Under the Affordable Care Act, medical service providers must establish compliance programs to enroll in the Federal health care programs. HHS has neither issued regulations on the core requirements of these compliance plans nor set a date for mandatory compliance. Providers, however, should consider adopting a compliance hotline program prior to the mandate not only because a requirement is imminent, but also to prevent fraud and demonstrate good faith.
Elements of an Effective Compliance Program
One of the seven elements of an effective compliance program is developing open lines of communication. CMS recommends that lines of communication run in multiple directions and include a process for anonymous reporting to provide an outlet for employees who may fear retaliation.
Many providers utilize an outside vendor to facilitate anonymous reporting. If you elect to use an outside vendor, you should choose a well-managed hotline that is focused on the health care sector. In addition, your organization should periodically audit the hotline to measure its effectiveness.
Considerations of a Compliance Hotline Audit
When auditing a compliance hotline vendor you should consider (a) does the hotline have established policies and procedures, (b) how is the hotline managed, and (c) does the hotline meet its goals.
Some questions you might use to review the hotline’s management, operation, and effectiveness include:
- Does the hotline follow its established policies and procedures?
- Do the policies discuss how to document and follow-up calls?
- Does the hotline act on calls and/or emails promptly?
- Does the hotline follow up with callers who provide contact information?
- Are hotline administrators properly trained to answer calls and ask appropriate questions?
- Does your department tasked with reviewing hotline reports receive reports in a timely manner?
- Are the reports provided by the hotline detailed enough to allow your organization to follow up and investigate?
- Is caller anonymity being protected?
- Are hotline files protected?
In addition, you should also evaluate your office’s internal use of the hotline by considering the questions below.
- Are employees aware and reminded that the hotline is available?
- Does the department tasked with handling reports follow up properly?
- Are your employees using the hotline?
- Do employees seem confident about the effectiveness of the hotline?
- Does the department handling hotline reports file and protect reports appropriately?
If you answered “no,” to one or more of these questions, it may be time to consider a new vendor. Call Exclusion Screening, LLC today to discuss our ComplianceHotline, which is staffed by Certified Medical Compliance Officers, today at 1-800-294-0952.