery, including reception, optical assistants, dispensing staff, delegated clinical support staff, mobile service staff, and administrative staff involved in WGOS records or claims, must complete the relevant mandatory WGOS training before undertaking delegated WGOS functions or supporting eligible WGOS patients.
The practice will maintain a WGOS training record showing each staff member’s role, relevant WGOS responsibilities, mandatory training completed, date completed, accreditation status where applicable, refresher training, and any supervision or competency sign-off. Training records will be available for internal governance, contractor assurance, Local Health Board review, or NHS Wales audit where required.
Staff training will include, as relevant to the role, how to recognise and escalate patient concerns, WGOS eligibility and service levels, patient management plans, prevention and wellbeing messaging, urgent eye problem pathways, referral refinement and monitoring requirements, low vision processes, mobile service procedures, electronic referral and reporting systems, claims administration, confidentiality, consent, record keeping, accessibility, equality, and patient communication.
The nominated complaints lead will review concerns and incidents to identify whether additional WGOS training, supervision, peer discussion, or competency review is required. Any training actions arising from complaints, significant events, audit findings, or WGOS guidance updates will be documented and followed up to completion.
Monitoring and Review
This policy will be reviewed annually, or sooner if NHS Wales guidance, WGOS service manuals, legislation, contractual requirements, Local Health Board arrangements, or practice arrangements change. The Practice Manager or nominated complaints lead is responsible for ensuring the policy remains current and that evidence of compliance is available for audit, inspection, contractor assurance, or Local Health Board review.