Compliance Culture Building Block #2: Understand your whistleblowers.  

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Red Phone

Whistleblower Hotline

Margaret ScavottoBy Margaret Scavotto, JD, CHC
Director of Compliance Services
Management Performance Associates

The whistleblowing business is growing every year. More than 700 whistleblower suits were filed in Fiscal Year 2014, generating $2.9 billion for the government, and $435 million for whistleblowers.[i] One hospital employee brought home $20.8 million for blowing the whistle on her employer. This made national news, which means your employees might have heard about it.[ii]

Do your employees trust you to treat compliance complaints seriously?

Should they?

Whistleblowers typically resort to calling the government because they believe their employer won’t, or hasn’t, taken them seriously. In other words: the culture of compliance is weak.

Providers can’t compete with the 6- and 7- figure payout the federal government offers your employees. But you CAN create an environment where employees feel comfortable reporting internally. A prominent goal of every compliance program should be to encourage internal whistleblowing. This will allow your organization to research and fix problems as soon as possible.

Remove all obstacles to internal whistleblowing

If you don’t already have a toll-free compliance hotline, this should be a top priority. But don’t stop there. Protect your hotline with anonymity, non-retaliation, and confidentiality policies. Remove all excuses an employee (or competitor!) might use to avoid reporting internally. If your organization is small, employees might worry their voice would be recognized on the compliance hotline voicemail. Consider providing at least one alternative method of reporting, such as a lobby drop box or website form. By removing obstacles and encouraging internal reporting, you help create a culture that encourages employees to complain to you.

The next step in cultivating a culture where employees feel comfortable reporting internally is to treat complaints seriously. Every single compliance complaint needs to be documented and investigated. If non-compliance is found, corrective action must be taken consistently, every time. These steps will show employees that you take their concerns seriously. Remember: employees who feel internal reporting is futile are more likely to go straight to the government. By creating a culture of compliance and encouraging internal reporting, you can address problems without government intervention.

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[i] Press Release, Office of Pub. Affairs, U.S. Dep’t of Justice, Justice Department Recovers Nearly $6 Billion from False Claims Act Cases in Fiscal Year 2014 (Nov. 20, 2014), http://www.justice.gov/opa/pr/justice-department-recovers-nearly-6-billion-false-claims-act-cases-fiscal-year-2014 (last checked November 11, 2015)
[ii] Florida Hospital System Agrees to Pay the Government $85 Million to Settle Allegations of Improper Financial Relationships with Referring Physicians, See Press Release, Office of Pub. Affairs, U.S. Dep’t of Justice, March 11, 2014, available at: http://www.justice.gov/opa/pr/florida-hospital-system-agrees-pay-government-85-million-settle-allegations-improper (last checked November 11, 2015)