Unfortunately, mistakes or misunderstandings may also occur at rTMS International.
We naturally do our best, but despite our commitment to quality service, things may not always go to your satisfaction.

You have the option to file a complaint directly, bypassing us (see the NIP complaints procedure below). However, we hope you will first try to find a good solution together with us. If this does not succeed, you can do the following:

• File a complaint with the psychologist/psychiatrist.
  A direct conversation with the psychologist or psychiatrist is the fastest way to reach a solution. You can do this by sending a letter or email to info@rtms-international.com. Within our practice, Nikita Groenwegen is the complaints officer.
• NIP Complaints Procedure
  We are members of the NIP (Dutch Institute of Psychologists), which has a Supervisory Board that handles complaints. You can find more information at www.psynip.nl.

There are two ways to submit a complaint:

• By email: nip@klachtencompany.nl
• Via the complaints form

Complaints and Disputes Procedure for Psychological Care Wkkgz (NIP)

Bram Wernsen is affiliated with the complaints and disputes procedure for psychological care (Wkkgz), established by the NIP.

Objectives of this complaints and disputes procedure:

1. Creating an opportunity to restore the relationship between the complainant and the care provider and resolving problems within that relationship.
2. Doing justice to the individual complainant.
3. Systematically collecting complaints to gain better insight into shortcomings in psychological and pedagogical care, enabling a better response to clients’ needs and preventing similar dissatisfaction or complaints.
4. Monitoring and evaluating the data mentioned above as part of policy-making to safeguard and improve the quality of care.

Article 1 – Definitions

• Client: The natural person who wants to use, is using, or has used the care offered by the care provider. “Client” also includes “patient.”
• Complaint: An expression of dissatisfaction about an action or behavior of the care provider towards a client.
• Complainant: The person submitting the complaint: the client, their legal representative, their authorized agent(s) in writing, a relative, or a person whom the care provider refuses to consider as the client’s representative.
• Defendant: The care provider about whom a complaint has been submitted.
• Complaints officer: An impartial and independent person who, if desired, assists the complainant with submitting the complaint and guides both complainant and defendant in resolving the complaint, aiming at problem-solving and restoring the relationship.
• Behavior: Any action, omission, or decision by the defendant that affects a client.
• Complaint mediation: Guidance by the complaints officer in helping the complainant and defendant find a satisfactory resolution to the complaint.
• Care provider: Bram Wernsen, an independent care provider, who fulfills the obligations for a care provider as described in the Wkkgz (Dutch Quality, Complaints, and Disputes Care Act).

Article 2 – General

1. The care provider is responsible for a careful, effective, and timely possibility for complaint handling.
2. The care provider will carefully investigate the complaint, ensure the availability of expert assistance for the complainant by an independent complaints officer, and join a competent disputes committee.
3. The care provider is responsible for informing clients about the complaints procedure, including the availability of the complaints officer and the disputes committee.

Article 3 – Admissibility of the Complainant

1. A complaint is inadmissible if:
   1. the complaint does not concern the care provider;
   2. the complaint was submitted anonymously;
   3. the complaint was submitted by someone other than the complainants mentioned in Article 1;
   4. the complaint was submitted on behalf of a client who does not consent when their consent is required;
   5. a similar complaint by the client is already being handled or has been handled under this complaints procedure;
   6. the complaint handling under this complaints procedure has already been completed without new facts;
   7. the complaint has previously been investigated and assessed by the disputes committee for psychological and pedagogical care.
2. If the care provider and/or complaints officer considers the complaint inadmissible, they will notify the complainant in writing as soon as possible, stating the reasons and indicating how and where the complainant can appeal the inadmissibility decision.

Article 4 – Complaints Officer: Purpose and Position

1. The complaints officer’s role aims, among other things, to promote an equal relationship between the complainant and care provider and to help find an effective resolution to the problems between client and care provider.
2. The care provider guarantees that the appointed complaints officer:
   1. is not involved in the matter to which the complaint relates;
   2. focuses on achieving the most satisfactory possible resolution of the complaint;
   3. is free to perform their duties in accordance with the law, applicable professional standards, and job description, without interference by the care provider.
3. The care provider ensures that the complaints officer meets the competencies and requirements described in the professional profile drawn up by the Association of Complaints Officers in Healthcare Institutions (VKIG).

Article 5 – Tasks of the Complaints Officer

The complaints officer has the following tasks:

1. Providing low-threshold reception of complaints.
2. Providing information about this complaints procedure and other options.
3. Advising and assisting the complainant in submitting and formulating the complaint, clarifying their goals, and determining a suitable approach.
4. With the complainant’s consent, informing the defendant about the complaint and requesting cooperation in resolving it.
5. Guiding and advising both complainant and defendant in resolving the complaint and closing the process clearly.
6. Keeping both parties informed about the progress of the complaint handling.
7. Identifying bottlenecks proactively or upon request.
8. Contributing to the defendant’s quality policy.

Article 6 – Procedure for Submitting, Handling, and Closing the Complaint

1. The complainant may choose to submit the complaint first to the defendant or directly to the complaints officer, orally, by phone, or in writing (by email or letter). The defendant and/or complaints officer will confirm receipt within 2 working days.
2. When a complaint is submitted to the defendant, the defendant will endeavor to provide an initial oral or written response within a reasonable period (preferably within 7 working days).
3. If the complainant feels this does not lead to a satisfactory outcome, the defendant will inform them of the option to engage the complaints officer.
4. The complainant will receive the complaints officer’s contact details and will be asked, if possible, to submit the complaint via the complaints form (available on the NIP website).
5. If the complaint is submitted directly to the complaints officer, they will confirm receipt and contact the complainant within 4 working days. The complaints officer will explore the complaint, the background, the complainant’s goals, and possible next steps. If necessary, the complaints officer will help formulate the complaint and goals or refer the complainant to other more suitable channels.
6. The complainant decides whether to proceed with steps towards the defendant and whether to involve the complaints officer.
7. If the complainant agrees to (re)submit the complaint to the defendant, the complaints officer will contact the defendant, inform them of the complaint and the complainant’s goals, and explore the defendant’s perspective and goals. The complaints officer will discuss and advise on further steps and the defendant’s contribution.
8. The defendant will, if requested, provide an explanation of their actions and cooperate in resolving the complaint.
9. A suitable resolution will be pursued, involving the complaints officer as appropriate. The complaints officer will act as a process facilitator, guide discussions, and mediate if needed. Correspondence can be shared between the parties by the complaints officer to support transparency.
10. The complaints officer monitors progress and keeps both parties informed.
11. The complainant will receive a reasoned, written decision within 6 weeks of submitting the complaint to the care provider (via the care provider or complaints officer), stating the outcome of the complaint handling and any measures decided upon, including implementation timelines.
12. If necessary, the period may be extended by 4 weeks or longer if careful handling requires more time. The complainant will be notified in writing of the extension, including reasons and the expected completion date.

Article 7 – Complaint About Another Care Provider

1. If the complaint concerns only another care provider or institution, the care provider or complaints officer will facilitate careful transfer of the complaint to the appropriate party, referring the complainant to the correct complaints procedure or, with consent, forwarding the complaint.
2. If the complaint also concerns the actions of another care provider or institution, the care provider or complaints officer will ensure a careful transfer and coordinate a joint complaint resolution, provided the complainant is informed and agrees.
3. If the complainant does not consent, separate handling will take place for the part of the complaint concerning the care provider governed by this procedure.

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

1. If the outcome of the complaint handling is not satisfactory to the complainant, they have the right to submit the complaint as a dispute to the Disputes Committee for Psychological and Pedagogical Care.
   This option also applies if the complaint includes a claim for damages (up to €25,000) that could not be resolved with the care provider or their insurer.
   The complainant may also submit the complaint to the disputes committee if the handling exceeds the time limits specified in the Wkkgz or agreed with the complainant.
2. The care provider will inform the complainant about the option of submitting the complaint as a dispute and provide the relevant contact details, deadlines, and cost information.
3. The Rules of Procedure of the Disputes Committee for Psychological and Pedagogical Care form an integral part of this regulation and can be viewed at psynip.nl/klachtenregeling.

Article 9 – Registration, Documentation, Archiving, and Retention

1. The care provider or defendant stores complaint-related records separately from client files.
2. The complaints officer maintains a complaint file and a record of key complaint data, ensuring privacy of complainants and defendants during documentation, registration, and storage.
3. The care provider/defendant and complaints officer will destroy personally identifiable data within 2 years after the complaint has been closed, unless there are compelling reasons to retain it longer.

Article 10 – Confidentiality

All persons involved in complaint handling are obligated to maintain confidentiality and may not disclose any information learned in that capacity beyond what is necessary for their duties.

Article 11 – Dissatisfaction with the Complaints Officer or Disputes Committee

If the complainant or defendant is dissatisfied with the performance of the complaints officer or disputes committee, they are expected to address it first with the respective body.

If this does not lead to a satisfactory outcome, the complainant or defendant may submit their dissatisfaction to the NIP, which will provide information on further handling.

Article 12 – Final Provision

In cases where this regulation leads to ambiguity about complaint handling and the parties cannot resolve it among themselves, they should contact the NIP. The director of the NIP will decide on an appropriate interpretation or amendment of the regulation.

Thus established by

Bram Wernsen
on December 19, 2023