When and How Should a Hotline Vendor be Re-Evaluated?

Most healthcare organizations have been using the same hotline vendor for many years.  Over time, advanced technology and enhanced methodologies have improved the service and reduced costs. There is also a lot more competition out there that provide variations of services and fees. This is good for negotiating a better deal.  As a result, you may find a new vendor with better services at half the cost of their current vendor.  At any rate, any organization that has had the same compliance hotline vendor for more than a number of years may wish to re-evaluate the agreement and services.  This is part of the compliance program ongoing monitoring and auditing called for by the OIG.  The following are 15 questions you should use to evaluate your hotline vendor:

1. Have your re-examined your current contract for terms, rates, and conditions?  This is the very first thing any organization should do when considering the merits of the terms, fees, and conditions under which a hotline service is provided.  Times have changed, competition has increased, and technology has advanced.  Is that reflected in your current agreement?
2. Are you satisfied with the cost levels for the services provided and is it comparable with what other vendors charge for the same level of service?  A good rule of thumb to evaluate cost is the hotline service should be no more than $1- $3 per employee per year.
3. Does your vendor lock you in by contract and not good service?  Any vendor that has to maintain you as a client by making it difficult to terminate the agreement should be suspect.  It is always advisable to seek agreements that permit termination without cause with simple 30 day notice.  Under any circumstances it is advisable to re-read the terms and conditions of your current contract.  Check and see if there is only a window of time during the term of the contract when you can terminate.
4. Does your vendor require you to use their hotline phone number?  One way vendors tie their clients is to have them use their number and have you advertise it internally.   In that way, it is difficult to change vendors without having to change the hotline number information in the Code of Conduct, intranet, posters, etc.  If you have such a deal and want to have a new vendor, have them assist you in transitioning with minimal disruption or costs.
5. Does the vendor have experience and expertise in the health care industry to recognize significant issues that may arise from a call?  It is advisable to have a company familiar with and understanding of health care issues, rather than just focus on employee theft or other generic matters common to all industries.  This can be critical in recognizing significant issues being raised by a caller.
6. Does your vendor provide multiple levels of service, including both live operator and web-based reporting? In today’s environment, it is advisable to have 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.
7. Has your vendor been able to keep you abreast of changes in the regulatory expectations relating to reports arising from the hotline operation?  It is a real plus to have your vendor assist you in staying current and be able to assist you with developing operating protocols, policies, and procedures related to hotline reports.  Many offer news briefs or alerts as part of their service.
8. Does your vendor provide advisory services in addressing difficult hotline allegations? The vendor should be able to provide the benefit of professional knowledge and experience of having many clients and a host of reports on a wide variety of subjects without increase in service fees or costs.
9. Does your contract provide for timeliness standards in submitting hotline call reports?  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 provided immediate.
10. Are the hotline reports being received well written, clear, concise, and complete?   Reports on individual calls should be of high quality.  There are very few more frustrating problems than trying to act upon incomplete or unclear information in a hotline report.
11. As part of ongoing monitoring, do you make quality control test calls to your hotline?  It is advisable as part of ongoing monitoring to call your own hotline to test how well they debrief you and then evaluate the timeliness and quality of the resulting report.
12. Is the manner of hotline report delivery secure and sensitive to privacy standards? The manner the report is delivered is important.  There can be security problems with reports provided either by facsimile or email.  This could be problematic.  Web-based reporting is the most secure with notification of a report being provided via email.
13. Does your vendor have adequate liability insurance coverage?  Like any other vendor, the company should have at least one to three million dollars coverage.
14. Are there any other benefits offered by the vendor within the price of service? Some vendors provide other ancillary services, such as policy and procedures for hotline management, etc.  Find out what they offer as part of the service.
15. Do you receive personalized service with your vendor?   It is always preferable to have a personal relationship with your vendor and have a single account manager with whom you can discuss any issues related to the service, from an invoicing matter to the quality of a report.  

No one likes to add to their daily burden by going over old contracts; however, doing so may result in significant reductions in cost, improved services, and an all around better hotline program.[1]

[1] For more information on details of a vendor operation see https://complianceresource.com/products/hotline-service-center/

About the Author

Richard P. Kusserow established Strategic Management Services, LLC, after retiring from being the DHHS Inspector General, and has assisted over 2,000 health care organizations and entities in developing, implementing and assessing compliance programs.