What is a compliance hotline?
A compliance and ethics hotline is a third party (unrelated) company that speaks to employees about compliance or ethics concerns. If you call a compliance hotline you have the option to leave anonymous comments. The goal of a compliance hotline is to provide a safe way for employees to share concerns without fear of retaliation. Compliance hotlines may be automated, hosted by a live operator, or web-based.
Find your company’s compliance hotline
Do a Google search with some of the following terms to find the hotline.
- “Company name” + compliance hotline
- “Company name” + ethics hotline
- “Company name” + code of conduct
- “Company name” + employee handbook
When you search for the code of conduct or employee handbook, the phone number will not show in the Google search results. Look through the code of conduct and employee handbook for the phone number (or email address).
The code of conduct and employee handbook are also great resources to review prior to contacting the compliance hotline. They may be good sources to support your concerns. In my review of these handbooks, many companies have ethical and legal procedures listed; however, pressure for maximizing reimbursement may result in an unwritten protocol being followed.
What concerns should you share with the compliance or ethics hotline?
- Patient or employee safety concerns
- Security breaches or risks, such as HIPAA compliance or personnel file privacy
- Third party payer fraud
- Workplace theft
- Patient rights are ignored, such as therapy continues after a patient has refused services or patients are not adequately informed of services or treatment
- Lack of clinical autonomy, such as therapists are not allowed to determine therapy appropriate for patients and therapists are not allowed to pick up or discharge patients according to their clinical judgment.
- Wasteful spending (too much therapy), such as intensity too high (e.g. RUG level), frequency too high, duration too long
- Conflicts of interest
- Poor therapy, such as not enough therapy or shortening therapy to maximize reimbursement and point of service documentation to maximize reimbursement
- Working off the clock encouraged (or not discouraged if it is known to be occurring
What happens after you submit a complaint?
Processes vary, but in communicating with several compliance hotline companies, the following two basic processes were identified.
First, it starts with an employee making a phone call, using a web form, or other form of communication provided by company hired by an employee. You will be given a case or call number, so you can call back and find out the status of your complaint. They will not call you to report, as your call is anonymous.
Process #1: The compliance company takes your complaint and it moves through the channels of their company before getting transferred (anonymously) to your employer. Each employer has their own internal process in which they handle compliance concerns. You can call to follow-up on your concern via the case number.
Process #2: The compliance company takes your concern and asks you to call back in a specified period of time. When you call back they will have a response from your employer regarding the complaint. The response may be “Thank you, we’re investigating this” or “we need this additional information”. Again, each employer has their own internal processes for handling complaints.
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