[author: Betsy Wade*]
Compliance Today (January 2025)
At a recent HCCA event, large digital signs throughout the conference venue displayed a toll-free number and the message, “If you see something, say something.”
The message served as a great reminder that healthcare organizations should be advertising their hotlines or independent reporting methods for individuals to report potential fraud, waste, violations of organizational policy, and abuse in commonly used physical and virtual spaces as recommended in the U.S. Department of Health and Human Services Office of Inspector General’s (OIG) General Compliance Program Guidance.[1]
Open communication between the compliance officer and employees and contractors and agents is imperative for an effective compliance program. The compliance committee should ensure multiple reporting methods are available for individuals to report concerns directly to the compliance officer and that the organization does not request individuals to go through a manager or supervisor first.
The reporting methods should also be accompanied by a written policy on nonretaliation so that it is clear to employees, contractors, and agents that they are encouraged to communicate with the compliance officer without fear of retaliation.
In its guidance, OIG stated that the organization should have at least one independent reporting method that allows individuals to report concerns anonymously.
To accomplish this, OIG offered many ways to accomplish the standard, including a hotline, email address, mailbox, or website. The compliance department should record all reports—regardless of how they are made—quickly in a log.
In addition to publicly posting information about reporting in physical spaces and virtually, compliance professionals should also include information about the reporting methods in orientation and annual general compliance training.
Key takeaways
Organizations should:
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Offer at least one independent reporting method for employees, contractors, and agents to report concerns anonymously.
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Display the organization’s hotline or independent reporting methods for reporting potential fraud, waste, and abuse and include them in orientation and general compliance education.
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Inform employees, contractors, and agents how they can contact the compliance officer directly and provide all methods, such as email, phone, or messaging, for example.
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Develop and implement a written nonretaliation policy that encourages reporting to the compliance officer without fear of retaliation.
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Log all reports—regardless of how they are made in a disclosure log—along with information related to the matter and how it was resolved.
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Share information about concerns received by compliance and the investigations that were conducted with the compliance committee, the CEO, and the board.
*Betsy Wade is the Chief Compliance and Ethics Officer at Signature Healthcare in Louisville, KY.
1 U.S. Department of Health and Human Services, Office of Inspector General, General Compliance Program Guidance, November 2023, https://oig.hhs.gov/documents/compliance-guidance/1135/HHS-OIG-GCPG-2023.pdf.
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