Cloak, not dagger: 13 tips to make hotlines
anonymous and helpful
By Charles Choi
UCG Staff Writer
July 7, 2000
An anonymous hotline allows potential whistleblowers to
blow off steam and report critical problems -- but first you have to make
sure that they will call. Employees won't call if they don't think anyone
cares or, worse, if they fear retaliation.
Here are 13 tips for compliance officers from your peers to make hotlines
both anonymous and effective:
1. Avoid answering machines, recommends Jerone
Cecelic, the assistant vice president of Corporate Integrity, Ethics and
Compliance for HCA-The Healthcare Company (formerly Columbia/HCA Healthcare
Corp.). "Having a cold, impersonal machine answer the call"
will discourage many callers and cause many to hang up, Cecelic says.
The human touch allows interviewers to provide feedback to callers as
well ask follow-up questions to help clarify a caller's statements, he
2. Have a toll-free hotline answered by an outside vendor... Cecelic
says many hotline vendors offer toll-free service 24 hours a day, 7 days
a week, with trained interviewers who provide written summaries of the
call via fax or encrypted e-mail. 24-hour service "is frequently
appropriate in the healthcare industry, where facilities are always open.
For example, [HCA-The Healthcare Company] receives 21.9% of the calls
to the toll-free number between 6 p.m. and 7 a.m.," he says. Some
providers may consider the use of an outside vendor pricey and overkill,
but in small practices where everyone knows each other's voices, an outside
vendor may allow for anonymity. Providers may share their resources with
others operating hotlines in order to mitigate the cost of the service,
3. ...Or put in an in-house hotline. It's more cost effective,
and while outside vendors may not know enough to provide detailed questions
and answers, in-house staff will know their own business better. It may
also be hard to monitor a hotline vendor's quality of service.
4. Make your in-house hotline untraceable. Theodore Sanford, compliance
officer with University of Michigan Health System, Ann Arbor, says the
compliance office has a hotline that is untraceable through the university
system. "It won't even show up on Caller ID," he adds.
5. Assign a reference number to each case and give that case number
to the caller for future reference to protect their anonymity.
6. Have callers choose code names if they want updates on their
cases, says Alice Guttler, senior vice president and corporate counsel
for Centrastate Health Care System, Freehold, N.J. "People can say,
'Hi, I'm Deep Throat,' if they want," she says.
7. Make sure that only compliance officers have access to cases.
This makes employees feel more comfortable and more likely to call.
8. Have interviewers keep after-hours calling periods on in-house hotlines
for callers who don't want to report problems at work because they are
afraid someone will listen in on them.
9. If you have an in-house hotline, prepare to make time for callers.
"Rarely can a caller's concern be described in less than 20 minutes
and frequently 45 minutes are necessary for the initial call," Cecelic
10. Tell callers that investigations take time. "We will usually
say you can expect some kind of update in two weeks, although we tell
them that the situation may not be resolved that quickly, especially if
legal counsel gets involved," says Sheryl Vacca, vice president and
corporate compliance officer for Sutter Health, Sacramento, Calif.
11. Give a date when callers can call back for updates. "People
don't like to be ignored. Getting back with employees makes them feel
their problems matter. Set up deadlines and live up to them," says
Anna Blair, compliance officer with Jackson County Health Care Authority,
12. Check every name mentioned by callers against OIG's exclusion list
to back up internal practices, Cecelic says. This goes for contracts with
hotline vendors as well.
13. Protect those who make the calls from harassment. "We
have a very strong policy supported by our management for very strong
disciplinary action applied against anyone who engages in retaliation.
From our perspective, it's absolutely intolerable. The bad part is that
harassed employees don't always tell you about it -- they're afraid that
it'll make it worse," Vacca says.
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