When revisions to the Grievance Interpretive Guidelines
first came on the scene back in 2004-2005, there was much anxiety surrounding the definition of a patient grievance and how comments from patient satisfaction surveys fit into the rules under the Medicare and Medicaid Conditions of Participation.
The Society for Healthcare Consumer Advocacy worked extremely hard with representatives from the Centers for Medicare and Medicaid Services (CMS) to clarify and ultimately agree to changes in the final guidelines around the question of survey comments as well as other provisions. The revised Interpretive Guidelines
were released in September of 2005 and require a formal process that is manageable for hospitals.
For those questioning how survey comments are to be treated, the definition of “patient grievance” is: “A written or verbal complaint (when the verbal complaint about patient care is not resolved at the time of the complaint by staff present) by a patient, or the patient’s representative, regarding the patient’s care, abuse or neglect; issues related to the hospital’s compliance with the CMS Hospital Conditions of Participation; or a Medicare beneficiary billing complaint related to rights and limitations provided by 42 CFR 489.”
And regarding patient satisfaction surveys, the Interpretive Guidelines
state: “Information obtained with patient satisfaction surveys does not usually meet the definition of a grievance. If an identified patient writes or attaches a written complaint on the survey and requests resolution, then the complaint meets the definition of a grievance. If an identified patient writes or attaches a complaint to the survey but has not requested resolution, the hospital must treat this as a grievance if the hospital would usually treat such a complaint as a grievance.”
I think there is a more important issue here and an opportunity for a hospital that is often missed when trying to determine what constitutes a grievance versus a complaint, and meeting the CMS guidelines for written responses within a seven-day time frame and the other requirements. That is, what do we do
with the data that is gathered to improve the experience of our patients and prevent complaints and grievances? The CMS guidelines also state that “data collected regarding patient grievances, as well as some other complaints that are not defined as grievances (as determined by the hospital) must be incorporated in the hospital’s Quality Assessment and Performance Improvement Program.”
Although CMS survey procedures remind reviewers to determine if the hospital applies what it learns from the grievance as part of its continuous quality improvement activities, it seems to me that the majority of the review process is focused on the process involved in responding to the grievance itself.
There is powerful information in the analysis of patient grievances, complaints and survey comments (positive and negative). Identifying trends in types of complaints, location, patient segment, individuals involved and a host of other possibilities is what gets us to the ultimate goal of eliminating those complaints and providing a better patient experience.
As a former patient relations professional, I can tell you that the types of complaints (or grievances) received are aligned with satisfaction data and comments received on patient satisfaction surveys. When complaints and grievances tell you that communication with patients about their treatment plan and providing information and involving them in decision making are issues; priorities from satisfaction data show the same items as the best opportunities for improvement, and survey comments provide additional confirmation.
Taking this information and acting upon it to prevent the recurrence of the same or similar kinds of complaints is where the real power of grievance processes and complaint handling lies. Armed with data from many sources of the voice of the customer takes us from reacting to the problems to being proactive and preventing problems, and leads to innovation.
It seems to me that the real power of the CMS guidelines and the process for responding to patient grievances and patient complaints is in what we do
with that knowledge to create the best patient experience possible.
“Excellence is the unlimited ability to improve the quality of what you have to offer.”
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