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Exit interviews: All in a day's work

Rehab Regs, February 1, 2005

Talking with outgoing employees can benefit both you and your therapists

Regardless of your setting or location, your facility is bound to experience turnover. When you do, treat the situation as an opportunity to improve your employee satisfaction as well as your compliance by conducting exit interviews.

Exit interviews can serve many purposes for employees regardless of why they are leaving your facility. For some, it may be an opportunity to comment on operational topics, whereas for others it can provide a time for them to criticize (constructively or not) an issue they may have been reluctant to bring up while they worked at the facility, says Carol C. Loepere, JD, a partner with Reed Smith, LLP, in Washington, DC.

"The Office of Inspector General views having effective lines of communication as part of an effective compliance program," says Loepere. "Exit interviews are critical because they benefit both employees and the rehab facility."

It's also a time to take care of logistical details such as where to send the employee's last check. Although no federal mandates dictates these types of employment matters, check your individual state employment laws, advises Loepere. You can then apprise your outgoing employees of when they will receive their last paycheck.

Likewise, exit interviews can leave employees with a sense of closure. "It is a proactive way for employees to feel as though they've been heard," says Loepere. "They may identify issues that have been dealt with and the employee just didn't know about [them]."

Although the exit interview can allow the employee to clear the air, it benefits the rehab facility as well, in the following ways:

Encourages troubleshooting. Facilities can use comments made by outgoing employees to improve the work life of current employees, says Ken Mailly, PT, of Mailly and Inglett Consulting, LLC, in Wayne, NJ.

"It's a good opportunity to take the pulse of the facility," says Mailly. "You can get information about whether you are a hospitable employer."

If you can address some ongoing problems that negatively influence your turnover rate, you may be able to keep your existing employees content. "You should work to create an environment where you have straightforward dialogue all along," says Angie Phillips, PT, president and chief executive officer of Images & Associates in Amarillo, TX. "The benefit of an exit interview is that it can help you hire, develop and keep good employees."

Limits liability. If a former employee accuses you or your facility of wrongdoing after he or she has departed, it may help your case if you have documentation of the exit interview discussion.

"If there's documentation that [says] we met and investigated the problem, it will be important as a mitigating factor," says Mailly.

But remember the old saying: "If you didn't document it, it didn't happen." You must record the employee's comments and also your actions to remedy the situation for the documentation to help you in court or during a government investigation.

Similarly, see Loepere's sample exit interview statement on p. 5.

Complements your compliance plan. A total compliance plan begins even before you hire employees, by basing their job descriptions on professional standards, says Mailly. Find these standards through the American Physical Therapy Association and the American Occupational Therapy Association and then tailor them to your facility. The exit interview can help you determine whether your facility follows through on this professional development.

"People think that compliance means Medicare, but what it really means is, 'Are you doing what you should be doing?' " says Mailly. "Corporate compliance means that you are fostering a culture of doing what is right."

Encourages professionalism. If you discover that a departing employee is leaving because he or she felt as though his or her professional judgment was overridden, you can change that practice at your facility. "It's a compliance, legal, reimbursement, and liability issue that should set off alarms in that facility," says Mailly. "It requires immediate remediation."

If you plan to incorporate exit interviews at your facility, first decide the following:

Who should attend. Loepere suggests including the employee's supervisor, a representative from the compliance or human relations department, and, depending on the situation and the size of the organization, a member of the legal department.

If you think some employees may be worried about burning bridges and won't be entirely honest if their direct supervisors sit in on the interview, you may want to omit them, says Phillips.

How to document. Create a form that serves as a checklist for the interviewer. It can include reminders about returning company-owned materials (e.g., keys, software, etc.), and can also serve as a way to document problems or criticisms the employee had.

How long to retain the records. File the interview notes into a personnel record and retain them according to any state law requirements. Best practices call for facilities to keep these records for at least six years.

The Marden Companies, headquartered in Marietta, OH, chooses to conduct exit interviews differently. After employees have been gone from one of their rehab facilities for two weeks, a compliance officer contacts them.

"We give them that time to unwind and separate themselves [from the facility]," says Cynthia Bowersock-Thiel, RN, vice president of The Marden Companies. "We try to make that connection after they've left."

This strategy serves two purposes. First, it gives the former employee the freedom to say whatever is on their minds because they have already left the facility and they are also not talking to their direct supervisors. Second, by contacting therapists after they start to work elsewhere, if they decide to make another job change, it might be back to the original facility.

"We've heard from people that their [new] job wasn't what they thought it would be," says Bowersock-Thiel. "We've had people ask to come back and we've rehired them."

But as with interviews conducted on an employee's last day of work, documenting any issues is a key component of improving the work climate for current therapists.

"You have to close the loop," says Bowersock-Thiel. "If there is a complaint, you have to investigate the situation."

Individual facilities must decide whether to incorporate exit interviews into their protocol. Larger facilities with human resources departments might be more likely to conduct them, but they may be even more vital in smaller rehab clinics and companies.

"The proportional impact of an employee leaving a smaller facility is much greater," says Mailly.

In the end, exit interviews can give rehab management insight into becoming more efficient and better service providers.

Ask your departing employees to sign a statement such as the one below during their exit interview. It will protect your facility from disgruntled employees who may sue after they have left the company.

I acknowledge that as an employee of [company/facility], I received the [standards of ethical business conduct, known as the "Standards"], confirmed my understanding of the Standards, and agreed to comply with them. I also acknowledge that as part of the Standards, I had an obligation to report suspected violations of the Standards, including applicable laws, that I observed or that became known to me, to my supervisor and/or [the compliance officer/a member of the compliance committee]. I acknowledge and agree that I am not aware of any current or past violations of the Standards, including but not limited to fraud, wrongdoing, billing for services not rendered, or insufficient/inadequate care (or have reported such violations as outlined below).

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