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Responding to concerns about complaints When the RCVS asked members of the profession and public about its complaints and disciplinary system, it received a great deal of feedback – some positive, but much of it critical. Here, Luke Bishop, RCVS communications officer, describes how the process has now been overhauled with the aim of making it quicker, more efficient and a more satisfactory experience for all involved

Every year, the RCVS receives around 800 complaints from members of the public and the profession, most of which are about veterinary surgeons. The vast majority of these complaints are closed before reaching the Preliminary Investigation Committee (PIC) although advice on professional conduct may be given. Of the 20 per cent or so of cases that do reach the PIC, most are closed, often, again, with advice, or are held open to allow further monitoring and follow-up visits. Only a very small proportion of those complained about, therefore, end up in front of a Disciplinary Committee (DC) hearing, and those who do represent the most serious cases of potential professional misconduct. However, being involved in the RCVS complaints process – whether as an animal owner or member of the profession raising a concern, or as a veterinary surgeon or registered veterinary nurse subject to one – can clearly be a very stressful experience for many, whatever stage of the process they reach. While the RCVS’s Professional Conduct Department and the veterinary investigators must always be robust and fair in how they investigate complaints, there are clearly ways in which the process can be made less difficult and stressful for all concerned. When the College launched its FirstRate Regulator initiative last year, the purpose was to evaluate the organisation’s effectiveness as a regulator in consultation with the profession, the public and other key stakeholders. Gaining feedback and

Luke Bishop, RCVS, Belgravia House, 62-64 Horseferry Road, London SW1P 2AF e-mail: [email protected] 164 | Veterinary Record | August 16/23, 2014

insight into the way in which complaints were handled and processed was a key part of why the consultation was undertaken, to determine where and how improvements could be made. In their responses to the consultation, both animal owners who had made a complaint and members of the profession

‘While we never expect a complaints procedure to be popular, what our research revealed was that it was also unsatisfactory to many members of the profession and the public’ identified two main areas in which they felt the way in which complaints were handled was poor – communication and speed.

Response to concerns

At the beginning of August this year, the RCVS responded to these concerns with the introduction of a simpler and more efficient complaints system that aims to increase the speed with which complaints are dealt with and better manage the expectations of all parties. Eleanor Ferguson, head of professional conduct at the College, explains: ‘We consider these revised procedures to be a real cultural shift in the way in which we investigate complaints, with more resources and formality being directed towards the most serious cases and less serious cases dealt with more quickly and informally. ‘We have taken on board many of the frustrations that were signalled in the First-Rate Regulator consultation in terms of speed and communication and have produced 10 key steps [see box on p 165] by which we will improve the process and provide a better service.

‘This is obviously a very emotive and contentious area and, while we concede that the process will never please all complainants or members of the professions, we do now hope to see improved levels of satisfaction.’ Before going into the details of how the process has improved, however, it is worthwhile giving an overview of the results of the First-Rate Regulator consultation and the areas it identified for improvement.

Professional concerns

The First-Rate Regulator initiative consulted the profession on a wide range of issues, garnering almost 5000 responses overall. Of these, just over 200 responses were received specifically from those who had had complaints made against them over the past two years, to gauge their experiences of the complaints process. Those respondents who had been complained about reported mixed experiences of the process and how the College handled their cases. Although the majority were satisfied, a third of respondents regarded the speed with which the College dealt with complaints as poor, while a fifth rated the College’s ability to resolve the complaint as poor. The statistics, however, do not tell the full story and some comments that were provided by members of the profession made clear the impact on individuals of receiving complaints. One respondent, for example, wrote that a veterinary surgeon colleague of theirs who had been cleared of professional misconduct had found the RCVS was very helpful, but was concerned about the amount of time the investigation took and suggested that they were considering leaving the profession. Other feedback suggested that there was room for improvement in terms of

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Ten steps to improvement In order to help the profession and the public better understand the improvements, the RCVS has produced 10 steps setting out what has changed and how this will lead to a better service for animal owners and the professions: 1.  There will be a simpler three-stage structure. The process starts with an assessment and investigation stage – where appropriate this will lead on to consideration by the PIC and, finally, referral to the DC if warranted. 2.  Each investigation will be managed by a small team of three, generally one veterinary surgeon, one lay person and one case manager to make the process more agile and flexible. 3.  Investigations will take place as soon as possible to either resolve concerns

the tone and the way information was conveyed during the complaints process.

Public perceptions

In a separate survey, feedback was also received from 265 members of the public who had made a complaint to the RCVS in 2011 or 2012, and they reported similar concerns about communication and the speed of the process. For example, almost half of the respondents reported that they had only a partial or poor understanding of the College’s complaints process. Other issues raised included feeling that the system was weighed against complainants; that the College’s powers of investigation and discipline were too narrow; that complainants were not sufficiently listened to or supported through the process; and that the College did not take a proactive approach with its investigations. Commenting on the overall findings, Nick Stace, the College’s chief executive, says: ‘While we never expect a complaints procedure to be popular, what our research revealed was that it was also unsatisfactory to many members of the profession and the public. There were frustrations, for example, over the fact that there were large time intervals in between our communications, which meant that many people were unsure what stage their complaint or investigation was at. ‘Overhauling the system became one of the key priorities in our Strategic Plan for 2014 to 2016 as part of our ongoing work to become a more modern, effective and compassionate regulator. Thanks to the

quickly or enable the PIC to make a decision more quickly. 4.  There will be improved communication, including phone calls to discuss cases and establish a point of contact for queries, and regular updates and correspondence in ‘plain English’. 5.  Case managers will help to manage expectations, both of the person raising concerns and the veterinary surgeon or nurse complained about, where appropriate, by indicating possible outcomes.

months; any PIC consideration will be completed within nine months; and any DC listing will be made within 12 months [all timings are from the date that the concern was raised]. Feedback on these standards will be sought. 7.  There will be better internal controls to help meet these service standards and allocate extra resources if needed. 8.  Serious cases will be fast-tracked to the PIC – for example, those involving dishonesty, false certification and serious criminal convictions.

6. Service standards will be implemented, meaning that all concerns will be acknowledged within two days; phone calls will be made within two weeks, during which expectations will be managed; there will be an initial assessment/investigation within three

9.  Current outstanding cases will be brought in line with the new procedures as soon as possible.

hard work of the staff in the Professional Conduct Department and members of our Preliminary Investigation and Disciplinary Committees we have now developed new procedures that I believe will allay many of those concerns and make it a more streamlined and efficient process.’

both parties, will significantly reduce the ‘fear factor’ that veterinary surgeons and registered veterinary nurses feel. Simpler forms for raising concerns and guidance have been produced, which will bring greater clarity about the process to all concerned. Furthermore, a new complaint-tracking system is currently being developed, with the aim of launching it next year. The new procedures have been broadly agreed by members of the PIC and DC and were formally approved by the RCVS Council at its June 2014 meeting. The changes have also been positively received by the Veterinary Defence Society, particularly with regard to being able to resolve cases more quickly and changes to the language and method of investigation. In the autumn, a six-month trial of an alternative dispute resolution service will be launched to help establish how best to handle the large majority of concerns raised with the College that it does not have the statutory powers to investigate. Detailed plans about how this will work are currently being developed with the aim of launching the trial service before the end of this year.

Making changes

With the feedback in mind, the principal objectives of the new complaints system are to reduce the time taken to resolve a

‘We consider these revised procedures to be a real cultural shift in the way in which we investigate complaints, with more resources and formality being directed towards the most serious cases and less serious cases dealt with more quickly and informally' complaint in a fair and transparent manner and improve the way in which the College communicates with veterinary surgeons and registered veterinary nurses and complainants. One area in which immediate changes have been made is in the language of the complaints process. ‘Concerns’ raised about a veterinary surgeon or registered veterinary nurse will be considered and, if there is a case against them, then ‘cases’ will be considered by the PIC and, if appropriate, referred to the DC. The RCVS believes that changes to the language, the method of investigation and the fact that expectations about a concern will be managed with

10.  There will be more communication of, and information about, the new procedures.

n  More information about the process, and the new forms and guidance, can be found at www.rcvs.org.uk/concerns. Further details about the process are available from the Professional Conduct Department, telephone 020 7202 0789 or e-mail: [email protected] doi: 10.1136/vr.g4947 August 16/23, 2014 | Veterinary Record | 165

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Responding to concerns about complaints Luke Bishop Veterinary Record 2014 175: 164-165

doi: 10.1136/vr.g4947 Updated information and services can be found at: http://veterinaryrecord.bmj.com/content/175/7/164

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Responding to concerns about complaints.

When the RCVS asked members of the profession and public about its complaints and disciplinary system, it received a great deal of feedback - some pos...
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