Breaking Compliance News Blog

The perils of “Good” compliance results

Posted by Margaret Scavotto, JD, CHC on 10/23/18 2:54 PM

The set of NBC’s hit TV series The Office includes an office suite (where many hijinks ensue) and an attached warehouse. In Season 2, Episode 5, office manager Michael Scott visits the warehouse and causes colossal destruction with a forklift.

Then, much to warehouse foreman Darryl Philbin’s chagrin, a warehouse employee erases the “936” on a sign that reads: “THIS DEPARTMENT HAS WORKED 936 DAYS WITHOUT A LOST TIME ACCIDENT” and replaces it with a big fat Zero.

This scene raises a nuanced compliance issue. The sign touting 936 days since an accident is an example of identifying – and celebrating – a compliance success. Presumably, accidents were avoided because employees adhered to safety protocols.

But, does this sign also encourage employees not to report accidents? Daryl will be pretty unhappy the next time someone has to put a “zero” on the accident sign – and everyone knows it. Nobody wants to be known as the person who broke the winning streak. This is an unintended consequence of the Zero Accidents sign.

The same is true for compliance: healthcare organizations that have months with zero compliance reports could have a problem.

We of course want to celebrate good metrics and results – but how do we do that while still encouraging people to report problems?

A goal of zero hotline calls deters people from finding and reporting problems. The unintended message is: Don’t report. This means that if your compliance dashboard repeatedly shows zero compliance reports – you should raise an eyebrow, not a glass.

Instead, we need to discuss compliance goals in a way that encourages reporting and discovering non-compliance. Perhaps our goal should be to encourage reporting instead of having Zero reporting. You can support this goal by promoting reporting options (and your anonymity, confidentiality and non-retaliation policies). And, you will still find things to celebrate:

  • Thank those who report
  • Add compliance reporting to performance reviews
  • Recognize efforts to promptly investigate and respond to reports 
  • Celebrate improvement

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Topics: Culture of Compliance, Hotline

Do Compliance Hotlines Help or Hurt Whistleblowing?

Posted by Margaret Scavotto, JD, CHC on 6/2/14 9:43 AM

 As part of their OIG compliance programs, health care compliance officers invest a lot of time and effort publicizing the compliance hotline and encouraging internal reporting.

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Topics: Compliance Basics, Hotline, Whistleblowers, Culture of Compliance

The Compliance Whistleblower: Friend or Foe?

Posted by Margaret Scavotto, JD, CHC on 8/10/12 1:00 PM

Some of the biggest Federal penalties for false claims begin with a call from a whistleblower. Employees who feel you are not addressing their concerns, or that you don't care about compliance, often turn to the government. By creating a culture of compliance and encouraging internal reporting, you can address problems without government intervention.

Whistleblowers are rewarded handsomely for reporting you

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Topics: Penalties and Enforcement, Hotline, Whistleblowers, Culture of Compliance

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