Consultation on changes to the Data on Written Complaints in the NHS – Primary Care (GP and Dental) KO41b collection

Closed 26 Mar 2021

Opened 12 Feb 2021

Feedback updated 17 Jun 2021

We asked

Recording, managing and resolving complaints is an important part of modern service delivery and provides important feedback for service improvement. The data that is collected nationally serves multiple purposes, for example, it enables national bodies discharge their respective legal duties and responsibilities in listening and responding to public voice on the NHS. It also helps with focusing improvement and support to the NHS including providers of NHS funded services.

Practices must compile the K041b return - a mandatory data collection – to capture data and information regarding written complaints received by GP and Dental Practices.

To help reduce the administrative burden associated with this data collection, we consulted on a package of simplifying changes. Specifically, we sought feedback on the usefulness and relevance of each of the 6 separate components which make up the existing return:

  1. Organisation Details and Summary Data
  2. Age of patient
  3. Status of Complainant
  4. Service area
  5. Subject area
  6. Staff group
  7. We also asked for free text responses on all the above points and in an additional feedback section. 

    Our proposals were to streamline the current collection to ensure it delivers maximum benefit whilst reducing the burden of the data submission.

    The vast majority of respondents showed support for this approach and the chance to remove some of the burden which is associated with the completion of the return.

    There were 91 responses in total from several types of organisation, ranging from GP practices to central government bodies, summarised below:

    National organisation         4

    Primary Care provider        80

    Regional organisation        5

    Other/unknown                  2

    Completion rate of all questions in the consultation was good, though a small number of respondents did not answer all questions.

    As a result of the complexity of some of the issues raised as part of the responses we received, we will form a Task and Finish (T&F) group to help us work on the best way to implement some changes. Where possible changes will be implemented for the 2020-21 collection year, though some matters will be carried over for the 2021-22 collection.

    Once the T&F work is complete, we will issue a further update to this response along with final details of the collection systems (covering General Practice and Dentistry) and changes we will make to the data items being collected.

    To further help practices at this time, we have extended the collection window from the usual 6 weeks to 12 weeks. Improvements have also been made to the portal to address technical issues that previously occurred and to make the experience of uploading the return easier.

    The remainder of this document summarises the findings for each of the 6 components of the return – headered and numbered through each of the We asked, You said, We did sections of the response. There is a summary of our proposals, the responses, and the resulting actions, including issues to be considered by the T&F group. If you would like to be involved in this process, please contact us at, quoting ‘Involvement in Complaints Consultation’. Our intention is to encompass views from a range of stakeholders involved.

    Please refer to ‘Next Steps’ in the ‘We did’ section for details of the collection window for the 2020/21 year.

    We would like to thank everyone who made the time to respond to the consultation.

Our Proposals: 

   1. Organisation Details and Summary Data

We did not propose any changes to this section to allow the high-level overview of complaint volumes and resolution status to remain in its current format.

  1. Age of Patient

We proposed ceasing collecting this data item on the basis that it was not consistent with other statistical returns, not collected by individual age to allow bespoke analysis, and cannot be linked to the types of complaints that are submitted.

  1. Status of Complainant

As with Age of Patient, we questioned if this data item was able to offer any insight into complaints, with approximately 80% of complainants being attributed to the Patient. The status also cannot be linked to types of complaints. We proposed whether there is value in still collecting this item or amending and simplifying the categories.

  1. Service Area

We proposed removing Service Area from the collection. This is because data shows 97% of GP practice submitted complaints have been for GP Surgery and 99% of Dental practice submitted complaints have been for Dental Surgery and there is therefore little value in retaining these items when this data would still be available via the 2 separate mechanisms used for collecting data from each.

  1. Subject Area

We did not propose removing this field from the collection, but instead asked users for ways in which the current list of 40 different Subject Areas could be improved or streamlined.

  1. Staff Group

Recognising that Staff Group is also a key component of the return, we did not ask for feedback on the potential for dropping this field but suggested a replacement list to the one currently in use. We asked users to comment on the list in terms of its accuracy, potential groupings, or further inclusions/exclusions.


You said

  1. Organisation Details and Summary Data

81 respondents agreed with our proposal to keep collecting the data items in this section of the return.

  1. Age of Patient

60 respondents said that collecting age was not a useful factor in assessing and resolving complaints, and 64 said they felt the current bandings were not useful. 72 respondents (79%) said it would not be detrimental if age band were no longer included in future collections.

There were also a number of contextual responses which referred to both the burden that this data item causes.

However, some respondents did say that age was a useful metric, for example, in relation to monitoring health inequalities, and that a pragmatic solution is to bring the age bandings in line with other existing statistical collections.

  1. Status of Complainant

59 respondents stated that the current Complainant Statuses were not useful, with 72 also stating that it would not be detrimental to stop collecting the item. However, 76 responses showed support for simplifying the categories and there were a number of comments related to the importance of capturing Carers.

  1. Service Area

59 respondents stated the current Service Areas are not useful in their current guise with 71 of the 91 responses advocating its removal.

  1. Subject Area

56 respondents answered at least one of the 4 questions posed.

There was a broad selection of contextual responses in this area, which ranged from suggestions for grouping the categories, right through to acknowledgement that all the categories could be legitimate cause for complaint. A cross-section of comments on the 4 questions asked are as follows.

Are there any subject areas that could be removed and why? (45 responses)

“I would sub-select the categories to the 5 or 6 most commonly reported.”

“These categories are all possible causes for complaints.”

“There are some which are very open to interpretation in relation to which to use therefore the resulting analysis will be flawed.”

What new subject areas could be added/included and why? (26 responses)

“Streamlining the categories is necessary although I would question that whether Pandemic or COVID should be listed as an option going forward.”

“We suggest including ‘Remote Dental appointment’, ‘Remote GP appointment”

Do you have suggestions on how this list could be grouped into categories and sub-categories? (30 responses)

“There are too many, just go back to the six”

“Clinical - attitude, knowledge, error

Management - attitude, infection control, safety

Staff - attitude, skill, knowledge

Prescriptions - error, reaction to”


“Better Headings for categories would be more simplistic for instance

Appointments can be grouped as one

Refusals can all be grouped

Clinical can be grouped, to include all aspects from care planning to misdiagnosis and prescribing”

Please use the box below to expand on any of your selections above or provide any further comments on this proposal (5 responses)

“Agree [that] proposed groupings improves ease of reporting and reduces repetition.”

  1. Staff Group

Slightly over half of respondents (46) supplied answers to at least one of the questions posed in this section. The remaining 45 did not respond to any of the questions.

Of those who did respond, a range of comments were provided on this topic with the most recurring themes centring on agreement with streamlining the current list of 10 down to the 7 provided, with strong support for merging the Practitioner / Locum category.

Other emerging themes were the need for clarity over the proposed Care Professional / Other Care Professional groups and repeated comments that this entire section could be further simplified into only 2 categories Clinical and Non-Clinical groups. A number of comments were also made asking for Practice Manager to not be a standalone category as this could be usefully grouped within other categories.

  1. Additional feedback

21 users provided further comments in this free-text section.

The main theme emerging from this were broad support for the intention to streamline the return and reduce the burden involved in submission. We welcome these comments which are in line with our proposals in the consultation. Some examples of the comments received can be seen below:

“Overall I think it is important to streamline the information and group things better to be able to see more clearly where complaints are made and the reasons for them.”

“Keen to see the collection process simplified.”

“I am pleased to see the changes you are proposing.”

“Too much information is requested which simply isn’t needed.”

We did

  1. Organisation Details and Summary Data

This data item will be retained within the collection.

  1. Age of Patient

If possible for the 2020-21 collection year, we would like to reference the age categories used in the General Practice Extraction Service (GPES) at the same time as reducing the number of categories in the current list. GPES categories are in 10 yr bands (0-9, 10-19 up to 90+0) and we propose to merge some of these bands to be 4 groups, down from the current 8 options, as below;

Existing Age Categories

Proposed categories

Age 0-5

Age 0-19

Age 6-17

Age 20-59

Age 18-25

Age 60 and above

Age 26-55

Age Unknown

Age 56-64


Age 65-74


Age 75 and over


Age Unknown




The T&F group will explore implementation barriers with implementing these changes for the 2020-21 collection, for example, if they have been categorising patients to the existing categories during the year.

  1. Status of Complainant

The number of options will be reduced, seeing some merged and Carers split out to represent the continued importance of Carer Identification, as below;

Existing Status categories

Proposed Status categories











As above, the T&F group will explore implementation barriers with implementing these changes for the 2020-21 collection. If these changes can be implemented for the 2020-21 collection clear annotation on the collection tool will reference the merged categories.

  1. Service Area

This data item will be removed, starting from the 2020/21 collection.

  1. Subject Area

Part of the feedback we received indicated that making significant changes to this category for the 2020/21 collection year would cause operational difficulties for some submitting organisations. We will therefore continue to collect the existing Subjects in the 2020-21 collection.

Ahead of the 2021/22 collection the T&F group will find the best way to improve this category and communicate the results to data submitters as soon as possible.  To allow maximum time for changes to be implemented ahead of the 2021/22 return. Given the broad range of responses and some of the complexities involved in sensibly re-shaping some of these categories we will invite contributors to this consultation to help improve the list of options ahead of the 2021/22 collection.

  1. Staff Group

Similar to the issue surrounding Subject Area, the T&F group will find the best way to improve this category with a view to simplification of the existing options for the 2021/22 collection year. Any re-classification of options within this category will reference the Expanding Our Workforce workstream led by NHS England.

We will therefore continue to collect the existing Staff Groups in the 2020-21 collection.

Next Steps

Any actions identified under the ‘We did’ sections will be built into an amended collection tool being developed in-house by NHS Digital for the 2020/21 data collection. Once these developments have been made, a short testing period will commence before the collection tool is made live.


We will then continue to work with stakeholders to identify the best way to simplify the Subject Area and Staff Group categories and provide updates as soon as the work is completed.

The collection window for the 2020-21 year KO41b will open on 9th August this year and remain open for 12 weeks.

Please contact us at, quoting Involvement in Complaints Consultation, if you wish to be involved in the T&F group.


Results updated 17 Jun 2021




The NHS complaints procedure is the statutorily based mechanism for dealing with complaints about NHS care and treatment. All NHS organisations in England are required to operate the procedure according to the April 2009 Complaints Regulations.

NHS Digital currently collects data on complaints regarding:

  • NHS Hospital and Community Health Services (HCHS) – collected quarterly via the KO41a return from secondary care providers.
  • NHS primary care services – collected annually via the KO41b return from GP and Dental practices.

From these collections NHS Digital usually produce 5 publications each year. 4 publications for the quarterly HCHS complaints data and an annual report that includes the primary care complaints data and an annual summary of the HCHS data. These are available on the NHS Digital website here. The Covid-19 pandemic in 2020 had the following impact on this schedule;

  • the annual information requirement relating to the 2019-20 period was not collected to ease the pressures faced by primary care providers in responding to Covid-19. Further information can be found on the NHS Digital complaints data publication page.
  • Primary care providers were asked to continue to record and manage complaints effectively during this period for local service improvement purposes.

Why your views matter

NHS Digital are carrying out this consultation to ensure that these collections and future publications deliver maximum value for the minimum burden on NHS organisations and that all the items collected remain relevant. This consultation covers the primary care (KO41b) complaints collection.

This collection is large and places significant administrative burden on the organisations making the return, due in part to the manual nature of its collection and submission. The primary care (KO41b) return collects 84 items from GP and dental care providers. This return was last reviewed in 2015, which resulted in a revised collection for the 2016-17 return onwards.

NHS Digital is developing a bespoke web reporting tool for the submission of data by GP practices to further ease the burden on GP data providers. The NHS Digital Data Collections team will perform testing on the tool with GP Practices prior to its launch. It is expected Dental practices will continue to submit data via a web tool provided by NHS Business Services Authority (NHS BSA).

What happens next

The responses to this consultation will be analysed and preferred options will be implemented by NHS Digital.


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