By definition, all effective compliance programs should have a hotline. It is an important avenue of communication between employees and management, in that it permits employees to report sensitive matters outside the normal supervisory channels. Both the U.S. Sentencing Commission and DHHS Office of Inspector General (OIG) call for a hotline.
Today, it is common for organizations to outsource this function. Although there are benefits to maintaining the function in-house, they are far outweighed by the advantages of outsourcing. There is no question that in-house operators may be more familiar with company policies, procedures and regulations. They know the organization and are more familiar with company resource personnel. All calls stay in the company. On the other hand, calls should never be answered in an area where others might overhear the hotline operator. Hotline numbers will need to be “backstopped” against tracing and all caller identification systems have to be blocked. People answering the calls in-house should not be highly visible to the work force. Confidence comes from neither party being known to the other. Hotline vendors have the training and experience to handle complainants. Callers are generally nervous and afraid and knowing they are providing information to an outside party generally is reassuring.
Receiving the information is only one part of the process. An organization operating its own hotline that will operate it during the 10 or 12 core working hours of operation will require more than one dedicated person to cover. Assuming one staff year costs $50,000, the overhead addition of about 25% will raise the total over $60,000. This would not cover the added costs of investigating the calls received. On top of that you must add the cost of the telephone line, the cost of the space and the cost of training and re-training operators. This could be prohibitive for a smaller organization. For example, for a company with 1,000 employees (approximately 12-20 hotline calls per year) the cost per call will be over $3,000 per call. Even for a company with 10,000 employees (approximately 120-180 hotline calls per year), the cost per call will be around $300 per call. It is advisable to shop and compare the costs of a hotline vendor service versus operating the hotline in-house. Note this approach would not permit employees to call or contact after normal work hours or during the weekend. No organization could reasonably consider afford staffing their hotline three shifts a day, seven days a week.
The following are best practice tips in evaluating hotline services:
- Cost of Operation. Compare costs of service with the cost to maintain and operate a hotline in-house. A vendor should provide its services at a set fee that can be used for comparison purposes. A good rule of thumb is that the cost of a hotline service should not be less than $3 per employee per year.
- Industry Expertise. Determine level of expertise in the health care industry. It is advisable to have a company familiar with and sympathetic to health care issues, rather than one that focuses on employee theft or other generic matters common to all industries.
- Hotline Services. In today’s environment, it is advisable to have two levels of service. The first is a web-based reporting system that prompts individual complainants, as well as the option to call and speak with a live operator. Either approach alone has its deficiencies and is not a best practice.
- Policies and Procedures. The company should be able to assist with developing operating protocols for following up on allegations and complaints received through the hotline.
- Timeliness. It is important to insist and have as part of any contract provision of a full written report within one business day of receipt of the call. For urgent matters, it should be immediate.
- Reports Provided. Reports on individual calls should be well written, clear, concise and of high quality. The manner in which the report is delivered is important. There are security problems with reports provided either by facsimile or email. This could be problematic. Web-based reporting is the most secure method, with notification of a report being provided via email.
- Insurance. Like any other vendor, the company should have at least one to three million dollars in coverage.
- Other Benefits. Most services provide other ancillary services, such as policy and procedures for hotline management, etc. Find out what they offer.