Kusserow on Compliance: Tips on finding the right hotline vendor

One of the critical elements of an effective compliance program outlined by OIG compliance guidance is the establishment and maintenance of communication channels with employees and management. Such communication permits employees to report sensitive matters outside the normal supervisory channels. Both the U.S. Sentencing Commission and DHHS Office of Inspector General (OIG) call for a hotline. Results from the Ninth Annual Healthcare Compliance Benchmark Survey conducted by SAI Global and Strategic Management Services found that 55 percent of organizations outsource their hotline. Daniel Peake of the Compliance Resource Center provides hotline services and explained there are many reasons why so many choose to outsource their hotline. Although there are benefits of maintaining the function in-house, it is far outweighed by the advantages of outsourcing it to a professional vendor service. He cited some of these reasons why so many decide to use a professional vendor service, including the following:

  • Cost of staffing with qualified people in-house is prohibitive
  • Systems must blocked and “backstopped” to prevent anonymous caller identification
  • Those answering the calls in house should not be highly visible to the work force
  • Calls should never be answered in an area where they can be overheard by others
  • Hotline vendors have the training and experience to handle complainants
  • Callers are nervous and speaking with an outside party generally is reassuring


  1. Cost of operation. Vendor’s services should be a set fee under $2/employee/year.
  1. Contract. Avoid contracts not permitting cancellation by 30 day written notice. Client should be held by good service, not by contracts.
  1. Industry expertise. Seek vendors knowledgeable of health care issues.
  1. Hotline services. Must include both live operator and Web-based reporting. Either approach alone has its deficiencies and is not a best practice.
  1. Policies and procedures. Vendor should assist with developing operating protocols for following up an allegations and complaints received through the hotline.
  1. Timelines. Insist on a provision of a full written report within one business day of receipt of the call. For urgent matters, it should be immediate.
  2. Reports provided. Written reports must clear, concise, and of high quality.
  3. Report Delivery. The manner the report is delivered is important. There is security problems with reports provided either by facsimile or email. Insist on secure web-based reporting with notification of a report being provided via email.
  1. Insurance. Like any other vendor, the company should have at least one to three million dollars liability coverage.


For more information, Daniel Peake can be reached at (dpeake@compliancereource.com or (703)-236-9854)


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.

Connect with Richard Kusserow on Google+ or LinkedIn.

Subscribe to the Kusserow on Compliance Newsletter

Copyright © 2018 Strategic Management Services, LLC. Published with permission.