In the healthcare industry, compliance with federal regulations is paramount. One crucial tool in maintaining this compliance is the implementation of a healthcare compliance hotline, which provides employees with a secure avenue to report concerns and ensure organizational integrity.
In this Article …
- The Importance of Employee Feedback in Healthcare Compliance
- What is the Purpose of Healthcare Compliance Hotlines?
- What Types of Compliance Hotlines or Communication Channels Does the OIG Recommend?
- How Should Employees be Educated on a Compliance Hotline?
- What about Compliance Hotlines and Whistleblowers?
- What should be in a Log of Compliance Concerns?
- What about Reports by an Employee Concerned about Other Conduct?
The Importance of Employee Feedback in Healthcare Compliance
Employers have often sought feedback from employees on their attitudes toward the employer and their concerns about the circumstances of their employment. Employers have used various methods to enable employees to report concerns about their benefits, workplace, managers, services, and policies affecting their work lives. Employee surveys, anonymous reporting, and many other forms of communication are among the business practices many employers use to obtain employee feedback.
But there are other reasons for making it possible for employees to report matters or concerns these days for health care providers who submit claims to federal health care programs. Specifically, the General Compliance Program Guidance issued by the Office of Inspector General (OIG) of the Health Human Services Department outlines several expectations of compliance with Element #4, Effective Lines of Communication. One of the major areas of a compliance program includes the use of a healthcare compliance hotline for employees to report compliance concerns.
What is the Purpose of Healthcare Compliance Hotlines?
The premise of the OIG guidance on a healthcare compliance hotline is straightforward. Open lines of communication between all of the employees and contractors of a healthcare organization are necessary to implement a successful compliance program. This in turn reduces the potential for waste, fraud, and abuse. Health care providers can utilize several methods to improve communication between employees and the Compliance Officer.
What Types of Compliance Hotlines or Communication Channels Does the OIG Recommend?
The OIG encourages several channels of communication for employees to report concerns or potential violations. At least one method should be a healthcare compliance hotline where employees can report on an anonymous basis. Other forms could include an email address, a compliance department phone message line, a website or even via the US Mail.
An anonymous hotline permits employees to make reports or complaints that are not subject to interference by supervisors or even by fellow employees. Of course, employees reporting a concern about following regulations or inappropriate conduct cannot always be guaranteed confidentiality.
How Should Employees be Educated on a Compliance Hotline?
Health care providers can utilize a variety of methods to initially train employees on the compliance hotline and other ways to communicate compliance concerns to the Compliance Officer. Compliance Program training has to cover all seven elements of the organization’s Compliance Training. Many organizations utilize compliance and ethics training courses from third parties. While these education programs can be useful, they tend to cover compliance issues at a “macro” level and do not include information like the telephone number of the organization’s hotline or the email address of the Compliance Officer.
After initial training, follow-up education can continue in the form of policies, written memoranda, employee huddles, and department meetings. Employees tend to pay the most attention to the issues that immediate supervisors emphasize in formal and informal settings. Short reminders of the importance of taking responsibility for making reports that support the ethics of the organization and the quality of its services are easy to do, and they will leave an impression on staff members.
What about Compliance Hotlines and Whistleblowers?
Certainly, there are concerns with regulations and potential violations raised by whistleblowers. Many of the larger False Claims Act settlements and Anti-Kickback Statute prosecutions were preceded by whistleblower complaints. Some were initially received via an organization’s compliance hotline. Health Care Provider organizations should have policies outlining the protections afforded to whistleblowers. They must also explain when confidentiality may not be protected, e.g., when the government comes to investigate!
What should be in a Log of Compliance Concerns?
The Compliance Officer should keep a log of compliance issues or concerns that are reported anonymously or by staff members or others who identify themselves. Among other things, the log should cover elements such as the date reported, the date of the incident or occurrence, the individuals involved, the results of the investigation, the date resolved, and the record of a report to regulatory agencies, if any. An accurate, comprehensive log can help establish the validity of the actions of the organization if a further legal investigation ensues.
What about Reports by an Employee Concerned about Other Conduct?
A Compliance Officer may routinely receive report matters on issues not directly related to the risk areas addressed in the Compliance Program. A staff member, a patient, and even some other vendor may place calls to the compliance hotline. An employee concerned about sexual harassment, disciplinary action, or service quality may use the hotline to make contact on such issues. The Compliance Department must maintain very close coordination with other leadership in the workplace to ensure the issue is referred – and addressed!
The OIG is certainly correct in emphasizing the need for open lines of communication in healthcare organizations. And employers should be paying close attention when staff members access channels like hotlines to report issues and ask questions. There is no OIG “Wall of Shame” like the Office for Civil Rights maintains for HIPAA violations, but there certainly is an informal one about healthcare fraud and abuse you can read about month after month and year after year!