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 adds.

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, Cecelic adds.

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 says.

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, Huntsville, Ala.

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.

©2000 UCG.

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