Auditing a Compliance Hotline Provider

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Compliance Hotline Auditing

Under the Affordable Care Act, medical service providers must establish compliance programs to enroll in the Federal health care programs. HHS has neither issued regulations on the core requirements of these compliance plans nor set a date for mandatory compliance. Providers, however, should consider adopting a compliance hotline program prior to the mandate not only because a requirement is imminent, but also to prevent fraud and demonstrate good faith.

Elements of an Effective Compliance Program

One of the seven elements of an effective compliance program is developing open lines of communication. CMS recommends that lines of communication run in multiple directions and include a process for anonymous reporting to provide an outlet for employees who may fear retaliation.

Many providers utilize an outside vendor to facilitate anonymous reporting. If you elect to use an outside vendor, you should choose a well-managed hotline that is focused on the health care sector. In addition, your organization should periodically audit the hotline to measure its effectiveness.

Considerations of a Compliance Hotline Auditing

When auditing a compliance hotline vendor you should consider (a) does the hotline have established policies and procedures, (b) how is the hotline managed, and (c) does the hotline meet its goals.

Some questions you might use to review the hotline’s management, operation, and effectiveness include:

  1. Does the hotline follow its established policies and procedures?
  2. Do the policies discuss how to document and follow-up calls?
  3. Does the hotline act on calls and/or emails promptly?
  4. Does the hotline follow up with callers who provide contact information?
  5. Are hotline administrators properly trained to answer calls and ask appropriate questions?
  6. Does your department tasked with reviewing hotline reports receive reports in a timely manner?
  7. Are the reports provided by the hotline detailed enough to allow your organization to follow up and investigate?
  8. Is caller anonymity being protected?
  9. Are hotline files protected?

In addition, you should also evaluate your office’s internal use of the hotline by considering the questions below.

  1. Are employees aware and reminded that the hotline is available?
  2. Does the department tasked with handling reports follow up properly?
  3. Are your employees using the hotline?
  4. Do employees seem confident about the effectiveness of the hotline?
  5. Does the department handling hotline reports file and protect reports appropriately?

If you answered “no,” to one or more of these questions, it may be time to consider a new vendor. Call Exclusion Screening, LLC today to discuss our ComplianceHotline, which is staffed by Certified Medical Compliance Officers, today at 1-800-294-0952.

Compliance Hotline Auditing

Ashley Hudson, Associate Attorney at Liles Parker, LLP and former Chief Operating Officer for Exclusion Screening, LLC, is the author of this article.

Why Timeliness Matters: From Hotline Tip Identification to Provider Case Closure

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ComplianceHotline – Best Practices

ComplianceHotline delivers reports to its clients one business day after it receives a call or e-mail from a complainant. What happens after the information is transferred is really up to a provider’s discretion. Best practices include following up with the complainant—if he or she provided contact information—or conducting an internal investigation. Regardless of the approach, it is imperative that the provider investigates a hotline tip in a timely manner. Failure to do so could hurt morale or potentially lead to a whistleblower suit.

According to a study published in the New England Journal of Medicine, nearly all whistleblowers raised their concerns internally first. Employees typically resorted to qui tam litigation only after it became apparent that mid and upper-level management were merely brushing their concerns aside. Some employees also resorted to whistleblower action for justice or integrity purposes. Others blew the whistle because they anticipated that the issue could negatively impact their careers.

In addition, according to a study conducted by NAVEX Global, the average number of days it takes a company to investigate and solve a case which was brought to light by a complaint has increased steadily over the past four years. The average case closure time in 2014 was 39 days. In comparison to 2010, it was only 32 days. Thirty-nine days is not likely an offensive amount of time to resolve a complaint. However, if an employee gets the sense that management is dragging its feet, or worse, totally ignoring the issue, then the company could be facing a much larger problem.  

What This Means

Utilizing a hotline service like ComplianceHotline is an excellent part of an effective compliance plan. The hotline, however, is a portion of the solution and it is critical that providers do not disregard tips they receive through the hotline. Providers should act swiftly and thoroughly to resolve the issue and ensure that their employees understand that the provider fosters compliance.

Contact The Compliance Hotline today for a free consultation by calling 1-800-294-0952 or by filling out the form below.

 



 

Ashley Hudson

Ashley Hudson, Associate Attorney at Liles Parker, LLP and former Chief Operating Officer for Exclusion Screening, LLC, is the author of this article. 

Anonymous Compliance Hotline Reports – Friend or Foe?

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In the compliance world, anonymous tip lines are touted as a simple and effective method to ensure that providers receive pertinent information about wrongdoing within their offices.  Compliance professionals, however, have divided opinions about the trustworthiness of anonymous compliance hotline reports. An argument in favor of an anonymous reporting option is that it provides an avenue for employees who fear retaliation. A criticism is that anonymous reports may be inaccurate or frivolous. Recent reports shed light on this interesting issue.

The Compliance Report Numbers

According to a 2014 Helpline Calls and Incident Reports survey conducted by the Society of Compliance and Ethics, 39% of compliance professionals reported that anonymous reports were substantiated at the same rate as named reports. Nine percent of respondents found that anonymous reports were substantiated more often than named reports. However, another 35% reported that they were substantiated less often than named reports. The 2015 Hotline Benchmark Report by NAVEX Global adds some clarity to these somewhat contradictory results. According to its data, anonymous reports were substantiated 36% of the time, or 9% less than reports from named individuals. The NAVEX report notes that the gap in substantiation between anonymous and named reports has actually remained at 9% during the last four years. It further goes on to suggest that the gap may be due to an investigator’s inability to follow-up anonymous reports.

Takeaways

An anonymous reporting option is a valuable tool available through ComplianceHotline and will enhance a provider’s compliance program. These reports may be substantiated at a slightly lower rate than named reports. Still, this is not necessarily due to nonsensical reports. Furthermore, capturing issues through both named and anonymous reports ensures that a provider is aware of all issues and may help to keep lawsuits at bay. Call Exclusion Screening, LLC today to enhance your compliance program with our ComplianceHotline solution at 1(800) 294-0952.

Compliance

Ashley Hudson, Associate Attorney at Liles Parker, LLP and former Chief Operating Officer for Exclusion Screening, LLC, is the author of this article.

Why Do I Need a Compliance Hotline?

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Compliance Hotline ReportingOne of the seven steps to an effective compliance plan is to develop effective lines of communication. While it is important to foster open lines of communication within your practice, many employees may fear retribution. Hence, they may feel more comfortable reporting complaints anonymously or at least to a third party vendor. Fortunately, providing an outside reporting mechanism such as the hotline offered by Compliance Hotline is an extremely cost effective solution. Within this article we will address some of the benefits of outsourcing your compliance hotline.

I. Minimize Risk by Fostering Confidential Compliance Hotline Reporting

Under Sarbanes-Oxley, certain whistleblowers are protected from employer retaliation for reporting instances of fraud. This provision permits an employee to file a complaint with the Secretary of Labor if he is discriminated against for “blowing the whistle.” However, many employees may not be educated about this law, or may still fear retribution. Therefore, they may not file a report to an internal department. By providing an outside confidential report line, like Compliance Hotline, your employees will be more comfortable reporting issues. You will also become aware of any lurking issues within your practice more quickly.

II. Protect your Practice from Fraud and Liability with the Compliance Hotline 

According to the Association of Certified Fraud Examiner’s Report to the Nations, tips are the most common mode of detecting fraud cases within organizations. Tips have a 40% fraud identification rate. Internal audits and management reviews follow as the second and third best detection methods. They have 15% and 13% identification rates, respectively.

Companies that utilized hotlines reported that 46% of fraud cases were reported as tips. However, only 10% of cases were discovered through internal audits, and merely 3% of cases were detected through surveillance/monitoring. Companies who did not provide hotlines had more abysmal numbers, identifying only 30% of fraud cases through tips.

ComplianceHotline powered by Exclusion Screening, LLC is a cost effective way to ferret out and minimize fraud within your practice. Contact us today at 1-800-294-0952 or online for a free consultation so that you can resolve any potential fraud issues before they get out of hand.

Read more about How Compliance Hotline Can Save You Money

Compliance Hotline Reporting

Ashley Hudson, Associate Attorney at Liles Parker, LLP and former Chief Operating Officer for Exclusion Screening, LLC, is the author of this article.