Building a better complaints system for Manitobans

Opinion

In the interest of assuring the public, particularly those with complaints in queue, that the concerns they raise with the CPSM about the care or conduct of physicians are heard and valid, it is worth providing details excluded from recent reporting.

The past 14 months have been transformative at the College of Physicians and Surgeons of Manitoba (CPSM), led by an entirely new leadership team that is deeply committed to innovation in regulatory practices.

The historical system of addressing complaints brought to the CPSM has not kept up with changing trends in the broader health system. Societal expectations of increased accessibility and transparency of processes administered by government and medical regulators have fundamentally shifted. At the same time, the delivery of health care is more complex than ever. The CPSM is responding to this by re-engineering how it handles complaints, so it can tackle complex investigations involving multiple providers and sites in a way that is accountable to the public.

This trend is not unique to Manitoba — medical regulators across the country are facing similar challenges and are at various stages of renewing their own complaints systems. These are not quick fixes and require thoughtful system engineering to achieve the desired outcomes.

The early phase of the redesign process involved direct communication with stakeholders, most crucially complainants themselves, to collect feedback about their experiences, with a focus on what worked and what didn’t.

It is essential to start with the right goal in mind. The vast majority of complaints that come to the CPSM’s attention are allegations that a physician has made a mistake. That could be in how they communicated with a patient, in their medical care or in following up a clinical encounter. The remedy to these issues is to identify the source of the error and remediate, so it doesn’t happen again. It would therefore be incorrect to assert that all investigations represent an imminent risk to the public. The vast majority of complaints stem from isolated incidents and many physicians face one or two complaints, at most, throughout their careers.

Much coverage has been afforded to the fact there are 225 open investigations, but it represents a narrow view of a much broader set of activities. First, the number of open investigations changes day-to-day. The CPSM on average receives 15-30 complaints per 100,000 Manitobans per year. While the complaint rate has been stable, the population of Manitoba continues to grow. Staffing levels have not always taken this into consideration. As with any workplace, staff turnover does impact timeliness. The loss of a seasoned investigator requires time to replace.

Additionally, not all investigations are comparable. For example, almost 20 per cent of open investigations are matters that were previously reviewed by the Complaints Committee and sent to the Investigation Committee at the request of complainants. Thus, a committee has already reviewed the care and provided recommendations for remediation if indicated. The second review requires resources and adds to the length of time needed to finalize the process.

New concerns coming in about physicians are benefiting from enhanced review and triage.

This allows the CPSM to confirm what the concerns may be and how best to resolve them. Not all concerns are best dealt with via a bespoke investigation. Concerns about medical records, for example, are best resolved by liaising with the physician to expedite resolution. Concerns about prescription renewals for controlled substances are best dealt with by our Prescribing Practices Program within the Quality Department.

Sometimes complaints require redirecting to other bodies such as Manitoba Public Insurance, or the College of Registered Nurses of Manitoba, or another health-care regulator, to resolve disputes around matters to which the CPSM does not have jurisdiction.

In the last year since these changes were introduced, we resolved 131 complaints using this approach.

We continue to expedite our response to high-profile, high-risk concerns, but we have made enhancements by implementing a Priority Review system. Triaged complaints that involve concerns over sexual boundary breaches or gross negligence are identified early and restrictions to practice can be imposed in response as an interim measure while an investigation is ongoing.

Recently, we have faced unexpected staffing challenges. This is being addressed through not only additional recruitment but also by development of new roles and capabilities. For example, the hiring of a dedicated research analyst. They will locate, assemble and summarize records and documents to ensure the investigator’s time is more efficiently focused on the investigation.

We are also building data-driven systems to more precisely track categories of complaints, workflow and outcomes, allowing us to analyze trends and be more transparent about timelines with complaints and the public at large.

We’ve re-engineered the process and we won’t see the full impacts overnight. However, Manitobans will benefit from the changes as they are implemented and additional resources will continue to be added to facilitate working through the existing backlog of complaints.

All complaints and investigation data are reported annually. As our new processes come into place, more frequent updates will become possible.

It is one thing to be critical of a system that lacks transparency; it is another to poke holes in a system that is actively implementing improvements. Casting aspersions without considering the full story creates a real danger that will discourage people from coming forward with their concerns.

The CPSM encourages members of the public to raise their concerns; this helps to continually improve the profession.

Dr. Guillaume Poliquin has been the assistant registrar of complaints and investigations at the CPSM for 12 months and has been spearheading improvements to meet the expectations of Manitobans.