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.
At the top of the list of benefits to be derived from these efforts is avoidance of whistleblower suits. Countering efforts to prompt internal reporting are the large number of lucrative false claims suits against healthcare entities that are enriching whistleblowers. Additionally, whistleblower training of employees in many healthcare entities is mandatory under federal law.
In spite of the increased awareness and the enticements of large rewards to whistleblowers, recently-published results of a survey on reporting indicate that employees prefer to report internally.
The survey was conducted by Health Care Compliance Association and the Society of Corporate Compliance and Ethics. Published results of the survey revealed that employees have become more likely to report concerns through helplines and directly to management and compliance officers over the past two years. Some of the more revealing numbers from the study include:
- 37% of respondents reported an increase in the volume of hotline calls.
- 58% of respondents had an increase in the number of incidents reported via all means.
- 6% of respondents reported an increase in the number of whistleblower claims.
The report on this study listed additional conclusions derived from the study. While some feared that increasing focus on reporting internally would prompt an increase in whistleblower suits, this has not been the case. The report also pointed out that in order to prevent employees from going to the government with complaints, it is important for health care companies to respond quickly and effectively to internal reports of wrongdoing, because if allegations are not taken seriously, employees are likely to repeat complaints externally, to the government and/or to qui tam attorneys.
Tips for Compliance
- Establish an anonymous, toll-free hotline for compliance reporting
- Promote the hotline to your employees with training, posters, etc.
- Check the hotline diligently
- Respect your anonymity, confidentiality, and non-retaliation policies
- Respond quickly to all hotline reports
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