Complaints and Appeals Procedure (ASF-GOV-005)

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1. Purpose

1.1This procedure establishes the routes by which complaints about ASF’s conduct and appeals against ASF’s accreditation decisions are submitted, handled, and resolved. Both routes are accessible, transparent, impartial, and free of charge.

1.2Both routes are aligned with ISQua EEA Principle 7 (Complaints and Appeals) and ISO/IEC 17021-1:2015, clause 9. Neither route affects the right of any party to seek remedy through external legal or regulatory processes.

2. Overview — Complaints vs Appeals

2.1The two routes are separate, distinct, and non-interchangeable:

3. Section A — Complaints Procedure

3.1 What Constitutes a Complaint

3.1.1A complaint is an expression of dissatisfaction with any aspect of ASF’s conduct or operations that does not concern a specific accreditation decision. Complaints may relate to: (a) surveyor conduct during a survey — discourtesy, bias, failure to follow protocol, or impartiality breach; (b) committee member conduct; (c) ASF’s failure to follow its published policies; (d) quality, clarity, or timeliness of ASF communications; (e) accuracy of information on france-asf.fr; or (f) any other conduct concern not involving a challenge to a specific decision.

3.2 Who May Submit

Any person with a legitimate interest may complain, including: current applicants, accredited organisations, or refused facilities; surveyors or committee members contesting a conduct allegation; patient representatives; and any other person directly affected. Anonymous complaints are accepted and investigated where sufficient factual detail is provided.

3.3–3.4 Timeframes and Submission

Complaints must be submitted within 90 calendar days of the event or of becoming aware of the relevant facts. Submit in writing to ASF at the contact address on france-asf.fr, including: name and contact details; specific conduct complained of; date(s) of events; supporting evidence; and the outcome sought.

3.5 Complaint Handling Process

3.5.1ASF acknowledges receipt within 5 working days and assigns to the President (or SDC Chair if the President is the subject).

3.5.3A written finding is issued within 30 calendar days of acknowledgement, stating: whether upheld, partially upheld, or not upheld; the reasons; and any corrective action. Where 30 days is insufficient, an interim update and revised timeline are provided.

3.5.4Where upheld and involving an individual, the matter is referred for action under ASF-GOV-003 (impartiality breaches) or ASF-OPS-002 (surveyor competency concerns).

3.6 Register and Escalation

All complaints are recorded in the ASF Complaint Register (reviewed at annual management review, ASF-QMS-002). A complainant not satisfied with the outcome may request a review within 14 calendar days, conducted by a person not involved in the original investigation — that finding is final within ASF’s internal processes. Beyond this, the complainant may raise concerns with ISQua EEA or seek external remedy.

4. Section B — Appeals Procedure

4.1 What May Be Appealed

The following ADC decisions may be appealed: (a) non-accreditation following a full survey; (b) Conditional Accreditation (where the appellant contends full accreditation was warranted); (c) suspension of accreditation; (d) withdrawal of accreditation; and (e) a CAP review outcome resulting in any of the above. A decision to grant full accreditation is not subject to appeal.

4.2 Grounds for Appeal

An appeal must be based on one or more of: (a) Procedural irregularity — the process did not comply with ASF’s published procedures in a way that materially affected the outcome; (b) Factual error — the decision was based on a material error of fact; (c) Disproportionate weighting — criterion findings were weighted inconsistently with the ASF classification framework; or (d) New material evidence — evidence not available at the time of survey that would materially affect the assessment. Disagreement with professional judgement alone is not a valid ground.

4.3–4.4 Timeframe and Submission

Appeals must be submitted within 30 calendar days of formal notification of the decision. Submit in writing including: the specific decision and reference number; the grounds from clause 4.2; all supporting evidence; and the outcome sought. Incomplete submissions are returned with a description of what is missing.

4.5 Preliminary Review

ASF acknowledges receipt within 5 working days and reviews whether: (a) submitted within the timeframe; (b) the decision type is appealable; (c) the grounds are within the permitted grounds; and (d) the submission is sufficiently complete. An appeal failing any criterion is declined with written explanation. Appeals passing all criteria proceed to the Independent Appeals Panel.

4.6 Independent Appeals Panel

4.6.1The IAP is constituted for each appeal and comprises: (a) a Chair — senior professional with accreditation, quality management, or dispute resolution experience, independent of ASF and the appellant; (b) a clinical expert relevant to the facility type; and (c) a governance or quality systems expert, independent of the original survey team.

4.6.2–4.6.4No original survey team member or ADC member who issued the decision may serve on the IAP. All IAP members complete a Declaration of Impartiality before constitution. IAP members are not remunerated by the appellant — ASF bears the cost, ensuring cost is not a barrier.

4.7 Hearing and Determination

The IAP receives the complete appeal submission, the original survey report, the ADC decision record, and ASF’s written response (submitted within 15 calendar days). The IAP may invite oral representations by video conference. The IAP issues a written determination within 45 calendar days of constitution, stating whether the appeal is upheld, partially upheld, or dismissed, and specifying whether the decision is affirmed, modified, reversed, or a new survey ordered. The IAP determination is final within ASF’s internal processes.

4.8 Effect on Accreditation Status During Appeal

Submitting an appeal does not automatically suspend or reverse the decision. The accreditation status at the time of appeal remains in effect until the IAP determination, unless the IAP Chair grants a stay of the decision on grounds that there is a prima facie case and that continued suspension or withdrawal would cause serious and irreversible harm.

5. Systemic Learning

The Complaint Register and Appeals Register are reviewed at the annual management review (ASF-QMS-002), examining: numbers and types received; proportion upheld; patterns indicating systemic issues; adequacy of corrective actions; and whether findings indicate a need to revise standards or policies. Anonymised, aggregated summaries are published in ASF’s annual transparency report. Individual decisions are not published without consent of the parties.

6. ISQua EEA Alignment

This procedure addresses ISQua EEA Principle 7 (Complaints and Appeals): clear distinction between complaints and appeals; defined submission and response timeframes; independence of appeals decisions from the original decision-makers; accessibility (free of charge); and systemic learning from outcomes. The ASF ISQua EEA Crosswalk (ASF-EV-004) maps these provisions to the applicable EEA criteria.

7. References

Document code: ASF-GOV-005  ·  Version: V3.0  ·  Effective: 2026-09-30  ·  Next review: September 2031  · 
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ASF-GOV-005 — Complaints and Appeals Procedure · Version V3.0

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