REPORT TO MERTON CLINICAL COMMISSIONING GROUP GOVERNING BODY

REPORT TO MERTON CLINICAL COMMISSIONING GROUP GOVERNING BODY Date of Meeting: 20 November 2014 Agenda No: 5.1 Attachment: 05 Title of Document: Purpose of Report: End of Year Report 2013-14 : Complaints and PALS For Approval Report Author: SLCSU (Wanda Palmer) Lead Director: Lynn Street, Director of Quality Merton CCG Contact details: lynn.street@mertonccg.nhs.uk Executive Summary: This is the year-end report for Merton CCG complaints and PALS service, covering the time period of 1 April 2013 to 31 March 2014. The complaints and PALS service is managed on behalf of Merton CCG by the South London Commissioning Support Unit (SLCSU). The report details the information from complaints received which are directly related to the CCG, and gives a broad picture of those which are not directly related to the CCG. There is some analysis and comparison to the other London CCGs for which the SLCSU provide a complaints and PALS management service, including feedback from equality and diversity information forms returned by complainants which is detailed in Appendix 1. The aim is to enable the CCG to consider further developments in the PALS and complaints process, its own processes and information and develop plans and recommendations to be met in the next financial year. Key sections for particular note (paragraph/page), areas of concern etc: Sections 2 & 3 There were a total of 50 complaints and 117 PALS enquiries managed by SLCSU on behalf of Merton CCG in 2013/14. PALS enquiries relating to the reconfiguration of services at St Helier Hospital - where particularly high - these provide an anomaly in the data as this is unlikely to be repeated in the 2014/15 fiscal year. There were relatively low numbers of PALS enquiries relating to contact information, which is not in line with enquiries received for other CCGs this may indicate that the CCG is receiving and managing a number of enquiries through the generic enquiries email. Section 2-Page 4 The highest numbers of complaints relate to commissioning decisions, and six of these relate to decisions made regarding IVF funding. Recommendation(s): To consider the recommendation in section 5 of the report. The Governing Body is asked to APPROVE the report Page 1 of 2

Committees which have previously discussed/agreed the report: Executive Management Team August 2014 Financial Implications: N/A Implications for CCG Governing Body: To receive assurance that the patient voice is heard in the organisation How has the Patient voice been considered in development of this paper: Changes in the IVF provision as a result of patient and public feedback. Other Implications: (including patient and public involvement/legal/governance/risk/diversity/ Staffing) Themes from complaints and PALS enquiries inform commissioning plans. Equality Assessment: Due regard has been given to the need to eliminate discrimination, harassment and victimisation, to advance equality of opportunity, and to foster good relations between people who share a relevant protected characteristic (as cited in under the Equality Act 2010) and those who do not share it. Appendix 1 of the report details analysis of available information related to Equality and Diversity. Information Privacy Issues: N/A Communication Plan: (including any implications under the Freedom of Information Act or NHS Constitution) This report is being made publically available at Governing Body and once approved will be made available to all staff and placed on the CCG web site. Page 2 of 2

Year End Report: Complaints and PALS 2013/14 Author: Wanda Palmer, Clinical Governance Lead, SLCSU

Introduction This is the year-end report for Merton CCG complaints and PALS service, covering the time period of 1 April 2013 to 31 March 2014. The complaints and PALS service is managed on behalf of Merton CCG by the South London Commissioning Support Unit (SLCSU). The report details the information from complaints received which are directly related to the CCG, and gives a broad picture of those which are not directly related to the CCG. There is some analysis and comparison to the other London CCGs for which the SLCSU provide a complaints and PALS management service, including feedback from equality and diversity information forms returned by complainants which is detailed in Appendix 1. The aim is to enable the CCG to consider any themes identified from the data provided to inform development in the PALS and complaints process and CCG commissioning plans. Complaints and PALS 1. Complaints and PALS Data From 1 April 2013 to 31 March 2014 there were a total of 50 complaints and 117 PALS enquiries received on behalf of Merton CCG. It is of note that not all enquiries are directed to the SLCSU and some may be received and handled directly by Merton CCG, and these calls are not included in the report. The graph below shows the complaints and PALS received by the SLCSU over the year period: In the table below, the complaints and PALS enquiries are separated out into CCG and non CCG. The non CCG complaints are largely made up of enquiries where the complaint is redirected to another source e.g. an acute provider. (*The MP enquiries are not additional to the complaints and PALS enquiries received). 2

CCG Direct Commissioner Complaints CCG Non Direct Complaints MP Enquiries* PALS CCG Direct PALS CCG Non Direct April 2013 6 1 6 2 4 May 2013 3 0 43 52 3 June 2013 3 3 4 4 1 July 2013 1 3 7 3 6 August 2013 3 2 0 3 2 Sept 2013 0 0 2 3 2 October 2013 1 2 3 3 1 Nov 2013 3 2 2 2 2 Dec 2013 2 4 3 0 2 January 2014 2 4 0 2 4 February 2014 2 0 4 0 6 March 2014 1 2 4 3 6 Total 27 23 78 78 39 With the exception of May 2013, PALS enquiries have remained stable over the year, with very few relating directly to the CCG. Over the year complaints have remained low, with an average of 3 a month; although notably in September 2013 no complaints were received. As complaints have been so low, it is not possible to attach any significance to this. The number of complaints and PALS enquiries for each quarter show that whilst complaints numbers have remained relatively stable, with a slight dip in Q2; PALS numbers for Q1 were much higher (discussed in PALS section of report) and then dropped, with a much lower number in Q3 than the other quarters. 2013/14 Complaints PALS Q1 16 67 Q2 9 19 Q3 14 10 Q4 11 21 Total 50 117 2. Complaints CCG Complaints Of the 50 complaints received during the year 2013/14, 27 complaints were directly related to the CCG. This would include all services directly commissioned by the CCG. In addition to the complaints received during the year, there were three legacy complaints, handed over from pre-april 2013, for management and completion. 3

The themes of the CCG direct complaints are: Theme Number of Complaints Assessment and eligibility 4 Commissioning Decisions 16 Complaints Handling 1 Medicines Management 2 Primary Care 1 Secondary Care 2 Staff Attitude 1 The highest number of complaints (16) related to commissioning decisions and these are broken down as follows: Type of Commissioning Decision Number of Complaints Individual Funding Request 2 IVF 6 St Helier Proposed Reconfiguration 2 Norfolk Lodge Closure 2 Use of Better Services Better Value 2 Continuing Care Funding Decisions 2 The majority of commissioning decision complaints are related to IVF funding, and the decision making associated with this. It is of note that this is a theme across all CCGs for which the SLCSU provides a complaints service in the South West Area (Croydon, Sutton and Merton) but is not as prevalent in the South East Area (Southwark, Lambeth and Lewisham). Extracts from complaint letters received related to IVF funding: My husband and I have been trying to conceive for over a year. I am 39 and my husband is 42. I understand that the CCG does not fund IVF but I would like to plead with you to make an exception and fund one cycle of IVF. We both had fertility tests done through St Helier Hospital. All the doctors and the nurses we encountered were absolutely brilliant helpful and understanding. We have been advised to consider IVF. For us to fund this ourselves would be financially challenging. If you assist us in starting a family we would be ecstatic. Having attempted unsuccessfully to conceive naturally for over six months I consulted with my GP as I am over 35. Following a number of tests and consultations I was diagnosed with unexplained infertility..treatment was not successful in helping me to conceive. The doctor said she would now recommend IVF as the next treatment option. I meet the eligibility criteria as set out by NICE. 4

As a result of complaint feedback and a review of services commissioned by the CCG and an increase in resource allocation, the decision was announced in September 2014 that women aged 42-years-old or younger who meet the criteria could have one cycle of IVF paid for by Merton Clinical Commissioning Group (CCG) which has reversed a decision to stop funding., made by the previous commissioning organization, the Sutton and Merton Primary Care Trust (SMPCT). Non CCG Complaints Of the 50 complaints received during 2013/14, 23 complaints were not directly related to the CCG. The service areas for these complaints are listed below: Service Type Number of Complaints Acute and Community Hospital Services 11 Dentistry 1 GP 5 Local Authority/Social Services 2 Mental Health Services 2 111 Service 1 NHSE 1 All complaints relating to acute and community hospital services were re-directed to the relevant hospital complaints team, local authority and social services complaints to the local complaints teams and primary care complaints to NHS England. Seven of these complaints related to care and treatment and five to access and eligibility. It is of note that there were two complaints relating to continence pads for children this is also a theme that has arisen in Sutton borough. 3. PALS CCG PALS Enquiries Of the 117 PALS enquiries received in 2013/14, 78 were directly related to the CCG. The themes are tabulated below: Theme Number of PALS Enquiries St Helier Hospital Proposed Reconfiguration 49 Contact Information 3 Assessment and Eligibility 5 Commissioning Decisions 14 Request for Policy 1 Continuing Care Discharge Planning 1 Case Update 1 Ombudsman Query 1 111 Query 1 Payment of Orthodontist 1 Compliment 1 5

The highest numbers of PALS enquiries related to residents concerns about the consultation regarding the proposed reconfiguration of services at St Helier Hospital. Information about the consultation process was sent out to all enquirers. Whislt Epsom and St Helier Hospital host commissioners of Sutton CCG, the majority of those raising concerns via the PALS team were Merton MPs (43 in total see MP Enquiries section of report). In other local CCGs, the highest number of PALS enquiries relate to contact details within the CCG. This is not the case for Merton CCG where the numbers are significantly lower than other areas. Merton CCG website states that general enquiries should be directed to the CCG and provides the local email address. There is information about the PALS team on the website, however it is likely that most enquiries regarding who to contact within the CCG are dealt with directly through the local email address. As with complaints, PALS enquiries relating to commissioning decisions relate to enquiries about the processes around funding and queries about who would fund various treatments. Five of these related to queries about the progress of IFR. There was one compliment received via the Pals and Complaints team from a member of Merton & Sutton Carers & Users Support Group writing a thank you letter to the Director of Commissioning & Planning at Merton CCG, thanking the CCG for being able to part fund a community post (carers support worker). Non CCG PALS Enquiries Of the 117 PALS enquiries received in 2013/14 by Merton CCG, 39 were not directly related to the CCG. The service areas for these PALS enquiries are tabulated below: Service Area Number of PALS Enquiries GP/Primary Care 20 NHS England 5 Community Services 5 Dental Services 4 Acute Hospital 3 Local Authority 1 General Enquiry 1 The PALS enquiries relating to GP and Primary Care were requesting either contact information or support with registering with a GP in the area. MP Enquiries There were 78 MP enquiries received during 2013/14, 17 were complaints (one of which was a legacy complaint) and 61 were PALS enquiries. Of the 61 PALS 6

enquiries received from MPs, 43 of these were received in May 2013 and concerned the future plans for St Helier Hospital and the consultation about the services. There were no other significant themes. An example of other MP enquires are provided below: Enquiry regarding continuing care since discharge from hospital Enquiry relating to waiting times at SGH, which was being monitored by the CCG/SLCSU Enquiry asking about the work and staffing of the home birth service MP enquiry about what services are available from children s centres in the Borough Two enquiries related to CCG decisions not to provide funding for medicines 4. Comparison with other Boroughs In terms of PALS and complaints numbers, Merton CCG has had a comparable number of PALS enquiries compared to neighbouring CCGs and a comparable number of complaints compared to the other London boroughs which purchase the service from the SLCSU. East Surrey CCG have been excluded from this data as the SLCSU only took over the complaints and PALS management service from them in October 2013. PALS: Borough Number of Direct PALS Enquiries Number of non-ccg PALS Total Number of PALS Enquiries/100000 head of population Croydon 142 123 265 72 Southwark 66 154 220 76 Lambeth 37 98 135 40 Merton 78 39 117 58 Sutton 50 65 115 63 Lewisham 22 91 113 39 Merton CCG received the 4 th highest number of PALS enquiries during 2014/14, also reflected in the number of PALS enquiries per 100,000 head of population. 7

Complaints: Borough Number of Direct Complaints Number of non-ccg Complaints Total Number of Complaints/100000 head of population Croydon 34 49 83 22 Sutton 29 45 74 41 Lambeth 12 43 55 16 Merton 27 23 50 26 Lewisham 16 31 47 16 Southwark 4 18 22 7 Merton CCG received a comparable number of complaints to other CCGs, although significantly fewer than either Sutton CCG or Croydon CCG. The themes from the PALS and complaints across the boroughs is similar, with the exceptions being where there have been specific issues in a borough, for example the proposed reconfiguration or closure of a service. Merton CCG received a high number of PALS enquiries relating to the proposed reconfiguration of St Helier Hospital. 5. Conclusions and Recommendations It is of note that Merton CCG receives a comparable number of PALS enquiries and complaints to the other boroughs, with Croydon CCG being outliers in terms of volume. The key recommendations for consideration: 1. Consideration should be given to triangulating the data with the numbers of enquiries to Merton CCG general enquiries email, which may give a wider picture of the numbers of people contacting the CCG and types of enquiry that may be handled without being passed to the SLCSU. 2. Consideration should be given to strengthening links with NHS England in the management of complaints and PALS to ensure that there are clear lines of communication and a clear pathway for complainants and enquirers so that the potential for dissatisfaction with the handling of complaints is reduced. 3. Greater emphasis on understanding the characteristics of complainants in Merton. 8

Appendix 1: Complaints Equality and Diversity Since 1 October 2013, the complaints team have sent an equality and diversity questionnaire to all complainants with their acknowledgement. Of 147 forms sent out, 23 have been returned. This means that while the information contained in this section of the report is of interest, it is not possible to state that it is reflective of all those who have made a complaint. The forms are anonymously completed, and there is at present no way of differentiating between CCGs. Given the small numbers returned, the data will instead provide an overview of the demographic factors relating to the complainants who have returned the form, with a limited analysis and recommendations made. There is limited access to demographic data, and the comparisons and reflections contained within this section of the report should be considered with a note of caution as a result. Ethnicity Of the 23 forms returned, 17 of the complainants identified themselves as white British. The last census (2011) identified that 92% of people in England identified themselves as white, although the data available does not give any further depth into the nationality of the population. As an average across the south London boroughs and East Surrey, where CCGs have purchased the complaints service from SLCSU, the proportion of those identifying themselves as white British is 62%. There are of course extremes to this data, as Merton, Lewisham and Lambeth report a comparably low percentage of white British population; whereas Surrey (there is no specific data for East Surrey available), Sutton and Croydon reports a high percentage of the population as white British. 9

Overall this indicates that the ethnicity of complainants loosely reflects the demographic of the populations served, although it may indicate that in areas such as Merton, Lambeth, Southwark and Lewisham more consideration needs to be given to engaging those within the population from ethnic minorities and encouraging their feedback. Gender There is little data available regarding the gender mix in each of the boroughs served. The only clear data relates to Croydon, where there is reported to be a 55/45 split of male to female population. The complainants who returned the equality and diversity form are predominantly male, but this is tempered by 5 respondents who chose not to disclose their gender. Sexuality and Marital Status There is, again, little data relating to stated sexuality of borough residents. It is of note, that Lambeth is reported to have the 6 th highest numbers of civil partnerships in England, and the 2 nd highest proportion of single people. 10

19 of the 23 complainants who returned the questionnaire identified as heterosexual, and this seems to be reflected by the data relating to marital status, where 16 respondents stated they are married (this is as opposed to being in a civil partnership or co-habiting). Of the respondents only 4 identified that they are single. This indicates that especially in terms of Lambeth residents, those responding to the questionnaire are not obviously representative of the population. Age Lewisham and Lambeth are among the youngest boroughs in England, with Lewisham having a population where 25% of people are under the age of 19, the average age of Lewisham residents being 34 years old. Anecdotally, Sutton reports a high number of elderly residents. As the graph above shows, half (12 out of 23) of respondents are between the ages of 46 and 65 years old. The 5 respondents who are over 66 years old have specified their ages on the questionnaire, and are all over 75 years old. Given the youth of at least 2 of the boroughs, there is further consideration needed as to how to capture the views and encourage feedback and complaints from those under 35 years old, and especially young adults. There has been some preliminary work with Lewisham CCG to develop a leaflet giving young people age appropriate information about how to complain to or about the CCG or its services, but this is still in its infancy. Religion There is, again, virtually no readily available information relating to religious beliefs. In Southwark 28% of people define themselves as non-religious, but there is no opportunity to compare this with other boroughs. 11

While the majority of complainants who responded identified as Christian, without comparative data, there is no analysis possible. Disability The majority of respondents identified as having no disability. Others, who stated that they were either registered or unregistered disabled detailed their disabilities and long term conditions in the questionnaire as additional information. The majority of those who identified themselves as unregistered disabled (4 out of 5) cited mobility problems as their disability; whereas those who identified as registered disabled cited a number of co-morbidities and complex needs. Conclusion There have been very few forms returned to the SLCSU as noted in the introduction to this section. The data that has been collated would seem to indicate that complainants, in a very general sense, are white British married heterosexuals between the ages of 46-65 who have no disability. While this information may appear to have little relevance and not reflect accurately the demographic of the populations served, it is of note that other research and studies of demographics of complainants have reached the following conclusions: Those aged over 30 are more likely to complain Men are more likely to complain than women Active complaining is associated with active information seeking behaviour and linked to upscale demographics It is usual for over 70% of complaints to be received from those identifying as white (PPO, 2011; Moyer, 1984; Warwickshire Police, 2013) 12

These conclusions fit well with the sparse information collected regarding CCG complaints, and serve as an indicator of the sectors of the population who are most likely to complain and to respond with information to questionnaires. The next stage, to enable more CCG specific data to be collected, is that from 1 April 2014 the questionnaires will be sent out with the name of the CCG the complaint relates to being on the form. The challenge in the future is how the SLCSU and CCG colleagues work together and with their communities to empower a more diverse pool of complainants to give feedback and actively seek information about CCG services. 13