How to Write a Complaints Policy That Satisfies CQC

Every CQC registered domiciliary care agency must have a complaints policy and procedure. This is not a suggestion. It is a requirement under Regulation 16 of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014. The regulation requires that complaints are received, recorded, handled, and responded to appropriately, and that any necessary action is taken as a result.

A good complaints policy does more than satisfy a regulatory requirement. It provides a structured system for identifying problems, resolving them, and learning from them. CQC inspectors treat complaints as a window into the quality of your service. How you handle complaints tells them a great deal about your culture, your governance, and your commitment to improvement.

What Regulation 16 Requires

Regulation 16 states that the registered person must establish and operate effectively an accessible system for identifying, receiving, recording, handling, and responding to complaints. It requires that every complaint is investigated, that appropriate action is taken in response, and that the complainant is not discriminated against for making a complaint.

The regulation also requires that you have a system for learning from complaints and using that learning to improve the service. This is not just about resolving individual complaints. It is about identifying patterns and making systemic changes.

What Your Complaints Policy Must Include

Your policy should cover the following areas:

• How to make a complaint: make it easy. Complaints should be accepted verbally, in writing, by email, or through a representative. Do not require complaints to be in writing. Many service users and their families find written complaints difficult.
• Who to complain to: name the registered manager as the person responsible for complaints, with their contact details. Include alternative contacts if the complaint is about the registered manager.
• Acknowledgement timescale: state how quickly you will acknowledge a complaint. Best practice is within three working days.
• Investigation process: describe how complaints are investigated, who carries out the investigation, and how the complainant is kept informed.
• Response timescale: state how quickly you will provide a full response. Best practice is within 20 working days for straightforward complaints, with longer timeframes for complex issues. If more time is needed, the complainant must be told.
• Escalation: explain what happens if the complainant is not satisfied with your response. This must include information about the Local Government and Social Care Ombudsman and how to contact them.
• Confidentiality: explain how complaint information is handled and who has access to it.
• Learning from complaints: describe how complaints are analysed for patterns and how learning is shared with staff and used to improve the service.

The Complaints Log

You must maintain a complaints log recording every complaint received, regardless of how it was received or how minor it appears. The log should record the date received, who complained, the nature of the complaint, the date acknowledged, the investigating officer, the investigation findings, the outcome, the date the response was sent, whether the complainant was satisfied, and any actions taken as a result.

CQC inspectors will review your complaints log during inspection. They look for evidence that complaints are handled within your stated timescales, that investigations are thorough, that responses are meaningful, and that learning is documented and actioned.

Distinguishing Complaints from Concerns

Not every expression of dissatisfaction is a formal complaint. Your policy should distinguish between concerns (which can often be resolved informally and immediately) and complaints (which require the formal process). However, you should still record concerns, because they may reveal patterns that need addressing.

Be careful not to downgrade complaints to concerns to avoid the formal process. If a service user or family member expresses dissatisfaction and wants it addressed formally, it is a complaint regardless of how serious you think the issue is.

Accessible Information

Your complaints procedure must be accessible to all service users. This means providing it in formats that people can understand, including easy read versions, large print, or other formats as needed. Under the Accessible Information Standard, you must identify, record, and meet the communication needs of your service users.

The complaints procedure should be given to every service user when they start receiving your service, typically as part of the service user guide. It should also be available on request at any time.

What Inspectors Look For

CQC inspects complaints handling under the Responsive and Well-Led key questions. Inspectors will check whether your policy meets Regulation 16, whether complaints are handled within your stated timescales, whether responses are thorough and empathetic, whether the complainant is informed of their right to escalate, whether learning from complaints is documented and leads to change, and whether staff understand the complaints procedure. For more on governance expectations, see our guide on registered manager documents. For broader context on building your policy library, see our ten essential policies guide.