When we speak of government accountability, most thoughts turn to the efficacy and legality of political leadership on issues like the economy, public health and foreign policy.
However, accountability also lies much lower down the food chain – with the professional conduct of civil servants and other government employees. This is where a much beleaguered mechanism comes to the fore: complaints. Complaints are the most readily available and direct form of public engagement with government. They can concern standards of service, staff behaviour and any action or inaction that affects an individual or group. Only one area is expressly off limits: policy. A complaint is not about how government should be run, but an appraisal of governance in practice.
Like the black box in aircraft, complaints help us to understand what happened, where things went wrong, and how to avoid a repeat scenario. This process is integral to continuous organisational learning.
Yet despite its value as a stakeholder feedback loop, the UK’s complaints system is mired in policy and procedural ambiguity.
For a start, public messaging is systemically vague. A quick scan of departmental web pages reveals an array of approaches and terminology. There are marked variations between the number of stages in a complaints process, response timescales and the degree of explanatory guidance given.
Worse still, linguistic side-stepping avoids explaining how complaints are actually assessed – they are “dealt with”, “responded to”, “answered” and, on rare occasions of seeming officialdom, “investigated”. But these statements are skin deep – the absence of supporting detail is glaring.
Interpretation is left wide open for the nuts and bolts of case handling, resolution and follow-on actions. Public understanding of, and trust in, complaints mechanisms suffers as a result. It is hardly surprising, then, that so many com plaints end up on the desk of the Parliamentary and Health Service Ombudsman.
The PHSO is a publicly-funded, independent body that arbitrates on cases free of charge. For complainants, the road to ombudsman consideration is a long one. Only after exhausting a multi-stage complaint process and securing the backing of a member of parliament will access finally be granted. Even then, there is no guarantee that a complaint will be investigated.
The PHSO is a complainant’s last hope, and, for most, figures suggest it is a forlorn one. In the 2020-21 reporting year, only 2% of the 23,124 complaints screened by the PHSO were admitted for detailed investigation. The vast major ity of referrals (81%) were discounted within just seven days of receipt dur ing the PHSO’s “initial check” stage.
The most common cause for rejection? Not being “ready” – a wonder fully bland way of saying that eligibility criteria, in some form or another, was not met. Or, put differently, in 2020-21, the PHSO deemed that 18,689 complaints were submitted erroneously.
Unfortunately, this is a recurring theme.
Over the last five years, the PHSO has rejected around 150,000 complaints, or an average of 79% of those screened annually. This begs the question: why do so many complainants get it so wrong?
The high number of PHSO referrals, and the equally high attrition rate, is a symptom of entrenched ambiguity. It boils down to a lack of consistency, clarity and ownership. Let’s discuss how to address each of these issues in turn.
Across the board, guidance and terminology should be standardised in public complaints web pages. There needs to be an agreed baseline for the description of procedural steps and the scope of avail able remedies. Moreover, reference to the PHSO’s principles of good complaint handling, as a central guiding document, should be included by default. Collectively, this common framework ensures that members of the public are appropriately channelled from the outset. This consistent signposting, in turn, supports the next area of reform: the methodology behind complaint assessment.
Clarity is desperately needed on how complaints are judged. The answer is sim ple – link the process to existing policy. Personnel management in government bodies is intrinsically process and defi ni tion driven. Recruitment and promotion in the civil service, for example, is bound to success profi les, going so far as to describe in detail the embodiment of each professional competency. Likewise, conduct is governed by the civil service code, which provides direction on what is and isn’t a demonstration of integrity, honesty, objectivity and impartiality.
It is Kafkaesque that prescriptive policies on performance and conduct exist, but their mention is entirely absent in the handling of public complaints. This needs to change. Aligning internal and external-facing procedures allows a more robust means of conceptually diagnosing the substance of concerns. The outcome is a more transparent and logical process. For this to work, though, harder decisions need to be made earlier.
Consistency and clarity are important, but ownership is everything. Public trust is undermined if responses dance around the crux of a complaint, effectively relinquishing responsibility and passing the buck in the PHSO’s direction.
True ownership is an unequivocal, comprehensive answer that draws a line in the sand on what is and isn’t conceded. A responding party should explicitly ac knowledge, in their assessment, whether there have been performance failings or breaches of a code of conduct. A structured response against each professional competence and behavioural value leaves no room for doubt. A similar, listed response to available remedies provides essential closure and a stronger, auditable footing.
The benefits of this approach are obvious. Frank and unambiguous answers not only support earlier dispute resolution, but fast-tracks learning actions and strengthens oversight.
The time for reform is now. Consistency, clarity and meaningful ownership will reap dividends for all involved, the PHSO included. A more effective and agile government awaits.
William Goodhind is a former Cabinet Office civil servant and a graduate of the Master of Public Administration programme at the University of York