Kusserow’s Corner: How to Evaluate and Select a Hotline Vendor

By definition, all effective compliance programs should have a hotline.  It is an important avenue of communication between employees and management, in that it permits employees to report sensitive matters outside the normal supervisory channels.  Both the U.S. Sentencing Commission and HHS Office of Inspector General (OIG) call for a hotline.  Today, most cannot afford to operate a hotline in-house and outsource the function to vendors.  An internal hotline operation is also challenged by the fact that it must be answered in an area where others cannot overhear the call. There is also the problem of ensuring against being able to trace the source of calls.  As such, all caller identification systems have to be blocked.  Furthermore, those answering the calls in-house should not be highly visible to the work force.  Confidence comes from neither party being known to the other. Hotline vendors have the training and experience to handle complainants.  The challenge becomes how to determine which hotline service will meet the needs of the organization. This is the subject of an upcoming free hotline webinar on June 18th that addresses this subject in more detail.

Avoid Vendor Traps

The first tip for anyone seeking or using a hotline vendor is to watch out for “Vendor Traps.”  One of the most common traps is holding clients by long-term contracts with no cancellation until a short window in advance of automatic renewal.  It is advisable to avoid signing a contract that locks you up without being able to cancel at any time without cause.  If you have a contract, check it for such a provision.  The second major trap is to have clients use their hotline number for posting on site, making it difficult to change vendors.  It is always best to use the organization’s number and point it to your vendor’s.  If there is a current contract that uses a vendor number, discuss with them about changing it.

Tips in Selecting a Hotline Vendor

The following are best practice tips in evaluating hotline services:

  1. Cost of operation.  Compare costs of service with the cost to maintain and operate a hotline in-house. Seek a fixed, not variable, rate based upon number or time of calls. A good rule of thumb is that the cost of a hotline service should not exceed $1-3 per employee per year.
  2. Industry expertise.  Determine level of expertise in the health care industry to better recognize issues.
  3. Hotline services.  Should provide 24/7 service, via both a web-based reporting system that prompts individual complainants, as well as the option to call and speak with a live operator.
  4. Other Differentiating Benefits.  Ask what other service benefits are included in the agreement, such as providing poster templates and hotline-related policy templates.
  5. Timeliness.  It is important to insist on and have as part of any contract a provision ensuring a full written report within the same business day of receipt of a call and, for urgent matters, immediate call notification.
  6. Hotline Number. Walk away from any vendor that insists on using their own number.  Always use your number, and re-point to the vendor’s.
  7. Language Translation.  Vendors should provide a language translation service to address non-English speakers.
  8.  Cancelation Policy.  Should be able to cancel anytime if not satisfied with service.  Walk away from contracts that lock clients in to long terms.
  9. Report Security.  Delivery of reports should be by the most secure means.  Web-based reporting is the most secure with email notification, not via fax or email that lack the same level of security.
  10. Insurance.  Like any other vendor, the company should have at least $1-3 million dollars coverage.

Richard P. Kusserow served as DHHS Inspector General for 11 years. He currently is CEO of Strategic Management Services, LLC (SM), a firm that has assisted more than 3,000 organizations and entities with compliance related matters. The SM sister company, CRC, provides a wide range of compliance tools including sanction-screening.

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Copyright © 2014 Strategic Management Services, LLC. Published with permission.