Patient Grievance Policy

Purpose

The purpose of this policy is to describe the structured processes by which the Husky Health Center (HHC) receives, addresses and resolves patient grievances in a fair and objective manner.

Scope

This policy applies to all patients receiving care or services from HHC.

Definitions

Complaint:

Any issue or concern about patient care, access to care, or service quality raised at the time of service.
Any post-visit verbal communications regarding patient care that would routinely have been managed by staff present if the communications had occurred during the visit.

Grievance:

Any written complaint communications by a patient or the patient’s representative regarding the patient’s care, abuse, or neglect.
Any post-care verbal communications with a complainant involving the patient’s care, unless deemed a complaint as defined above.
Any complaint that a patient asks to be considered a grievance.
Comments solicited through the patient feedback program (e.g., Press Ganey survey) are not considered grievances unless an identified patient writes or attaches a complaint that would normally be treated as a grievance.
Billing issues are not considered grievances except for Medicare beneficiary billing complaints related to rights and limitations.

Procedure

The Patient Rights and Responsibilities Notice (U3931) is given to all patients at check-in and is available upon request. This document notifies patients and their representatives of their rights, including but not limited to the right to file a complaint about their care and treatment without fear of retribution or denial of care.

Signage advising patients of rights and responsibilities, as well as contact information for complaints and grievances, is posted conspicuously within HHC and on the HHC website.

Resolution of Complaints

Patients or their representatives may file a complaint with any staff member, supervisor or manager at the point of care or service, or directly with HHC’s leadership. Staff in receipt of a complaint will directly initiate problem resolution.
If the staff member who receives the complaint cannot resolve the incident, the issue is referred to the manager of the associated department/unit/clinic.
Complaints that cannot be resolved at the point of service, as defined above, are considered grievances.
Patients may also register any complaints directly with the Washington State Department of Health, UW Medicine Patient Relations, the Accreditation Association for Ambulatory Health Care (AAAHC), Acentra Health (the Washington State Quality Improvement Organization for Medicare patients), the US Department of Health and Human Services (HHS), the UW Civil Rights Compliance Office, or any other applicable oversight or regulatory body.
Depending on the nature of the complaint and whether the staff member who receives it is designated as a confidential employee, mandatory reporting requirements may apply, including but not limited to reporting to the UW Civil Rights Compliance Office.
Grievances regarding quality of care or consent are referred to HHC’s Clinical Risk Management and Quality Committee (CRMQC).
Complaints or grievances alleging discrimination or sexual misconduct are referred to the Director of Operations, Medical Director, and Executive Director, as applicable, as well as Clinical Risk Management’s Investigation and Resolution Specialist, the UW Civil Rights Compliance Office and/or UW/HHC Human Resources.
Privacy complaints are forwarded to UW Medicine Compliance and are handled in accordance with UW Medicine Compliance Patient Information Privacy Policies.
Billing complaints are forwarded to the Director of Operations, Director of Wellness Shared Services, or their designees. Billing complaints may also originate from patients contacting UW Medicine Patient Financial Services, and HHC may forward billing complaints to UW Medicine Patient Financial Services.
Lost property complaints are managed by the manager of the unit where the patient lost the property, and/or the supervisor of the Patient Service Center.

Grievance Process

Patients or their representatives may file a grievance through various channels, including in person, by phone, by email, by fax or in writing. The preferred contact methods for receiving grievances are as follows:

Email: uwhhc@uw.edu
Phone: 206-597-5242
Fax: 206-221-0922
In writing: drop off at HHC Patient Service Center front desk, or mail to: Husky Health Center, 4060 E. Stevens Way Northeast, Box 354410 Seattle, WA 98195
In person: the Patient Service Center (Husky Health front desk) or any HHC staff member

Any HHC staff member in receipt of a grievance should immediately forward it to their supervisor or to the Health Services Manager, Director of Operations, Medical Director, or Executive Director, as applicable.

All received grievances will be investigated, including consultation with a qualified medical provider for concerns related to quality of care.

Documentation of the grievance, investigation process and resolution will occur in Safety Net, a HIPAA-compliant, QI-protected database.

Timeline for grievance process

Starting from when HHC receives the grievance:

HHC will acknowledge receipt of the grievance within 7 business days.
HHC will send a resolution letter within 30 business days.
If a grievance requires additional time for resolution, HHC will advise the patient or their representative of the timeline for the extension(s).

Content of the resolution letter

Summary of the investigation and findings.
Advisement of the right to appeal the grievance resolution.
Telephone and mailing address information for the Washington State Department of Health and Acentra Health.
Appeal requests will be reviewed by the UW Medicine Clinical Risk Management and Quality Committee (CRMQC) with representatives from HHC. The patient or their representative will receive a final written determination following the CRMQC review.

Quality Improvement

Overall trends in patient complaints and grievances are presented in the UW Medicine Clinical Risk Management and Quality Committee (CRMQC) to identify areas for quality improvement.

Compliance

This policy complies with all applicable laws, regulations, and accreditation standards related to patient grievances, including but not limited to:

Federal and State Requirements Regarding Patient Complaints and Grievances.
Centers for Medicare & Medicaid Services (CMS) Conditions of Participation 482.13 Patient’s Rights contain federal requirements.
Washington Administrative Code (WAC) 246-330-125 Patient Rights and Organizational Ethics contain state requirements.

Accreditation Requirements

The Accreditation Association of Ambulatory Health Care (AAAHC) maintains accreditation requirements for ambulatory facilities such as HHC with respect to handling of grievances and complaints.