REGULATIONS FOR THE COMPLAINTS AND DISPUTES PROCEDURE FOR PSYCHOLOGICAL CARE (WKKGZ), ESTABLISHED BY NIP

Zeynep Demirelli Sağ (‘’Realistic Body Therapist’’) is affiliated with the complaints and disputes procedure for psychological care under the Wkkgz, established by NIP.

Objectives of this complaints and disputes procedure are:

Creating the possibility to restore the relationship between the complainant and the healthcare provider and resolving problems that play a role within this relationship.
Doing justice to the individual complainant.
Systematically collecting complaints in order to gain better insight into shortcomings in psychological and pedagogical care, thus enabling a more effective response to clients’ needs in general, and preventing similar dissatisfaction or complaints.
Monitoring and evaluating the data mentioned under point c. for policy development, to safeguard and promote the quality of care.

Article 1 – Definitions

Client: The natural person who wishes to use, uses, or has used the care provided by the healthcare provider. “Client” also includes “patient.”
Complaint: An expression of dissatisfaction about an action by the healthcare provider towards a client.
Complainant: The person who submits the complaint, namely: the client, their legal representative, their authorized representative(s) in writing, or the next of kin, as well as any person whose request to be recognized by the healthcare provider as the client’s representative is refused.
Defendant: The healthcare provider against whom a complaint is filed.
Complaints Officer: The person who, from a neutral and independent position, offers support to the complainant when they wish to submit a complaint, and who guides the complainant and the defendant in handling the complaint, aiming at problem resolution and restoration of the relationship.
Action: Any act or omission, as well as any decision made by the defendant that has consequences for a client.
Complaint Mediation: The process by which the complaints officer supports the complainant and the defendant in seeking a satisfactory resolution to the complaint.
Healthcare Provider: Vasiliki Sarantopoulou, an independent care provider, who under this regulation fulfills the obligations of a healthcare provider as described in the Healthcare Quality, Complaints, and Disputes Act (Wkkgz).

Article 2 – General

The healthcare provider is responsible for a careful, effective, and timely process for handling complaints.
The healthcare provider will investigate the complaint diligently, ensure the complainant has access to expert support by an independent complaints officer, and affiliate with a competent dispute resolution body.
The healthcare provider is responsible for communicating the complaints procedure (including the availability of the complaints officer and the dispute resolution body) to clients.

Article 3 – Admissibility of a Complainant’s Complaint

A complaint is inadmissible if:

the complaint does not concern the healthcare provider;
the complaint does not relate to conduct covered by the Wkkgz;
the complaint was submitted anonymously;
the complaint was filed by someone other than the complainant(s) mentioned in Article 1;
the complaint was filed on behalf of a client who does not agree to it (and whose consent is required);
an identical complaint by the client is already being or has been processed under this complaints procedure (either by the healthcare provider directly or through the complaints officer);
the handling of the complaint under this complaints procedure has already concluded and no new facts have arisen;
the complaint has already been examined and assessed by the dispute resolution committee for psychological and pedagogical care.

If the healthcare provider and/or the complaints officer deems the complaint inadmissible, they will notify the complainant in writing as soon as possible, stating the reasons. In doing so, they will indicate how and where the complainant may seek a review of this inadmissibility decision if desired.

Article 4 – Complaints Officer: Purpose and Position

The involvement of a complaints officer aims, among other things, to promote or contribute to an equal relationship between the complainant and the healthcare provider and to find an effective solution for the problems that have arisen between the client and the healthcare provider.
The healthcare provider ensures that the appointed complaints officer:
- is not involved in the matter to which the complaint relates;
- focuses, in the performance of their duties, on reaching a solution for the complaint that is as satisfactory as possible;
- has the freedom to carry out their work in accordance with the law, the relevant professional norms, and their job description, without interference by the healthcare provider.
The healthcare provider ensures that the complaints officer it makes available meets the competencies and job requirements described in the professional profile compiled by the Association of Complaints Officers in Healthcare Institutions (VKIG).

Article 5 – Tasks of the Complaints Officer

The Complaints Officer has the following tasks:

Providing accessible support for complaints.
Giving information about this complaints procedure and other ways to file a complaint.
Advising and assisting the complainant in submitting and formulating the complaint, clarifying their goals when filing the complaint, and determining how best to handle the complaint.
Notifying the defendant of the complaint (with the complainant’s consent) and requesting the defendant’s cooperation in (further) handling the complaint.
Guiding and advising both the complainant and the defendant on further handling of the complaint and ensuring a clear conclusion to the process.
Keeping both the complainant and the defendant informed about the progress of the complaint’s handling.
Identifying obstacles and issues, both upon request and on their own initiative.
Contributing to the defendant’s quality policy.

Article 6 – Procedure for Filing, Handling, and Concluding a Complaint

The complainant may choose to file the complaint (initially) directly with the defendant or with the Complaints Officer. This can be done verbally, by telephone, or in writing (by email or letter). The defendant and/or Complaints Officer will confirm receipt of the complaint within 2 working days.
If the complaint is filed with the defendant, the defendant will strive to provide a (first) response to the complaint, either orally or in writing, within a reasonable period (preferably 7 working days).
If the complainant believes that this response does not lead to a satisfactory outcome, the defendant will inform the complainant about the possibility of involving the Complaints Officer.
The complainant is given the contact details of the Complaints Officer and is asked, if possible, to file the complaint via the complaints form (available, among other places, on the NIP website).
If the complaint is submitted to the Complaints Officer, after confirming receipt, the Complaints Officer will make direct contact with the complainant as soon as possible and no later than within 4 working days.
Together with the complainant, the Complaints Officer will further explore the complaint, any prior steps taken, the complainant’s goals, and possible ways to proceed with handling the complaint. The Complaints Officer will assist the complainant in formulating the complaint and clarifying their objectives if necessary. If needed, the Complaints Officer will direct the complainant toward other, more suitable options for addressing the complaint. The complainant decides whether they wish to proceed further with the defendant and whether they want the involvement of the Complaints Officer in doing so.
If the complainant agrees to (re)submit the complaint to the defendant, the Complaints Officer will contact the defendant for that purpose. The Complaints Officer will inform the defendant about the complaint and the goals the complainant aims to achieve. The Complaints Officer will ask the defendant for their view of the matter and discuss the defendant’s goals regarding the further handling of the complaint. The Complaints Officer will consult with the defendant and advise on further steps to handle the complaint and how the defendant can contribute.
The defendant will, if asked, (again) explain the actions that gave rise to the complaint and cooperate in resolving the complaint.
In consultation with the complainant and the defendant, and with the involvement of the Complaints Officer as appropriate to the case, the complaint is further processed.
The Complaints Officer acts as a process facilitator for both the complainant and the defendant in their subsequent communication and will, if desired, guide a mediation meeting between them. As part of this facilitator role, the Complaints Officer may forward any correspondence related to the procedure (between the Complaints Officer and the complainant or the defendant) to the other party.
The Complaints Officer monitors the progress of the complaint handling and keeps the complainant and the defendant informed.
Within 6 weeks after the complaint has been submitted to the healthcare provider, the complainant will receive a reasoned, written statement from the healthcare provider (possibly via the Complaints Officer) indicating the outcome of the complaint handling. This statement will also specify whether (and if so, which) decisions and/or measures have been taken in response to the complaint, and the timeline for implementing any measures decided upon.
If necessary, the aforementioned 6-week period may be extended by 4 weeks or longer if the careful handling of the complaint requires more time. The complainant will receive a written notice of this extension (from the healthcare provider, possibly via the Complaints Officer) stating the reasons for the extension and the intended timeframe for resolving the complaint.

Article 7 – Complaint About Another Healthcare Provider

If the complaint submitted by the complainant (through the healthcare provider and/or the Complaints Officer) concerns exclusively another healthcare provider or institution, the healthcare provider or the Complaints Officer will facilitate the careful transfer of the complaint to that provider or institution. He or she will direct the complainant to the correct complaints procedure or transfer the complaint (with the complainant’s consent) to the relevant provider or institution.
If the complaint submitted by the complainant also pertains to the conduct of another healthcare provider or institution, the healthcare provider or the Complaints Officer will ensure a careful transfer of the portion of the complaint concerning the other provider or institution, and coordinate with that provider or institution in order to enable a combined complaint handling and resolution.
Such a transfer and (discussion of) combined complaint handling and resolution are only possible if the complainant has been informed in advance and consents.
If the complainant does not consent, then there will be a separate handling of the complaint that only addresses the complaint about the healthcare provider to whom this complaints procedure applies.

Article 8 – Submission to the Disputes Committee for Psychological and Pedagogical Care

If the outcome of the complaint handling by the healthcare provider and/or the Complaints Officer does not yield a satisfactory result for the complainant, the complainant has the right to submit the complaint as a dispute to the Disputes Committee for Psychological and Pedagogical Care.
This option also exists if a complaint (in part) involves a request for compensation (up to a maximum of €25,000) and the complainant has not reached an agreement with the healthcare provider or the healthcare provider’s insurer regarding the compensation.
The complainant may also submit the complaint to the Disputes Committee for Psychological and Pedagogical Care if handling of the complaint takes longer than the period specified in the Wkkgz or a period agreed with the complainant.
The healthcare provider informs the complainant about the possibility of submitting the complaint as a dispute to the Disputes Committee for Psychological and Pedagogical Care and provides the complainant with the correct contact details and information about deadlines and costs for filing.
The Regulations of the Disputes Committee for Psychological and Pedagogical Care form an integral part of this regulation and can be viewed at www.psynip.nl/klachtenregeling.

Article 9 – Registration, Reporting, Archiving, and Retention

The healthcare provider (i.e., the defendant) keeps data related to complaints concerning him or her, and the handling of these complaints, separate from the client files that he or she maintains.
The Complaints Officer maintains a complaint file and a log of the key details concerning the complaint and its resolution. In creating and keeping these records, as well as storing the complaint file and complaint log, the privacy of complainants and defendants is safeguarded.
The healthcare provider/defendant and the Complaints Officer destroy any data traceable to individuals (complainant or defendant/healthcare provider) within two years after the complaint process has concluded, unless there are compelling reasons to keep it longer.

Article 10 – Confidentiality

All persons who, by virtue of their position or otherwise, are involved in handling complaints submitted to or about the healthcare provider are obliged not to disclose any information they become aware of in this capacity, other than what is required for the performance of their duties.

Article 11 – Dissatisfaction with the Complaints Officer or the Disputes Committee

If the complainant or the defendant is dissatisfied with the conduct of the Complaints Officer (as referred to in this regulation) or with the Disputes Committee, they are expected to raise this issue first with the relevant authority.
If this does not lead to a satisfactory outcome, the complainant or the defendant may submit their dissatisfaction to the NIP. They will then receive information about how their concerns will be handled further.

Article 12 – Final Provision

If the provisions of this regulation result in ambiguities about how to handle a complaint, and if those involved are unable to resolve the matter among themselves, they will contact the NIP. The director of the NIP will then make a decision on the appropriate interpretation or adaptation of the regulation.

Thus established by

Zeynep Demirelli Sağ

on January 10, 2025