Jeannine LeCompte, Publishing and Research Coordinator
A hotline can be a powerful tool in the ongoing fight against fraud, waste, and abuse, and is beneficial to the good operating procedure of a long-term care facility. It can allow previously undetected issues to be brought to management’s attention before it is too late.
Hotlines are only as good as the people behind them though, and all calls should be taken seriously, evaluated, and, if the issues raised show merit, acted upon. This is why a facility must ensure that investigations which follow hotline calls are carried out to the highest possible standard.
On the issue of confidentiality, the facility must ensure that all reports made on the hotline are kept anonymous, whether requested or not. There must also be a procedure in place so that all reports are protected and guarded to retain confidentiality. In addition, a hotline should be answered by someone with direct compliance responsibilities and experience.
All calls made must be taken seriously. This is a requirement even if the call at first seems to be frivolous. Calls can only be dismissed when fully peer-reviewed by the compliance and ethics committee, and even in such cases, full documentation of the reasons given for that decision must be maintained and included in any reports.
If the issue raised is clearly not frivolous, then a prompt investigation must follow. The results of the investigation—carried out according to the facility’s preset policies—must be fully documented, and reported upward to the relevant authorities.
If the investigation finds that disciplinary steps are required, such procedures must be immediately instituted without fear or favor, and all necessary follow-up with relevant parties conducted in the shortest possible time.
If the investigation results in any policy changes, these must be adequately communicated to everyone inside the organization, once again using the facility’s established channels.
Occasionally, a hotline call will be made by someone who does not remain anonymous. In such a case, the person making the call must be assured that their anonymity will be respected, unless, of course, the nature of the investigation makes it otherwise impossible.
Once the investigation is complete, an action plan must be developed to address all issues raised, and procedural changes implemented to prevent a recurrence of the same issue.
Finally, if, in the opinion of the compliance and ethics committee, any incidents raised on the hotline need to be reported to outside authorities such as the Department of Health or law enforcement, there should be no delay in that matter either.
