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Recent Compliance Updates & Tips

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The U.S. Sentencing Commission and Department of Health and Human Services (HHS) Office of Inspector General (OIG) call for compliance program hotlines. Developing and monitoring a Hotline is a critical part of any effective Compliance Program. Hotlines provide an avenue of communication outside of normal supervisory channels for employees to report sensitive matters. An organization’s Compliance Officer bears the responsibility of continuously reviewing and improving the effectiveness of hotline operation.  However, today, the vast majority of ethics and compliance hotlines are operated through vendors. Only a few organizations have the size, capacity and resources to manage a 24/7 hotline.  Additionally, organizations that do decide to operate and manage the function in house are confronted with a number of challenges. The following are some best practice tips in selecting or retaining an ethics hotline vendor.

  1. Costs. Compare costs of a vendor with the cost to maintain and operate a hotline in-house. A vendor should provide their services at a set (fixed) fee that can be used for comparison purposes. A good rule of thumb is that the cost of a hotline service should be around $1 per employee per year.
  1. Industry Focus. Determine level of expertise in the health care industry. It is advisable to enlist a company familiar with and up to date with health care issues rather than a company focusing on employee theft or other matters common to all industries.  Ask for a breakdown of the types of clients they serve.  Do they have a primary focus (transportation, finance, energy, health care)?
  1. Hotline Service Types. 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. Second, the hotline should provide the option to call and speak with a live operator as well. Either approach has its pluses and minuses.  Your vendor should provide both approaches in a single service fee.

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  1. Vendor Contract Traps. You should stay with a contractor because of good service, not due to tricky contract terms. Don’t sign a contract that does not permit you to cancel at any time with a simple 30-day notice. If you have a current contract, check the termination clauses to see if cancelling a contract is cumbersome.  If it is, ask to renegotiate the termination clause. If they decline, then take steps to follow termination procedures in the contract. Usually termination procedures contain short windows to cancel before the contract renews.
  1. Hotline Number. Always use and own your own hotline number. This number can be directed to a vendor.  Never use a vendor-owned number because it is another common vendor trap.  If you use a vendor-owned number, you advertise their number everywhere and if you decide to change vendors, you would be required to update all the places you have advertised the number wasting time and resources. If you are currently in a contract using a vendor-owned number, it is advisable to either renegotiate the agreement to use you own number or change to another vendor. It is worth the pain of making the change.
  1. Background and References. It is advisable to know as much about the vendor as you can. Determine who the key players are in the ownership, management and operation of the service and check out their credentials. It is important to ascertain whether they have personal history and expertise in hotline operations. Also, ask for client references from any vendor you are considering.
  1. Policies, Procedures, and Protocols. The company should be able to provide expert advice on developing operating protocols for following up on allegations and complaints received through the hotline. This includes providing/signing a Business Associate Agreement to meet HIPAA Protected Health Information requirements (and if they don’t know what that means, forget them).
  1. Timelines. It is important to insist and have as a part of any contract, the provision of a full written report within one business day of the receipt of a call. For urgent matters, it should be immediate.
  1. Reports Provided. Reports on individual calls should be well written, clear, concise and of high quality. The manner the report is delivered is important. There are security problems with reports provided either by facsimile or email. Web-based reporting is the most secure with notification of a report being provided via email.
  1. Insurance. Like any other vendor, the vendor should have at least one to three million dollars liability coverage. If your vendor does not have this insurance, consider changing over to one that provides this assurance.
  1. Caller Contact Information. Although anonymity is a must for any hotline, sometimes gaining additional information from callers is important. Vendors should have procedures for providing callers with a means to call back without disclosing their identity.
  1. Accessibility to Responsible Parties. Vendor responsiveness to your hotline needs is very important. If something comes up, will there be a responsible live human being available with whom you can communicate issues and concerns? You never want to be lost in a bureaucratic shuffle.
  1. Other benefits. Most vendors offer other ancillary services, such as policy and procedures for hotline management, poster templates, etc. Find out what they offer.
  1. Update Reports. Vendors vary considerably in providing update reports. These can be of two types. The first is a report on call volume and types received by them.  The second relates to industry updates and patterns of issues arising from hotlines. Assess vendors to determine what they offer.
  1. Ongoing Vendor Monitoring. Like all other programs, the hotline program should be subject to ongoing monitoring to increase your hotline’s effectiveness. This includes constantly reviewing the hotline vendor service.  Review to see if they are meeting all their obligations under the contract and how responsive they are to any queries and concerns raised. It also means periodically making test calls in the guise of a complainant. See how well they debrief you and look at the resulting report for timeliness and accuracy.
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