1. Name of the hospital representative the patient should contact to file a grievance;
2. Specific time frames for review of the grievance and the provision of a response;
3. A mechanism for timely referral of patient concerns regarding quality of care or premature discharge to the appropriate peer review organization.
4. A provision for notifying the patient of the results of the grievance review. This notification must be made in writing and include the name of the hospital contact person, the steps taken on behalf of the patient to investigate the grievance, the results of the grievance process, and the date of completion.
5. A provision for appeal if the patient is not satisfied with the outcome of the grievance investigation.

Preliminary Review

Whenever possible, the hospital should try to resolve patient questions or concerns quickly and informally. If this is not possible, patients must be afforded the opportunity to file a formal grievance. It is essential that physicians and hospital staff who may encounter patients understand the basic grievance procedures, as they may be the first point of contact for patients. Ideally, any member of the hospital staff can start the grievance process and help the patient figure out how to file their complaint. Written procedures should be developed to explain how to receive and initiate the processing of grievances. These procedures should include the form patients can use to make their complaint and the name of the hospital representative who will coordinate the grievance investigation.

When the hospital receives an oral or written grievance, several questions need to be addressed by the "grievance coordinator." The grievance coordinator may be the patient advocate, the quality manager, risk manager, or another person designated to fulfill this role. First, the grievance coordinator must determine if the hospital is the right organization to investigate the grievance. The patient may have a complaint that deals with something outside of the hospital's control, e.g. insurance coverage, problem with another provider, etc. In this situation, the complainant should be contacted and told where the grievance should be directed. Offer to help the person file their complaint with the appropriate agency or organization.

Next, determine if the issue can be quickly resolved without the need for a formal investigation. In all likelihood, the problem can be settled without a formal grievance investigation. Even if the complaint is informally resolved, the issue and its resolution should be recorded in a complaint log, so that information on volume and nature of complaints is available for internal performance measurement functions.

If a formal investigation is needed, the designed hospital representative should acknowledge receipt of the issue and explain the process that will be followed in investigating the complaint. If the person is a current inpatient, this can be a verbal explanation but be sure the person also receives a written notice. If the person is no longer in the hospital, send a letter explaining the grievance process steps. The written notifications should provide a clear explanation of how the grievance will be resolved, describing each step in the process, the time frame for each step, and the patient's rights or responsibilities at each step. Also, inform the person of any additional options that may be available for resolving the issue. For example, Medicare patients have the right to submit a quality of care complaint to the state peer review organization.

The hospital's procedure for handling grievances should include time frames that spell out how quickly each step will occur. Many hospitals try to complete the initial grievance investigation within 10 business days. Shown below is an example of a procedure that can be used by a hospital to handle all formal complaints/grievances received from patients or families:

Step One:

An acknowledgement of receipt of the complaint is sent by the Director of Patient and Visitor Relations to the complainant within two working days. A response detailing the outcome of the complaint is sent within ten working days of receipt. When this is not possible, the complainant should be informed.

Step Two:

If the complainant is not satisfied with the response, they can ask the hospital, within twenty working days, to establish an Independent Review Panel. The complainant is required to provide a written statement saying why they are not satisfied. The Patient Advocate may help the person prepare this written statement. The Independent Review Panel is appointed by the chief executive officer with input from the medical staff if the issue involves physician practices. The panel is appointed within one week of receipt of the complainant's request for review and should complete its work within 10 working days.

The panel shall consist of at least five people that were not involved in the original complaint investigation and none of who stand to gain through a recommendation or decision adverse to the complainant. It is desirable to include the hospital chaplain as an ad hoc member of the hearing panel or another unbiased respected member of the community.

The panel will review how the complaint was originally investigated and may seek expert advice or interview the complainant. The panel can decide the complaint was properly investigated and concur with the initial outcome or over-turn the initial outcome and make other recommendations intended to settle the complaint. The recommendation of the Independent Review Panel shall be forwarded to the hospital governing board for final approval. The complainant will be informed in writing of the review results and final decision within 3 days of the governing board's action.

Appeal Stage:

Complainants may appeal directly to the Chairman of the hospital governing board if they are not satisfied with the Independent Panel Investigation.

Copyright 2000 by Brown-Spath & Associates

To Learn More: Patrice L. Spath is available for inhouse presentations on this and other health care quality and resource management topics. For further details, visit Brown-Spath & Associates on the web at: http://www.brownspath.com or write to: Brown-Spath & Associates, PO Box 721, Forest Grove, OR 97116.

Visit the web site of Brown-Spath & Associates (www.brownspath.com) for the latest information on health care quality and resource management, free up-to-date articles on contemporary performance improvement topics and invaluable training resources. Our web site is updated at least quarterly, so be sure to return often!

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