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2018 Compliance Survey Results Relating to Hotlines

The 2018 Ninth Annual Healthcare Compliance Benchmark Survey (Survey) was conducted by SAI Global and Strategic Management Services, with a total of 388 responding organizations. The Survey was designed to gain a better understanding of the status and progress of compliance program development in the healthcare industry. One aspect of the Survey focused on compliance communications channels. The Department of Health and Human Services (HHS) Office of Inspector General (OIG), U.S. Sentencing Commission, Department of Justice (DOJ), and other authorities call for the use of compliance hotlines to: (a) permit employees to report anonymously; (b) offer confidentiality for those that identify themselves; and (c) avoid non-retaliation or reprisals for reporting potential violations of laws, regulations, and/or the company’s code of conduct or policies. The most widely-accepted compliance communication channel is a hotline that is available 24/7 to receive complaints, concerns, and allegations of wrongdoing. Virtually all healthcare entities maintain a hotline to channel employee concerns, allegations, and complaints. Eight out of ten surveyed entities use outside vendors to answer their hotline.

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Over half of the surveyed respondent organizations use internal hotlines, either as the only means to receive hotline calls or in addition to a vendor hotline. In either case, the respondents revealed that the internal hotline is not a properly qualified hotline that guarantees anonymity, as the calls can be traced back to their origin. Furthermore, an internally operated hotline is rarely effective.    For example, voice-mail based hotlines are sub-optimal. First, there is the larger question of whether voice-mail reporting can be classified as hotline reporting in the first place. Recording an individual’s voice clearly violates the anonymity standard called for by the OIG. Also, the source of the call can, in most cases, be identified through phone records. Such hotlines not only fail to assure anonymity for the reporter, they also do not permit debriefing of complainants unless they formally identify themselves. Despite these concerns, four out of ten Survey respondents indicated using voice-mail reporting. Note that email-based hotlines are also problematic. While the reports may contain useful information, the reports themselves are not secure. Email reports do not provide the opportunity for anonymity or confidentiality.

Evidence suggests that most employees lack confidence in discussing sensitive information with another employee of the same organization. This remains one of the most significant issues with internal hotlines. If employees cannot or do not feel comfortable reporting internally, they will do so outside the organization, causing potentially greater damage to the organization. Using a professional ethics hotline provider is thus an all-around best practice.

A full report and analysis of the 2018 Healthcare Compliance Benchmark Survey will be available at the 22nd Annual Compliance Institute in Las Vegas, from April 15-18, at the booths for SAI Global (#1403) and Strategic Management Services (#412). Richard Kusserow will be at booth #412 to answer any questions concerning the Survey results and implications.

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Our compliance experts can provide detailed information on what a confidential compliance and ethics hotline should look like in the health care industry. For questions about our ethics compliance hotline services or any of our other compliance program services, please feel free to contact our experts online, or give us a call at (703) 683-9600.

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