Complaints Policy

Pernovia Health is committed to providing a safe, respectful, professional and clinically robust ADHD assessment service.

We recognise that there may be occasions when a patient, representative or other person is unhappy with an aspect of our service. We welcome feedback and complaints as an opportunity to address concerns, identify where something may have gone wrong and improve the service we provide.

Making a complaint will not adversely affect your assessment, clinical outcome or your ability to access our service.

You will be treated respectfully, fairly and without discrimination throughout the complaints process.

You can raise a concern or complaint about any aspect of the service you have received from Pernovia Health.

This may include concerns about:

• communication;
• appointment administration;
• accessibility or reasonable adjustments;
• delays;
• fees, cancellations or refunds;
• the conduct or behaviour of a member of our team;
• the way your assessment was carried out;
• information or explanations you received;
• confidentiality or information handling;
• clinical processes;
• our policies or procedures; or
• another aspect of your experience with Pernovia Health.

You do not need to use formal, clinical or legal language when making a complaint.

You are entitled to raise concerns about any aspect of your clinical assessment or diagnostic outcome.

However, the complaints process cannot be used to require a clinician to make, remove or change a diagnosis where, in their professional judgement, the available clinical evidence does not support doing so.

A disagreement with a diagnostic outcome does not, by itself, mean that an assessment was conducted incorrectly.

Where a complaint concerns an assessment or diagnostic decision, we will consider whether:

• appropriate assessment procedures were followed;
• relevant information was appropriately considered;
• recognised diagnostic criteria were appropriately applied;
• the clinical reasoning was supported by the available evidence;
• appropriate professional standards were followed; and
• further clinical review is warranted.

Where appropriate, a clinical complaint may be reviewed by a suitably qualified clinician who was not responsible for the original diagnostic decision.

A complaint may be made by:

• a patient;
• someone acting on behalf of a patient with appropriate authority;
• a relative, partner, carer or advocate authorised by the patient; or
• another person directly affected by the matter being complained about.

If someone makes a complaint on your behalf, we may need to obtain your permission before discussing confidential clinical information with them.

This does not prevent us from considering information provided by another person where there is a serious patient-safety, safeguarding or other lawful reason to do so.

Formal complaints should be sent to:

complaints@pernoviahealth.com

This is our dedicated complaints address. Messages sent to this address are securely directed to our monitored service inbox so that complaints can be identified and managed appropriately.

Please include, where possible:

• your name;
• your date of birth if you are a patient;
• a brief description of what happened;
• approximately when it happened;
• the aspect of the service you are concerned about;
• the outcome or resolution you are hoping for; and
• any information you believe will help us understand your concerns.

You do not need to provide all of this information before contacting us.

If you need help making a complaint or require a reasonable adjustment to use our complaints process, please let us know.

When you email our dedicated complaints address, you should receive an automatic confirmation that your message has been received.

This automatic response is intended to reassure you that your communication has reached us. It is separate from our formal acknowledgement of your complaint.

We aim to provide a formal acknowledgement within 5 working days.

The formal acknowledgement will normally:

• confirm that your complaint is being considered under this policy;
• identify any further information we need;
• explain what will happen next; and
• confirm the expected timeframe for our substantive response.

Where appropriate, we may contact you to clarify your concerns or better understand the outcome you are seeking.

Some concerns can be resolved quickly without requiring a formal investigation.

Where appropriate, we may contact you to:

• clarify an issue;
• provide an explanation;
• correct an administrative error;
• resolve a booking or communication problem; or
• agree another straightforward solution.

You do not have to accept informal resolution.

If the matter cannot be resolved informally, or you would prefer the matter to proceed as a formal complaint, it will be handled under our formal complaints process.

Formal complaints will be investigated fairly, objectively and proportionately.

Depending upon the nature of the complaint, the investigation may include:

• reviewing correspondence;
• reviewing appointment and administrative records;
• reviewing relevant clinical records;
• reviewing applicable policies and procedures;
• speaking with the clinician or team member involved;
• obtaining additional information from you;
• considering relevant clinical and professional standards;
• reviewing relevant technical or system information; and
• obtaining additional clinical or governance input where appropriate.

Where reasonably practicable, a complaint concerning the clinical judgement or conduct of an individual clinician will include review or oversight by another appropriate person.

The person whose actions are the subject of a complaint will not determine the complaint outcome alone.

We aim to provide a full written response to a formal complaint within 30 working days of receiving sufficient information to investigate it.

Some complaints may take longer, particularly where:

• the issues are clinically complex;
• several people need to provide information;
• an independent or additional clinical opinion is required;
• relevant clinicians or team members are temporarily unavailable;
• planned leave affects the investigation;
• information is required from another organisation; or
• another investigation or process affects our ability to conclude the complaint.

If we are unable to provide a final response within 30 working days, we will contact you, explain the reason for the delay and provide an updated expected response date.

We will not allow a complaint to remain open without reasonable communication about its progress.

Where appropriate, our written response will explain:

• the concerns we investigated;
• how the complaint was investigated;
• the relevant information considered;
• our findings;
• whether the complaint, or individual elements of it, were upheld;
• any explanation or apology that is appropriate;
• any action we have taken or intend to take;
• any learning or service improvement identified; and
• what you can do if you remain dissatisfied.

Where something has gone wrong, we aim to be open about it and take reasonable steps to put matters right where possible.

An apology or acknowledgement that a patient’s experience could have been better will not be withheld simply because a complaint involves clinical care.

If you remain dissatisfied after receiving our response, you may request an internal review.

Please contact complaints@pernoviahealth.com and explain which aspects of our response you remain dissatisfied with and why.

Where reasonably practicable, the review will be undertaken or overseen by someone who was not responsible for the original complaint response.

The review will consider whether:

• the original complaint was appropriately investigated;
• relevant information was considered;
• the conclusions reached were reasonable; and
• any further action is appropriate.

Following the review, we will provide our final internal response.

You are not prevented from contacting an appropriate professional regulator, statutory body or other organisation where you are entitled to do so.

The appropriate external route depends upon:

• the nature of your complaint;
• whether the service was provided in England or Northern Ireland;
• the professional involved; and
• the jurisdiction of the organisation concerned.

England

The Care Quality Commission (CQC) is the independent regulator of health and adult social care services in England.

Where CQC has regulatory jurisdiction over a service, concerns about the quality or safety of care may be reported to it. CQC does not ordinarily investigate or resolve individual complaints on behalf of patients.

Where a Distinct Mind And Co Ltd service does not require CQC registration, we will not represent ourselves as a CQC-registered provider for that service.

The Parliamentary and Health Service Ombudsman does not ordinarily investigate healthcare complaints relating solely to privately funded healthcare.

Some independent healthcare providers participate in independent complaints adjudication schemes. Where Distinct Mind And Co Ltd becomes a member of an applicable scheme, details of that independent escalation route will be made available to patients.

Northern Ireland

In Northern Ireland, the Regulation and Quality Improvement Authority (RQIA) is the independent body responsible for monitoring and inspecting the availability and quality of certain health and social care services.

Concerns may be raised with RQIA where the matter falls within its remit. Information provided to RQIA may inform its regulatory, inspection or review activities, although RQIA does not necessarily investigate or determine individual complaints.

The Patient and Client Council (PCC) may also be able to provide independent information, advice or support in relation to concerns about health and social care services where the matter falls within its remit.

The availability of an external route will depend upon the nature of the service and the jurisdiction of the relevant organisation.

Healthcare professionals working with Pernovia Health remain individually accountable to their relevant professional regulators.

Where a concern relates to serious professional conduct, patient safety or fitness to practise, you may be entitled to contact the relevant regulator.

For pharmacists, the professional regulator is the General Pharmaceutical Council (GPhC).

For doctors, the professional regulator is the General Medical Council (GMC).

Professional regulators do not ordinarily determine routine service complaints or act as an appeal body simply because a patient disagrees with a clinical diagnosis.

We encourage patients to use our complaints process first where appropriate so that we have an opportunity to investigate and respond.

However, nothing in this policy prevents you from contacting a professional regulator directly where you consider this appropriate.

Pernovia Health is a trading name of Distinct Mind And Co Ltd. If your concern relates to the way Distinct Mind And Co Ltd has collected, used, stored, disclosed or otherwise processed your personal information, you can contact us at:

complaints@pernoviahealth.com

You also have the right to raise a data-protection concern with the Information Commissioner’s Office (ICO).

Further information about how we process personal information and your data-protection rights is available in our Privacy Notice.

If a complaint identifies an immediate patient-safety, safeguarding or serious professional concern, we may take appropriate action before the complaints investigation has concluded.

This may include:

• escalation through our clinical-governance procedures;
• seeking additional clinical advice;
• taking immediate steps to reduce a potential risk; or
• referring information to an appropriate external authority where necessary and lawful.

Patient safety takes priority over completion of the administrative complaints process.

Complaints are handled confidentially.

Information will only be shared with people who reasonably need access to it to investigate, review, manage or respond to the complaint, or where disclosure is otherwise required or permitted by law.

Complaint information will be processed in accordance with our Privacy Notice and records-retention procedures.

We maintain an appropriate record of formal complaints, investigations, outcomes and actions taken.

Complaints and other feedback may be periodically reviewed to identify:

• recurring concerns;
• patient-safety issues;
• communication problems;
• accessibility issues;
• training or development needs;
• changes required to policies or processes; and
• opportunities to improve patient experience.

Where a complaint identifies an opportunity for improvement, appropriate actions will be recorded and followed up.

Formal complaint records are retained in accordance with our records-retention schedule.

No patient will be disadvantaged because they have made a complaint in good faith.

Making a complaint will not affect the clinical independence of our clinicians or the outcome of an assessment.

We also expect communication during the complaints process to remain respectful.

Threatening, abusive, discriminatory or seriously inappropriate behaviour towards clinicians or staff may result in reasonable limits being placed on the way communication is conducted.

This will not prevent legitimate concerns from being investigated.

We want our complaints process to be accessible.

If you:

• have difficulty making a complaint in writing;
• require information in a different format;
• have communication needs;
• need additional time or support; or
• require another reasonable adjustment,

please tell us.

You do not need to provide a formal diagnosis to request reasonable support.

You may also ask an appropriate representative or advocate to assist you.

Please see our Accessibility Statement for further information.