Breaking Compliance News Blog

Have you tested your compliance hotline lately?

Posted by Margaret Scavotto, JD, CHC on 10/2/19 7:28 AM

The Kansas Medicaid fraud and abuse complaint email inbox went unchecked for 17 months.

According to a report issued by the Kansas Office of the Medicaid Inspector General, 209 emails were unread. 95 of these emails "alleged fraud, waste, abuse, or illegal acts related to Medicaid, MediKan, or SCHIP, or were seeking information on how to report suspected fraud." 42 of these emails contained "partially or wholly substantiated allegations of Medicaid or SCHIP fraud, waste, abuse or illegal acts....

How did it happen?

The complaint inbox went unchecked from August 2, 2017 to January 9, 2019.

Read More

Topics: Hotline, annual review, compliance

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

New Call-to-action

Read More

Topics: Hotline, Culture of Compliance

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.

Read More

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

Read More

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

    Privacy Policy           Terms of Use