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Keep good hotline records to improve compliance

Radiology Administrator's Compliance and Reimbursement Insider, March 1, 2005

Many facilities have hotlines that employees can use to report fraudulent practices and other potential violations to management. Having a hotline discourages employees from filing whistleblower suits against your organization and shows the government that you're serious about compliance. But simply having a hotline isn't enough, warns Alex Schillaci, a Connecticut compliance consultant.

"Anybody can get a special phone number and claim they have a hotline," he says. However, you must be able to show that you not only take calls, but that you also take them seriously. To do this, keep thorough records documenting each call you received and how you responded to it.

But experts say providers-including radiology facilities-have a tendency to overlook the importance of good records and therefore don't create systems for tracking this vital information. Experts also say there's a simple way to correct the problem: Create a hotline report sheet and have your operators complete it for each call they field. Below is information that explains how these forms work and how to create one you can use. To help, we've provided for you a model form of a hotline report sheet that you can adapt.

What's a hotline report sheet?

A hotline report sheet is a one-page form that outlines the essential information an operator needs to get from a caller. Each sheet has its own serial number so each call can be tracked. Hotline operators must fill out a sheet every time they field a call.

Three ways report sheets further compliance

Using hotline report sheets aids your compliance efforts in three ways:

1. Funnel complete information to your compliance officer. Hotline report sheets ensure that operators quickly relay information to the appropriate person, says Stacey Schleifer, an attorney with an Alexandria, VA, hotline service company. At the end of their shifts, operators assemble all the sheets they've completed and send them directly to the compliance officer or to another designated person. This way the compliance officer gets all the sheets on the same day or, if the call comes in after business hours, by the next business day.

Giving operators hotline report sheets to fill out also acts as a check against sloppy and incomplete fact reporting. "It's like a phone script showing operators what to ask callers," notes Schillaci. That's important because it ensures that operators get all the information the compliance officer needs to decide to handle the calls, he adds.

Finally, the hotline report sheet forces all operators to report information the same way, notes New York-based compliance consultant F. Lisa Murtha. "Standardization of reporting formats makes the information easier for the compliance officer to process," Murtha says. If you don't require operators to use a standard form, they're apt to provide vague narratives or invent their own formats.

2.Win points with the government.

Various Office of Inspector General (OIG) compliance plans (e.g., for labs, hospitals, third-party billing companies, etc.) specifically recommend creating a hotline. They also say "the OIG will be critical of compliance programs that exist on paper but are not earnestly implemented or enforced."

Hotline report sheets can help you demonstrate to the OIG-and any other enforcement agencies-that you have implemented your hotline program. "The government doesn't want guesses and estimates-it expects specific data about the calls you're getting and how you respond to them," Murtha says.

Insider says: Enter the raw data from your hotline report sheets into a log. The OIG requires you to maintain a log of all calls "that suggest substantial violations of compliance policies, regulations, statutes, or program requirements of federal, state, and private insurers," including "the nature of any investigation and its results."

3. Enhance effectiveness of internal audits. The OIG says providers should conduct regular compliance audits of their operations. Use hotline report sheets to identify problem areas to audit. This enables you to solve potential problems before they become major liability risks. It also helps you verify the effectiveness of corrective measures you've taken to resolve past problems. That's important because the OIG suggests that audits focus on making sure that past problems are corrected and won't recur.

How to create a report sheet

The operator who answers a hotline call fills in most of the report sheet for that call. The operator then sends the report sheet to your compliance officer or another designated contact. The compliance officer or contact fills in the rest of the report sheet. Our model hotline report sheet form is based on one developed by National Hotline Services, Inc., a company that manages hotlines for hospitals and other providers. As with our model form, your hotline report sheet should cover the following 13 items:

1. Confidentiality warning.A hotline report sheet contains highly sensitive information that should be seen only by the operator, the compliance officer, your attorney, and any other authorized persons. Put a warning at the top of the sheet in boldface, italics, or another attention-drawing typeface. Note that the report sheet is proprietary, confidential information and that photocopying it or revealing the information in it to a third party without authorization is forbidden. No matter how careful anyone handling report sheets is, the forms may be misplaced or accidentally sent to an unauthorized person. Include a phone number people can call if they find a misplaced sheet.

2. Serial number. Each sheet should have its own printed serial number so you can track each call individually. Also have the operator read to each caller the serial number on the report sheet being used for that call. Callers may later want to find out what you're doing about the problem they reported. If they made their calls anonymously, they can use the serial number to identify themselves during subsequent calls.

3. Date, time, and operator's name. Noting the date and time that calls are received is critical. It enables you to monitor how quickly you respond and which information you'll need to demonstrate the effectiveness of your program. Also provide a space for the operator's name. If you have questions or concerns about a report sheet, you'll know exactly who to contact.

4. Caller's acknowledgement of right to anonymity. A hotline typically greets callers with a prerecorded message that explains the rules and procedures. Among other things, the message reassures callers that they can remain anonymous or give their name but ask that the information remains confidential. Although you can promise confidentiality, you can't totally guarantee it. That's why the various OIG compliance plans say providers should "explicitly communicate" to callers that their "identity may become known or may have to be revealed in certain instances where governmental authorities become involved." This should be part of your prerecorded message. The first thing an operator should do when answering a call is ask whether the caller heard the prerecorded message and understood the options and limitations with regard to confidentiality. Our model form has yes and no boxes in which the operator can indicate the caller's response.

5. Whether caller gave identity.

Although callers have the right to remain anonymous, they needn't do so. Include yes and no boxes in which the operator can indicate whether the callers identified themselves. If so, the operator should note the caller's name, phone number, and division. Also include yes and no boxes in which the operator can indicate whether the caller's identity was given in confidence.

6. "Material facts" of allegation or concern. Have the operator list the "material facts" of the caller's allegations or concerns.

7. Promises or representations made. Some providers tell operators not to give advice or make any promises or representations (i.e., statements indicating an opinion) to callers. Some providers want operators to reassure callers by saying a report will be filed with the compliance officer. In either case, ask operators to indicate what-if any-advice, promises, or representations they made.

8. Whether the problem has been resolved. Some matters can be resolved immediately over the phone. For example, the operator may be able to convince the caller that the information being reported is a patently false rumor that has already been examined. Give operators yes and no boxes in which they can indicate whether the problem has been resolved. Also give them space to indicate the resolution if the answer is yes. A yes answer generally tells the compliance officer that no follow-up is necessary. However, sometimes operators make mistakes and follow-up is needed anyway. For example, the operator may be wrong about the caller's information being a rumor.

9. Whether follow-up arrangements were made. If the matter isn't resolved, the operator should note any follow-up arrangements that were made. For example, the caller may have agreed to try to learn more about the situation and call back in a week.

10. Date and time the sheet was forwarded and to whom. The last item operators should note is the date and time the completed hotline report sheet was forwarded to the compliance officer or other designated contact. If the sheet was forwarded to a designated contact, the operator should fill in that person's name.

11. Date and time the sheet was received. It's up to the person who receives the hotline report sheet-the compliance officer or other designated contact-to complete the remaining items on the sheet. This includes the date and time the sheet was received.

12.Any referral made. In some cases, the compliance officer may refer the matter to a more appropriate person. For example, the personnel department may handle sexual harassment complaints. If so, the time and date of the referral should be noted, along with the name of the person to whom the referral was made.

13.Acknowledgment of entry in log. Include a check box for the compliance officer to indicate that the information on the hotline report sheet was entered into the hotline log. This helps ensure that this step isn't overlooked. It also helps prevent the same report from inadvertently being entered twice.

Insider says: Once a sheet is completed, the compliance officer should open a correspondence file for it, explains Murtha. The compliance officer should keep records of all follow-up actions taken to deal with the problem and attach them to the report sheet. When the matter is resolved, the compliance officer should create a final report indicating what the resolution was and the date it took effect. That report should also go in the file.

Insider sources:

F. Lisa Murtha, KPMG LLP, 345 Park Ave., 39th Fl., New York, NY 10154. Alex Schillaci, Deloitte & Touche, Stamford Harbor Park, 333 Ludlow St., Stamford, CT 06902-6982. Stacey Schleifer, Esq., National Hotline Services, Inc., 112 S. West St., Alexandria, VA 22314.

 

Sample hotline report sheet

Important: This report is proprietary and contains information that is confidential. Photocopying this report or disclosing
information it contains without authorization is strictly prohibited. If you find this report or receive it in error,
please call 202/123-4567 immediately.

Serial number: ___________________________ Date: ______________________ Time: _______________________
Call received by: _________________________________________________________________________________

Introductory questions
Did caller acknowledge hearing and understanding the prerecorded message? yes ? no ?
Did caller specifically acknowledge hearing and understanding the rules and limitations of anonymity/confidentiality
explained in the prerecorded message? yes ? no ?
Did caller identify self? yes ? no ?
If yes, caller's identity and phone number: _____________________________________________________________
Caller's division: _________________________________________________________________________________
Did caller ask that identity be kept in confidence? yes ? no ?
Material facts provided about allegations/concerns: ______________________________________________________
_______________________________________________________________________________________________
Advice, representations, or promises you made to the caller: ______________________________________________
Was problem resolved? yes ? no ?
If so, explain: ___________________________________________________________________________________
Arrangements made for follow-up contact: ____________________________________________________________
Date and time report was forwarded to compliance officer or designated contact: ______________________________
To whom was report referred? ______________________________________________________________________

For compliance office use only
Date and time report was received: ___________________________________________________________________
Was report referred? yes ? no ? If yes, to whom?____________________________________________________
Date and time of referral: __________________________________________________________________________
Check this box to acknowledge that the report has been entered into the log. ?
Sample hotline report sheet

Source: National Hotline Services, Inc. Reprinted with permission.

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