Complaints and Appeals Policy

Complaints Procedure

Definition of Complaints

For the purposes of this procedure, a complaint is defined as:

"an expression of dissatisfaction with a particular situation where OTT is expected to identify the cause of the problem and to take remedial action."

OTT is committed to providing a high-quality service for all and will ensure that our customers can seek advice, provide feedback or make a complaint about any aspect of our service. This policy describes how we receive, manage, respond to and learn from complaints made about our services. All members of the OTT team are expected to understand and follow this policy when dealing with a complaint.

The key aspects of this policy are that:

• Our customers know how to complain and are confident that we will take their complaint seriously
• We will investigate all complaints and will keep the complainant informed of the findings of our investigation
• We will learn from any complaints, concerns and feedback that we receive and use these lessons to improve our service.

Information for customers

We believe that if a customer wishes to make a complaint or register a concern about any aspect of our service, they should find it easy to do so. Our code of practice for handling complaints encourages customers to let us know when our service has not met their expectations and explains how we will investigate their complaint and keep them informed.

Our approach to complaints

A complaint can be made by a customer or a person acting on their behalf if the customer has consented to the person acting on their behalf or has delegated authority to act on their behalf. A complaint can also be made by an individual who is, or is likely to be, affected by our actions, inactions, decisions or omissions.

A complaint provides us with the opportunity to identify where our systems have failed and what we can do to improve our service. In dealing with a complaint, we will

• Be open and transparent to ensure that all those involved understand the process and what to expect
• Acknowledge a complaint promptly
• Undertake evidence-based investigations
• Provide sympathetic responses within appropriate timeframes
• Identify the causes of complaints and act to prevent recurrence
• Learn lessons and implement change
• if the individual is a learner, ensure that their assessment is not adversely affected by the complaint.

Complaints process

Handling a complaint efficiently and sympathetically from the outset may encourage early resolution and avoid the need for a formal complaint process, involving investigation and formal reports. which is stressful and time-consuming for all concerned.

When making a complaint, an individual usually wants an apology and to know what happened and why, what will be done to put it right, what action will be taken immediately and to prevent the cause for complaint happening again.

Receiving complaints

All members of the OTT team must be able to receive a complaint or feedback (verbal or written) and deal with it appropriately. You should bear in mind that the individual making the complaint may not refer to their concern as a complaint.

OTT External Liaisons Coordinator, Isobel Fennell, is responsible for dealing with all complaints, unless immediate resolution is possible. The responsible person in charge of overseeing OTT complaints procedure and implementing changes where necessary is the CEO, Richard Cure.

Verbal complaints: Listen to what the individual is saying and be polite and considerate; avoid justifying the action that led to the complaint or being dismissive of the individual’s concerns. Where possible and, depending on the nature of the complaint, you should aim to resolve the matter as soon as it is received, making a note of the complaint and how you resolved it and pass the information to the External Liaisons Co-Ordinator, Isobel Fennell.

If you are unable to resolve the complaint immediately, you should encourage the individual to speak with the External Liaisons Coordinator. If the External Liaisons Coordinator is not available, you should take brief details of the complaint and arrange a convenient time for the External Liaisons Coordinator to contact the individual. Your notes should be passed to the External Liaisons Coordinator and a copy given to the complainant, together with a copy of the code of practice for handling complaints.

If the complaint requires an urgent response and the External Liaisons Coordinator is not available, you should pass the complaint to Richard Cure.

Written complaints: If you receive a written complaint (by letter or email.), you should pass it immediately to the External Liaisons Coordinator.

Acknowledgement

The External Liaisons Co-Ordinator will acknowledge the complaint in writing within three working days and enclose a copy of our code of practice for handling complaints. If a delay in acknowledging the complaint is anticipated, the reason for the delay will be explained to the individual.

The acknowledgement will include

• Confirmation that the matter will be investigated and that the individual will receive a report of the findings
• An offer to meet with the individual to discuss the complaint and gather information
• A description of how the complaint will be handles and who will be involved
• Anticipated timescales for the investigation and preparation of the report
• How the individual would like to be kept informed of progress.

Investigation

The purpose of the investigation is to

• Understand what the complaint is about
• Establish what the individual would consider to be a satisfactory resolution
• Seek the views of other team members and seek suggestions on how to resolve the matter
• Identify other useful sources of information
• Decide if any further action is required to any individual(s)
• Decide what actions are required to prevent a recurrence and disseminate learning from the incident.

We aim for the investigation to be completed and for the individual to receive the report within 10 working days) or, if the issue is complex, within 3 months. Where we anticipate a delay, we will explain this to the individual and provide an update on progress at least every 10 working days. Should the situation require it, the Governing Board will set up an Independent Panel to investigate the complaint.

Response

Before providing a written response, we will invite the individual to a meeting to discuss the findings of our investigation.

Our written response to the individual will

• Address all the issues raised and demonstrate that each has been fully and fairly investigated
• Include an apology where something has gone wrong
• Explain our conclusions and any action that we have taken as a result or explain why no further action is needed

Records

The External Liaisons Coordinator keeps full records of all complaints, investigations and responses. These records are kept securely. These records include:

• The date a complaint was received, by who and how (verbally or in writing)
• Details of the complaint and the results of the investigation
• Copies of any communications and records of telephone conversations and meetings
• The outcome of the complaint and any action that we took as a result
• Correspondence between the patient and the practice.

Learning from complaints

We adopt a no-blame approach to complaints that we receive but recognise that all feedback provides an opportunity for us to develop and improve our service. We also recognise that, depending upon the findings, further actions may be necessary.

As soon as possible after a complaint has been dealt with, we will ensure that those involved are given individual feedback. Where our investigations identify a need to improve or review our working systems, we will hold an appropriate meeting and encourage general discussion and seek and decide suggestions for improvement. Any agreed changes will be kept under review.

We will undertake ongoing monitoring of all complaints to identify trends and assess training requirements.

Timescale for making complaints

Complaints should be raised as soon as possible to ensure prompt investigation and swift resolution. Complaints must be raised within 5 working days of the problem becoming apparent.

OTT procedure for complaints is as follows:

1. Complaint submitted to OTT
   • Complaints must be put in writing and sent within 5 working days of the problem becoming apparent
2. Complaint reviewed

   The OTT staff member who receives the compliant will, within 1 working day, acknowledge it and bring the matter to the attention of the OTT Responsible Officer who will within 2 working days either:

   • Action an investigation of the complaint, to be carried out by the Head of Qualifications and Quality Assurance or by an independent person if the Head of Qualifications and Quality Assurance is involved in the matter under complaint; or,
   • Convene an Independent panel to investigate the matter in the case of serious threat to the integrity of OTT. The investigation will be led by a non-executive member of the Governing Board, who is independent of the normal day-to-day working relationships with the matter(s) raised in the complaint.
   • Consider whether the regulators should be notified of the matter and notify the Head of Qualifications and Quality Assurance of the course of action.
3. Investigation Undertaken

   The investigation is carried out and reported to the Responsible Officer within 5 working days

4. Report considered

   The Responsible Officer will consider the report and decide on the response within 2 working days, which is sent to the complainant by the Head of Quality Assurance and Standards, or, if a response cannot be decided on the evidence available, ask for further work to be carried out, which must be completed within 5 working days

5. Response made

   The Head of Quality Assurance and Standards sends the response to the complainant within 5 working days and ensure any preventative and/or corrective action is undertaken in due course. OTT will respond to the complainant by email or post within 12 working days and will take appropriate, preventative and/or corrective action required. Should the complexity of the situation mean a decision cannot be reached in this timeframe, OTT will respond to the complainant within 12 working days, explaining the reason for the delay and giving a timeframe for the decision.

6. Notifying regulators and/or other external bodies (where necessary)

   In cases where there could be an adverse effect (e.g. cases with alleged fraud or serious threat to the integrity of OTT, OTT is required to escalate the matter immediately to the appropriate regulator or other external body.

Timeline for process

• Complaint submitted
• Acknowledged by administrator within 2 working days and passed to RO
• Complaint reviewed by RO and course of action decided within 3 working days
• Investigation undertaken by Head of QA and S, or others as decided by RO
• Report sent to RO within 5 working days
• RO decides on response or asks for more work within 2 working days
• Head of QA and S sends response to complainant within 2 working days. If extra time is needed at any stage, the complainant will be informed and the delay explained.

Signed: Richard Cure Director OTT December 2024

Date for Review: December 2025