Open Communication as a Two-Way Channel
A culture of open communication in an organization creates a two-way channel when it comes to remaining compliant— a Compliance Department-to-workforce channel and a workforce-to-Compliance Department channel. With the ever-changing nature of the healthcare regulatory environment, effective communication in both channels is critical for successful compliance operations.
Considering the first channel, Compliance Officers are responsible for communicating regulatory updates from the U.S. Department of Health and Human Services Office of Inspector General (OIG) and Centers for Medicare and Medicaid Services (CMS) as they are issued. Maintaining effective communication with the workforce on these updates is critical for Compliance Officers. They must inform the rest of the Compliance Department and organizational staff on the latest laws and regulations, CMS coding and billing requirements, and internal company policies, and ensure that all workforce members understand and can remain compliant with these requirements. In order to do this effectively, the Compliance Department and other managers need to have open communication with each other and with the workforce members they manage. Having a culture of open communication in the workplace ensures that all levels of staff are on the same page about federal and state requirements, and what compliance with such requirements means for the organization.
In addition to managers and Compliance Officers reporting to the workforce on regulatory changes, workforce members should have a way to communicate with the Compliance Department about potential instances of fraud, waste, or abuse in the workplace that may put the organization at risk. Anonymous hotlines are an easy and efficient way for workforce members to openly and securely communicate potential compliance violations, and they represent the second element of the two-way channel of open communication. This type of hotline gives employees, physicians, contractors, volunteers, and other non-employed workforce members a way to express their concerns that protects their identities while still informing the Compliance Department of the potential issue. The anonymity aspect of a hotline is key because it guarantees that workforce members will not be singled out or penalized for reporting, thus encouraging more reports and strengthening the culture of open communication in an organization.
Benefits of Anonymous Hotlines
Anonymous hotlines offer secure communication channels for the workforce to report their concerns confidentially and avoid the risks of exposing their identity. Workforce members don’t have to fear retribution or penalties from managers or co-workers for reporting a compliance concern because they are able to report anonymously. This also allows the Compliance Officer to manage reported concerns privately and correct any possible violations without revealing who reported the concern. Additionally, anonymous hotlines improve the reporting method for both workforce members who were already expressing concerns and for workforce members who may have been unsure of how to securely share their reports before. If the organization previously required reporters to provide their identity, workforce members may have been discouraged from reporting a concern because they did not want managers or co-workers to know they reported the information. But when the hotline is anonymous, the aspect of identity protection is likely to encourage workforce members to report because no one will know who the report came from. This means that more individuals will likely be reporting overall when there is an anonymous hotline in place, leading to a better compliance program and improving the work environment.
Workforce members can have confidence in their reporting through anonymous hotlines because they know that the information, and their identities, will not be revealed. And because the organization does not know who specifically submitted the report, they do not have the burden of protecting the reporter’s identity. This further promotes the culture of open communication because the workforce will not be afraid to report compliance violations. They will establish a deeper level of trust with the Compliance Officer and managers simply by having the opportunity to securely and honestly share concerns of fraud, waste, abuse, or other unethical behavior in the workplace.
How Third-Party Vendors Help Increase Open Communication
Organizations that implement an anonymous hotline through a third-party vendor guarantee that their workforce members’ concerns of fraud, waste, abuse, or other unethical behavior will be acknowledged objectively. Third-party vendors assure that no one in the organization will find out who submitted the report, and designated hotline associates will document the information about the issue securely and anonymously. The high level of identity protection provided by third-party employee hotline vendors will encourage workforce members to report any compliance concern without fear of retaliation or negative consequences from upper management or co-workers. Further, hotlines that are managed externally provide flexibility for the workforce to call about a concern at a time most convenient for them. Anonymous hotlines that are managed through third-party vendors further promote cultures of open communication by providing a guaranteed secure and effective channel that workforce members know they can rely on.
In addition to increasing open communication in an organization, employing a third-party vendor to manage the anonymous hotline has other benefits. While organizations may think that implementing the hotline in-house will save them money and other resources, this is not necessarily true. Hotlines that are managed internally require organizations to hire additional staff to manage and operate the hotline, but third-party vendors will manage all coverage, maintenance, and operations of the hotline for the organization. In the long run, utilizing a third-party hotline vendor is the more cost-effective solution because the organization can use their current staff for other priorities without sacrificing the benefits of having an anonymous hotline in place. Third-party vendors also ensure that the hotline report goes directly to the Compliance Officer who can objectively analyze and address the concerns in the report separate from the reporter’s direct managers and peers.
As laws and regulations are changing, the importance of developing a culture of open communication within healthcare organizations is at an all-time high. Compliance departments are expected to share industry and regulatory updates with the workforce while hoping that, in return, workforce members will help the organization remain compliant with those updates by reporting possible unethical or improper conduct in the workplace. When enacted effectively, this two-way method of communication bolsters the compliance program and promotes a culture of open communication that benefits all workforce members. The best way for workforce members to uphold their part of the two-way channel and communicate with the Compliance Department about unethical conduct in the workplace is through anonymous hotlines. These hotlines, particularly when run by third-party vendors, enable workforce members to securely share their concerns without fear of retribution or retaliation. Given the aspect of anonymity, all workforce members can feel comfortable reporting any compliance issue, which increases instances of open communication and decreases the potential for unethical activities or behaviors that may put the organization at risk.