Patient Grievances Policy

SUD Specialty Group – CA, Mental Health Specialty Group, P.A., Mental Health Specialty Group NJ, PC, and Mental Health Specialty Group KS, P.A. (collectively, “Group”) contracts with Path, CCM, Inc. d/b/a Rula (“Rula”) for management and administrative support services. Each entity within the Group and Rula may be referenced herein as a Company and, collectively, as the Companies.

Policy Statement

This policy supports the rights of patients, their families, and other interested parties to file a complaint or formal grievance regarding any issue or concern about their care or the business practices of Rula. This policy allows for the prompt resolution of a grievance, identifies a system to track trends, and provides a mechanism to improve the overall quality of care that patients receive. 

Applicability

This policy applies to all team members. For purposes of this policy, the Companies’ team members include individuals who are considered part of the workforce, such as employees, independent contractors, and other persons whose work performance falls under the direct purview of the Companies’ business practices.

Definitions

Complaint: A verbal or written expression of dissatisfaction where the complainant  (or authorized representative) requests that a complaint be filed, documented, or made “formal,” and the concern can be resolved within one team’s scope without cross-functional investigation or determination, beyond standard troubleshooting or policy explanation.

Grievance: A formal complaint that requires involvement from another team (cross-functional) to investigate, determine an outcome, or issue a formal response. Some examples may include:

• Actual or potential harm (emotional, physical, psychological, financial, legal)
• Possible legal, regulatory, or licensing violation
• Clinical safety concern or questionable clinical judgment
• Discrimination, harassment, retaliation, or patient rights concern
• Confidentiality, privacy, or security breach (including potential HIPAA issue)
• Ethical concern, boundary violation, exploitation, or abuse 

Retaliation: Any adverse action, harassment, threats, or other conduct that would discourage a reasonable person from making a report or participating in a grievance review process.

Policy

1. Anyone may file a complaint regarding patient care and/or services, team members, service providers, and/or the business practices of the Group or Rula. For the purposes of this policy, a complainant refers to anyone who files a complaint, whether or not they are a patient. 

   1. Patients are encouraged to discuss any issues with services directly with their provider; however, a patient is not required to speak with their provider about their complaint.

   2. A strict non-retaliation policy is followed. Any acts or threats of retaliation against those who file any type of grievance or complaint is strictly prohibited. 

2. Filing a Complaint or Formal Grievance

   1. A complaint or formal grievance can be filed by calling or emailing Rula Support.

   2. The Rula team member receiving the complaint will document relevant information and send it to the appropriate team for processing.

   3. If the complainant is not the patient or the patient’s guardian/authorized representative, information regarding the formal grievance will be collected from the complainant; however, the final resolution may not be shared with the complainant unless an Authorization to Release Patient Information is in the patient’s record, which indicates protected health information can be shared with the complainant.

3. Investigation of a Formal Grievance

   1. A Rula representative will reach out to the complainant within three business days to gather additional details regarding the grievance, explain the resolution process, and provide any other relevant information regarding the nature of the grievance, if needed. 

   2. Rula’s Patient Programs team and/or Clinical Quality team will lead the investigation. 

   3. Rula teams will collaborate internally as needed to investigate the grievance. 

   4. During the course of the investigation, Rula team members or others involved in the investigation, including the relevant contracted provider, could become aware of the identity of the complainant who filed the grievance. Anonymity during the formal grievance process is not guaranteed.

   5. If it is determined that the grievance is related to a violation of the privacy rights of a patient, the grievance will be reported to the Compliance team for further investigation, resolution, and external reporting according to the HIPAA Privacy Complaints protocol.  

4. Resolving a Formal Grievance

   1. Rula’s teams will attempt to resolve a grievance within 30 days of when the grievance was filed. 

   2. Any extenuating circumstances indicating that this time period must be extended must be documented in writing.  

   3. Every effort will be made to resolve the grievance satisfactorily. 

   4. If the complainant is not satisfied with the resolution, they may be referred to a member of the Quality leadership team or other appropriate internal source to have their grievance re-reviewed. 

   5. Patients may choose to file a grievance with entities external to Rula at any time.

5. Notification of Grievance Resolution

   1. The complainant will be notified (verbal or written) that the grievance has been resolved once the investigation has concluded. They will be given information pertinent to their specific request. 

      • Specific actions taken or not taken against the relevant individual (i.e. contracted provider, internal staff member) are not required to be disclosed to the complainant.  

   2. Notifications to other internal or external parties may occur as applicable.

6. The effectiveness of this process is monitored and reviewed to ensure we can continuously improve and learn from formal grievances and the grievance process. 

   1. Complaint data may be shared internally for quality assurance and continuous improvement purposes. 

   2. Additionally, grievance data may be aggregated and shared with others as appropriate or required. 

7. This policy is not intended to cover the process for team members or others associated with the Group or Rula’s business practices to make a grievance. 

8. The information captured on the Complaint Form and the Grievance Response Form will be kept for a minimum of six years in accordance with the Retention and Destruction of Compliance Documents. 

Updated January 21, 2026 20:18