Kusserow on Compliance: Fifteen tips for a more effective hotline program

Having an effective hotline program is a must for any effective compliance program. The operative word is “effective.” Laurel Eakes at the Compliance Resource Center has worked with many hotline operations. She notes from her experience that “the hotline needs to be seen by employees and management as a priority to bring complaints and allegations of wrongdoing in house. The alternative is to drive such information externally to government agencies, litigating attorneys, media, etc., and that can only spell trouble. As such, not acting promptly on information received can result in potential liabilities, headaches, and a lot of remedial work. It is important to make employees comfortable in raising concerns internally and lessening the perceived need to resort to ‘whistleblowing’ to external parties.” Eakes offered the follow tips she has found with her clients for ensuring a more effective hotline program:

  1. Implement related policies (e.g. hotline Operations, Duty to Report, Non-Retaliation, Anonymous and Confidential Reporting, Investigations, etc.)
  2. Log and track all complaints/allegations received through resolution
  3. Set time frames for completion and resolution of complaints and verify they are followed
  4. Be sure those investigating hotline allegations have been trained how to do it properly
  5. Document all steps in the process of resolving hotline complaints/allegations
  6. Have posters on employee bulletin boards for the availability and use of the hotline
  7. Ensure hotline number and its availability is included in new employee orientation
  8. Ensure the hotline program is part of annual compliance training
  9. Have information about the use of the hotline made part of the Employee Handbook
  10. Consider having a flyer go out to all employees on the availability of the hotline
  11. If there is an Intranet for employee use, include information about the hotline
  12. If there is an organization newsletter or intranet, use it to promote the hotline
  13. Maintain a document management system for compliance records
  14. Ensure records are kept in a secure limited access area
  15. Develop summary reports for management and Board on results from the hotline program

 

For more information on this subject, contact Laurel Eakes (leakes@complianceresource.com)

 

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 LinkedIn.

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Copyright © 2020 Strategic Management Services, LLC. Published with permission.