Complaints Policy and Procedure

Next review: 21 June 2027
Approved by: Clinical Director / Registered Manager
Responsible person: Registered Manager

1. Purpose and Scope

Instant GP Limited, trading as Mend Clinic (“Mend Clinic”), is committed to providing high-quality, patient-centred care. We treat all complaints as an opportunity to learn, improve, and strengthen our service. This policy sets out a clear, accessible, and proportionate three-stage complaints procedure for all patients, representatives complaining on behalf of a patient, and other users of the service.

This policy applies to all Mend Clinic services, including Initial and Follow-up Consultations, the Opinion Service, Membership, Programmes, prescribing, and any related administrative or commercial interaction with the Clinic.

This policy has been written in accordance with:

• Care Quality Commission Regulation 16 (Receiving and acting on complaints)
• Health and Social Care Act 2008 (Regulated Activities) Regulations 2014
• General Medical Council Good Medical Practice
• Statutory Duty of Candour (Regulation 20)
• The Consumer Rights Act 2015
• UK General Data Protection Regulation and the Data Protection Act 2018
• The Centre for Effective Dispute Resolution (CEDR) Code of Practice for independent adjudication

2. Our Principles

In dealing with complaints we will:

• Treat every complaint seriously and confidentially.
• Be fair, impartial, and proportionate.
• Respond promptly and within published timescales.
• Provide a clear written explanation and, where appropriate, a genuine apology.
• Ensure that no patient experiences any detriment to their clinical care as a result of making a complaint.
• Use complaints to drive service improvement.
• Comply with the Statutory Duty of Candour at all times.

3. Definition of a Complaint

A complaint is any expression of dissatisfaction, written or verbal, formal or informal, about the standard of service, action, or inaction by the Clinic, its clinicians, or its staff. This includes complaints about clinical care, communication, prescribing, fees, administration, the conduct of staff, or any other aspect of the service.

A concern raised informally, where the complainant does not request a formal investigation, will be treated as a Stage 1 matter under this policy.

4. Who Can Complain

A complaint may be made by:

• A current or former patient.
• A family member, carer, or legal representative acting on behalf of a patient, with the patient's written consent or where the patient lacks capacity.
• An advocate or third party with the patient's written consent.
• A bereaved family member where the patient is deceased.

Where a complaint is made by a representative, we may request evidence of authority to act before disclosing confidential clinical information.

5. The Three-Stage Process

Acknowledgement of all complaints. Every complaint, regardless of stage, will be acknowledged in writing within 3 Working Days of receipt. The acknowledgement will confirm the nature of the complaint as understood by the Clinic, the stage at which it is being handled, the name of the person handling it, and the expected timeline.

Stage 1 — Local Resolution and First Response

Most concerns can be resolved quickly and informally at the point of contact. Patients are encouraged in the first instance to raise concerns with the staff member involved, with their clinician, or with the Patient Success Lead.

Quick resolution. The Clinic aims to resolve Stage 1 concerns within 2 Working Days of acknowledgement, particularly for operational matters such as scheduling, dose titration queries, prescription delivery, and other day-to-day issues.

Stage 1 written response. Where a Stage 1 concern cannot be resolved within 2 Working Days, or where the complainant has requested a formal written response, the Clinic will issue a substantive written Stage 1 response within 20 Working Days of acknowledgement. The response will set out the matters considered, the findings, any apology where appropriate, and any learning or changes resulting from the complaint.

Recording. Stage 1 matters resolved informally are recorded on the Complaints Register, even where no written response was required.

Escalation. If the complainant is not satisfied with the Stage 1 response, or wishes to escalate at any time, they may proceed to Stage 2.

Stage 2 — Formal Senior Investigation

If a complaint cannot be resolved at Stage 1, or if the complainant prefers to make a formal senior-level complaint directly, it will be investigated at Stage 2 by a senior member of the Clinic.

Submission. In writing to info@instantgp.co.uk, by post to the registered office, by secure platform messaging within the Mend platform, or transcribed from a telephone call and confirmed in writing with the complainant before investigation begins.

Acknowledgement. Within 3 Working Days of receipt of the Stage 2 complaint or escalation request.

Investigating officer. Stage 2 complaints are investigated by the most appropriate senior member of the Clinic, allocated according to the nature of the complaint:

• Operations Manager for complaints relating to administration, booking, billing, scheduling, communication, or non-clinical staff conduct.
• Medical Director (or Clinical Director acting in that capacity) for complaints relating to clinical care, clinical decisions, prescribing, written clinical deliverables, or clinician conduct.
• Registered Manager for complaints involving safeguarding, regulatory matters, patient safety incidents, complex complaints spanning multiple domains, or where the complaint concerns the Operations Manager or the Medical Director.

Where a complaint concerns the Registered Manager personally, or where the Clinic considers it appropriate for impartiality, an independent senior clinician or external healthcare consultant will be appointed to conduct the Stage 2 investigation.

Accountability. The Registered Manager retains overall accountability for the operation of the Complaints Procedure in accordance with CQC Regulation 16, regardless of who conducts any individual investigation.

Investigation. The investigating officer will review all relevant records, interview involved staff, and may invite the complainant to provide further information or to attend a meeting (in person or by secure video). The complainant may be accompanied or supported by a person of their choosing.

Response. A substantive written Stage 2 response will be provided within 20 Working Days of acknowledgement. If the investigation requires additional time (for example because of the complexity of the matter, unavailability of a key party, or the need for external clinical input), the complainant will be informed in writing of the reasons and a revised timeline. The Clinic will aim to conclude all Stage 2 investigations within a maximum of 40 Working Days.

Stage 3 — Independent External Adjudication

If the complainant remains dissatisfied at the conclusion of Stage 2, they may request an Independent Stage 3 Review.

Mend Clinic is a subscriber to the Centre for Effective Dispute Resolution (CEDR) independent adjudication scheme, which provides external, independent review of complaints that have completed the Clinic's internal process.

• The request for a Stage 3 review must be made within 6 months of the Stage 2 final response.
• The CEDR Adjudicator will review the clinical records, the investigation process, and the reasonableness and fairness of the Stage 2 conclusion.
• The Adjudicator's decision is final for the purposes of the Clinic's internal complaints process.
• Engaging Stage 3 does not affect the complainant's right to refer matters to an external regulator, professional body, or court at any time.

Information on how to contact CEDR will be provided in every Stage 2 final response letter.

6. How to Make a Complaint

• Email: info@instantgp.co.uk
• Post: Instant GP Limited, trading as Mend Clinic, 30 Stratford Road, Wolverton, Milton Keynes, MK12 5LW
• Secure platform messaging: via the Mend platform.
• Verbal: telephone complaints are transcribed by the receiving staff member and sent to the complainant in writing for verification before any investigation begins.

Reasonable adjustments. If the complainant requires reasonable adjustments to make a complaint (for example because of disability, neurodivergence, English not being a first language, or any other reason), the Clinic will make those adjustments. Please tell us what would help.

7. Time Limits for Making a Complaint

Complaints should ordinarily be made within 12 months of the incident or matter complained of, or within 12 months of the complainant becoming aware of it. Complaints made outside this period may still be considered at the Clinic's discretion where there are good reasons for the delay and where it remains possible to investigate the matter fairly.

8. The Written Response

A Stage 1 or Stage 2 written response will include:

• A factual summary of the matters investigated.
• A clear, point-by-point explanation of the findings on each issue raised.
• An apology where appropriate. An apology is a recognition of distress caused and is not, of itself, an admission of legal liability.
• A clear statement of any Learning Points identified.
• A clear statement of any changes the Clinic has made or will make as a result of the complaint.
• The name and role of the investigating officer.
• Information about the right to escalate (to Stage 2 from a Stage 1 response, or to CEDR independent adjudication at Stage 3 from a Stage 2 response), and the other onward routes set out at clause 11.

9. Duty of Candour

For any notifiable safety incident, Mend Clinic complies fully with the Statutory Duty of Candour (Regulation 20 of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014). The Clinic will:

• Provide a clear and timely verbal explanation to the affected patient or their representative.
• Offer a genuine apology.
• Provide a written follow-up and a record of the conversation.
• Keep the patient or representative informed of any further enquiries or investigations.
• Offer reasonable support to the patient.

The Duty of Candour applies independently of, and runs in parallel to, this Complaints Procedure. The Clinic discharges its Duty of Candour whether or not a complaint has been made.

10. Safeguarding and Serious Incidents

Where a complaint identifies a safeguarding concern, a risk to life, a notifiable patient safety incident, or a serious clinical concern, the Clinic will activate its Safeguarding Policy and Significant Event Policy in parallel with this Complaints Procedure. Where required by law or by CQC reporting obligations, the matter will also be reported to the appropriate authority without delay.

11. Further Escalation and External Regulators

A complainant may, at any time, also refer their concerns to:

• Centre for Effective Dispute Resolution (CEDR) — independent adjudication of private healthcare complaints under the Clinic's Stage 3 scheme. www.cedr.com
• General Medical Council (GMC) — concerns about a doctor's fitness to practise. www.gmc-uk.org
• General Pharmaceutical Council (GPhC) — concerns about a pharmacist or registered pharmacy. www.pharmacyregulation.org
• Care Quality Commission (CQC) — to share information about the Clinic. The CQC does not adjudicate individual complaints but monitors provider performance against regulatory standards. www.cqc.org.uk
• Information Commissioner's Office (ICO) — concerns about the handling of personal data. www.ico.org.uk
• Trading Standards / Citizens Advice — consumer concerns under the Consumer Rights Act 2015.

Nothing in this policy affects the complainant's right to seek legal advice or take legal action at any time.

12. Anonymous Complaints

The Clinic will accept and consider anonymous complaints. The ability to investigate and respond to an anonymous complaint is necessarily limited. In such cases we will record the complaint, take any action we reasonably can, and use the information to inform service improvement.

13. Vexatious or Unreasonable Complaints

In the rare circumstance that a complaint, or a complainant's behaviour during the complaints process, becomes unreasonable, abusive, or vexatious, the Registered Manager may apply proportionate restrictions on engagement (such as limiting contact to a single channel or single point of contact). Any such restriction will be communicated to the complainant in writing, with reasons, and will be reviewed periodically. This does not extinguish the complainant's right to pursue any external route under clause 11.

14. No Detriment to Clinical Care

A patient who raises a complaint will not experience any detriment to their clinical care as a result. Clinical decisions are made on clinical grounds alone. If a patient believes that their care has been adversely affected by their having raised a concern, they should escalate this immediately to the Registered Manager at info@instantgp.co.uk.

15. Records, Learning, and Governance

15.1 Complaints Register. All complaints received at any stage are recorded in the Mend Clinic Complaints Register, including: date received, complainant (or anonymous), nature of the complaint, stage, investigating officer, outcome, learning points, and changes implemented.

15.2 Governance review. The Complaints Register is reviewed at least quarterly by the Clinical Board, which considers themes, trends, and learning. Significant matters are escalated for action and, where appropriate, result in changes to policy, training, or service design.

15.3 Significant events. Complaints identifying potential clinical safety concerns are also entered onto the Significant Event Register and managed under the Significant Event Policy.

15.4 CQC reporting. Complaints data is made available to the Care Quality Commission on request and forms part of the Provider Information Return.

15.5 Confidentiality. All complaints and associated records are handled in strict accordance with the UK GDPR and the Data Protection Act 2018. Information will only be shared with those who have a legitimate need to know, and with regulators where lawfully required.

15.6 Retention. Complaints records are retained for a minimum of 10 years from closure, in accordance with the NHS Records Management Code of Practice and the Clinic's Records Retention Policy.

16. Policy Review

This policy is reviewed at least annually by the Registered Manager and the Clinical Director, and at any point following a significant incident, regulatory inspection, or change in regulatory guidance. The next scheduled review date is shown at the head of this document.