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Independent Private Health Sector Complaints Management Service


The Independent Private Health Sector Complaints Management Service


Complaints Management Service For

Independent Healthcare Providers.


1.   Summary

1.1              This program sets out the scope of service provided by the Independent Health Sector Complaints Management Service.

1.2              The secretariat for this program will be provided by the Uganda National Association of Private Hospitals.

2.   Background

2.1              It is a current requirement of National Minimum Standards (‘NMS’), which regulate independent healthcare sector providers (PFP) that each provider has in place appropriate arrangements for non–MOH individuals who wish to complain about the services provided. (A different regime applies in the MOH and is considered very likely to be part of future registrations requirements.)

2.2              The requirements are that each Independent Sector healthcare provider should have a complaints policy and operational practices that are compliant with widely accepted Standards. There are three specific issues for independent healtcare providers:

A.    the need to have a complaints policy which meets the requirements of Standard practice; and

B.     the need to have access to a Stage 3 (externally moderated) complaints process for use when required.

C.     The need to benchmark own performance

2.3              UNAPH will maintain a close working relationship over complaints management with both the District Health Officer (as the arm of government responsible for the creation and continuing review of the standards/registration criteria for the independent healthcare sector) and with the Uganda Private Medical Council (as the regulator responsible for inspection and compliance). As a result, and on the basis of co-operation between members, UNAPH will provide an industry-wide model complaints management policy which was last updated in May 2006.

2.4              UNAPH will organize  has  agreements  with  the  Uganda Private Medical Council a  complaints operating protocol under which the Healthcare Commission will allow Independent healthcare sector providers that abide by the UNAPH Code of Practice for Handling Patients’ Complaints to keep control of the investigation of complaints against them (unless it an alleged breach of the Private and Voluntary Healthcare Regulations (affecting patient safety).

2.5              The benefits to independent healthcare sector providers of an independent sector complaints management service are therefore:

•         Uganda Private Medical and Dental Practitioners Council.
•         actual and perceived independence of the Stage 3 process;
•         reduced duplication;

•         reduced cost of establishment and maintenance of a readily available, accessible adjudication (Stage 3) process;

•         rapid access, when required, to a functioning adjudication system; and

•         access to industry wide complaints experience and (anonymised) data for benchmarking purposes;

3.  UNAPH Complaint Task Desk

3.1              UNAPH Complaint Task Desk is a department supported by UNAPH for whom it is essential to comply with NMS complaints procedures. For practical purposes this potentially includes all PFP independent private providers Even for those who provide services only to NHS patients, any MOH complaints backlog with the UNAPH Complaint Task Desk may make it appropriate to consider accessing UNAPH Complaint Task Desk, providing a service for MOH patients treated in the independent sector.

3.2              UNAPH Complaint Task Desk membership provides:

•         access to experienced UNAPH Complaint Task Desk administrative staff and the infrastructure necessary to

•         maintain an up to date UNAPH Model Complaints Policy, in full consultation with District Health Officer and Uganda Private Medical Council;

•         maintain a Stage 3 (externally moderated) complaints management system,

•         publish industry - standard literature for use by patients
•         collect and publish industry wide statistical outcomes
•         access to UNAPH exclusively-retained impartial Adjudicators ;
•         costs maintained at realistic levels

3.4        Cost of the UNAPH services are divided as follows:-

•         an annual membership fee to cover general advisory and support services, and access to Stage 3 and to the Model policy;

•         specific charges for individual adjudications or complaints management services.


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