Complaints and the Use of Artificial Intelligence (AI)

More patients are using AI tools such as ChatGPT to help write complaints. These complaints are often long, and they can contain inaccurate legal or contractual references. They may raise one issue in several different forms. This guidance helps practices respond fairly and efficiently, and gives them text to share with patients.

It builds on guidance from the Association of Greater Manchester LMCs (AGMLMC). The patient-facing section is adapted from work by Gloucestershire LMC and Lincolnshire LMC.

For advice on a specific complaint, contact West Pennine LMC through this website or speak to your Medical Defence Organisation.

Key principles

• Every complaint must be handled in the usual way, however it was written. You cannot decline a complaint because it may be AI-assisted, and you do not need to work out whether it is.
• Statutory timescales still apply. Under the Local Authority Social Services and NHS Complaints (England) Regulations 2009:
  • acknowledge within 3 working days and offer to discuss how the complaint will be handled;
  • the usual time limit for complaining is 12 months;
  • your final response must explain the right to refer the complaint to the Parliamentary and Health Service Ombudsman (PHSO).
• Follow the PHSO NHS Complaint Standards. The Ombudsman will judge any escalated complaint against them.
• Using AI may be how a patient is able to engage with you. It can help people with disabilities, communication difficulties, or English as a second language. Bear the Equality Act 2010 and reasonable adjustments in mind throughout.

Acknowledging the complaint

• Do not say or imply that the complaint was written by AI.
• If the complaint is long or the key issues are unclear, you can say the response may take longer. You can also invite, without requiring, a short summary:

"To make sure we focus on what matters most to you, you are welcome (but not required) to send a short summary covering what happened, when it happened, how it affected you, and what you would like us to do to put things right. This will not affect how your complaint is handled."

• If several letters about the same matter arrive close together, you can acknowledge them all in one reply.
• Offer an early conversation or resolution meeting where this may be more productive than written exchanges. You will still need to send a written response afterwards.
• Signpost free independent complaints advocacy. NHS Greater Manchester lists the advocacy provider for each borough on its patient services page (https://gmintegratedcare.org.uk/patient-services-faqs/).

Investigating and responding

• Start with a list of the themes you have identified. Say that because of the length of the complaint, you hope you have not missed or misunderstood anything important. If several letters arrived before your response, list the date of each one and what it added.
• Use the themes as headings so that each concern is visibly addressed.
• Check facts against the record. AI can state things confidently that did not happen, or quote laws, regulations or contract terms that do not apply. Correct inaccuracies politely and factually, and do not accept points simply because they are asserted.
• Write one thorough first response. It saves time later, because any repeat points can be answered by referring back to it.

Using AI in your own response

Practices may use AI tools that the practice or ICB has approved, for example to help structure a response. However:

• never enter identifiable patient information into a tool that is not approved (one without a DPIA, or not covered by your DSPT arrangements);
• a named member of staff must investigate, check every factual statement, and sign off the response;
• the response must address this complainant's concerns specifically, not in generic terms.

Follow-up correspondence

• Reply to reasonable new points.
• Compare each follow-up letter with your earlier response. Where a point has already been answered, refer the complainant to the relevant section and explain that you will not respond to it again.
• Keep a numbered timeline of all correspondence (Complaint 1, Response 1, and so on).

Unreasonably persistent behaviour

Occasionally, repeated correspondence about the same issues may become unreasonable. That might be because of how often it arrives, or because of its effect on staff and resources. Practices must be able to justify any action they take, and must not stop a patient raising new concerns.

Before restricting contact, discuss it as a practice. Then consider these steps:

1. Send a de-escalation letter that explains:
   • which behaviour is causing difficulty and why;
   • what you are asking the complainant to change;
   • what will happen if it continues.
2. Set a single route of contact and name one person who will read the complainant's correspondence.
3. Send a final response that:
   • summarises all correspondence sent and received;
   • explains that local resolution has been exhausted;
   • restates the complainant's right to go to the PHSO;
   • confirms that future letters will be read and filed, and will be answered only if they raise new issues.
4. Restrict contact only as a last resort, for example by blocking an email address. Any restriction must:
   • be proportionate, documented, time-limited and reviewed;
   • leave the patient able to access care and to raise new complaints.

   Speak to West Pennine LMC, NHS Greater Manchester and your MDO before restricting contact.

Keep your tone neutral and factual throughout. The PHSO may read every letter.

Further guidance

• PHSO – Using AI tools to help your complaint (https://www.ombudsman.org.uk/making-complaint/using-ai-help-write-your-complaint)
• PHSO – NHS Complaint Standards (https://www.ombudsman.org.uk/handling-complaint/complaint-standards)
• NHS England – Complaints policy (https://www.england.nhs.uk/long-read/nhs-england-complaints-policy/)
• BMA – Dealing with complaints made against you personally (https://www.bma.org.uk/advice-and-support/complaints-and-concerns/complaints/dealing-with-complaints-made-against-you-personally)
• NHS Greater Manchester – independent complaints advocacy providers (https://gmintegratedcare.org.uk/patient-services-faqs/)

First published November 2026 · Review due November 2028 · West Pennine LMC