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Updated: May 31, 2026

Using Visual and Narrative Methods to Achieve Fair Process in Clinical Care
Published on: February 16, 2011
Comparisons of patient complaint management systems in China, the United States, United Kingdom, Germany, and Japan:
Lanting Lyu1, Yanran Song2, Ruike You3
1School of Population and Health, Renmin University of China, No. 59 Zhongguancun Street, Haidian District, Beijing, 100872, China; Health Technology Assessment and Policy Evaluation Group, Renmin University of China, No. 59 Zhongguancun Street, Haidian District, Beijing, 100872, China.
Background:
In modernizing global medical governance, optimizing the effectiveness of patient complaint mechanisms is a shared goal for addressing doctor-patient conflicts and rebuilding trust in healthcare systems.
Objective:
To systematically examine the complaint handling mechanisms in five healthcare systems: China, the United States, the United Kingdom, Germany, and Japan METHODS: A three-dimensional dynamic analytical framework of "structure-process-outcome" was constructed. Based on the interactive governance theory, an in-depth analysis of the institutional structure, operational logic, and effectiveness of quality improvement in the selected countries was conducted RESULTS: The findings indicated that system design significantly influenced the efficiency and fairness of dispute resolution. The "administration-led closed-loop management" model institutionalizes a responsive complaint governance system; however, it faces structural challenges. The market-oriented system, while ensuring procedural justice, struggles with high judicial costs. Moreover, the social insurance model separates economic disputes via insurance compensation and professional mediation, though it faces urban-rural gaps and weak patient representation. The NHS model reduces litigation dependency through a hierarchical response; however, it is hindered by data-sharing barriers. The public mechanism, leveraging AI to transform complaints into quality improvement resources, faces uneven technology coverage CONCLUSIONS: The experiences of these five countries highlight that patient complaint management mechanisms are not confined to handling grievances and are essential for a healthcare system's adaptability and continuous improvement. Different patient complaint resolution system designs have unique strengths and weaknesses. Hence, we propose several suggestions, emphasizing the interaction between system design and operational processes, with a patient-centered, demand-driven, and problem-solving approach as the core.
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