Hotline and Case Management System
“Now that you have them, what do you do
with them?”
Mike Hill
Chief Audit Officer, GHSU
Tad Bixby
About Georgia Health Sciences Enterprise
The University – GHSU (formerly the Medical College of
Georgia) was founded in 1828
GHSU has more than 2,500 students in five colleges:
Medicine, Allied Health Sciences, Dentistry, Graduate Studies
and Nursing
GHSU has approximately 5,000 faculty, staff and residents (the
Enterprise has over 8,500 total employees)
Total Sponsored Research - $90 million
Total Revenue for Enterprise over $1.1 billion
The Hospital (Georgia Health Sciences Medical Center) is a
separate entity from the University, but since July 2010 the
University, Hospital and Physicians Practice Group have
About Global Compliance
•
Pioneered the original ethics/compliance reporting hotline in 1981
•
Provides a comprehensive set of ethics/compliance offerings:
– Hotlines/Case Management Solutions – Training and Education
– Consulting and Assessment – Inspections and Validations
•
Serves 4,000+ clients and their 25+ million employees in more than 200
countries and territories
•
Serves 50% of Fortune 100, 45% of Fortune 500, 35% of Fortune 1000 and
25% of Global 500
Session Objectives
• Connect the Federal Sentencing Guidelines and Hotline Services – Understand why you need a Hotline.
• Better understanding of the Hotline Service and Case Management System and their potential use.
• Discuss initial implementation of Hotline and Case Management functions. Who needs to be involved in implementation of Hotline?
Who gets reports and triages them for assignment?
Who administers the hotline, who is the support for the system? Who needs to be involved in the training of the system?
• Provide suggestions on increasing awareness of Hotline and the other options (i.e., internet, email) for reporting fraud, non-compliance, questionable activities, etc.
• How use of the Case Management system will increase effectiveness and efficiencies on reviews that involve multiple departments.
First polling question
Who in the room does not have
enough work to do?
Current Environment
• For most organizations, ethics and compliance exposure − and the
associated risk − remains high; most organizations are subject to a
breadth of potentially damaging business misconduct
• Newly implemented legislation has placed an even greater focus on
ethics and compliance and the associated risks:
– SEC Whistleblower program rules adopted (Dodd-Frank Act) – UK Bribery Act implemented
• Major organizations across diverse industries continue to be
assessed large fines and penalties as a result of ethics and
compliance failures
• Despite more focused ethics and compliance efforts, business
misconduct is still both prevalent and costly
The Risk is Real
• Business misconduct is a legitimate business risk in today’s
environment − financial, legal and reputational risk
• Business misconduct can be driven by a host of issues ranging from
unrealistic targets to lack of leadership to inability to distinguish
right from wrong
• To mitigate ethics and compliance risk, organizations must design
and implement an ethics and compliance program tailored to their
organization, giving consideration to:
– Industry of operation
– Geography of operation
– Employee population size and employee demographics
– Organizational culture and personality
Nine Elements of an “Effective” Ethics and
Compliance Program
An “effective” ethics and compliance program as defined by the U.S. Sentencing Commission includes the following 9 elements:
Risk Assessment
Code of Ethics or Conduct and Ethics and Compliance Policies Tone from the Top – Ongoing Communications
Training
Vehicles for Reporting Suspected Misconduct or Noncompliance Centralized Data Repository
Standardized Case Investigation, Management and Disposition Data Analytics
Step 1
Select who will be responsible for administering the Hotline and Case
Management (CM) programs?
Suggestion
The department selected needs to have administrative support staff (i.e.,
para-pro type position) and make this position part of the triage team that
receives the initial incident reports.
Example
GHSU uses the Compliance and Enterprise Risk Management office as the
Admin Dept for our Hotline and CM programs. GHSU’s
Compliance/Privacy Analyst is the Administrative User, who also receives
copy of each report from Hotline Provider. This position also is
responsible for the generic office email account. Where reports have
been provided to our office.
Step 2
Determine your Triage Team for Incident Reporting
Who is going to be part of the initial team that receives the
incident report and analyzes the actions to be taken?
Suggestions
Select departments /individuals that are usually involved in
employee matters. Why – A majority of reports will involve
employee relations type matters.
Dept Considerations: Internal Audit; Legal; Compliance; Human
Resources; Public Safety; Information Technology.
Step 3
Develop your internal institutional process for incident reports
once received from the provider.
Examples/Considerations
Establish timeframe to assign cases.
Establish reporting/work timeframes to complete preliminary
review.
Establish tracking responsibilities.
Develop communication guidelines with administrator and team
members.
Step 4
Train your Triage Team and other
personnel that may be involved
with case review/investigations.
Each team member needs to understand the
incident reports and how the CM works.
Step 5
Draft
a Communications and Marketing Plan for
your campus.
Communicate your Hotline and Case
Management programs and processes to
senior leadership.
Get their buy-in and any suggestions that they
may have prior to finalizing the
draft
WHY IS YOUR COMMUNICATION
AND MARKETING PLAN SO
Uncovering Business Misconduct
6.50% 6.50% 8.90% 6.50% 10.70% 13.00% 43.20% 5.20% 6.00% 8.20% 11.20% 11.60% 15.40% 35.80% 2.30% 5.00% 3.90% 6.80% 16.70% 17.60% 41.10% 7.40% 3.90% 4.60% 5.30% 15.10% 11.60% 46.30% 0% 10% 20% 30% 40% 50% External Audit Document Examinatin Account Reconciliation By Accident Internal Audit Management Review Tip Government Public Corporation Private Corporation Non-profit•
Communication is imperative to the receipt of “quality, actionable” reports
– Regularly reinforce that employees should “speak up” if business misconduct is observed
– Continually remind employees about available channels of reporting
– Reassure employees that they will not experience retaliation for speaking up when business misconduct is observed
– Ensure reporters receive notification that the matter was investigated and
appropriate action will be taken; keep channel of communication open to ensure reporter believes report was taken seriously
– Consider internally sharing high-level details about business misconduct uncovered through a tip, and celebrate the reporter for speaking up
Ethics and Compliance Hotlines
Impact Of Ethics/Compliance Programs
51% 88% 0% 50% 100% 63% 92% 0% 50% 100%Would feel comfortable reporting misconduct to a supervisor?
Believe they would be doing the right thing by reporting
misconduct? Without Program With Program Without Program With Program
Step 6
Communications Plan
•
Introduce hotline and case management initiatives to Senior Leadership.
(Make presentations for President’s Cabinet, Deans Council, Faculty
Senate, Administrative Dept staff meetings, etc. and give them
opportunities to ask questions.)
•
Email message from President to all employees. (This reinforces the tone
from the top and importance of this initiative.)
•
Place hot button and announcement on internet/intranet sites. (Link web
page(s) to on-line reporting and information page.)
•
Use campus paper for article and placement of “public service
announcements” (these are usually free of charge).
•
Include in new employee orientation
Step 7
Marketing Plan
• Develop an identifier and identifying color scheme for Hotline
Program. (In other words a Name and a Look)
• Develop website/webpages.
• Develop marketing materials – posters, brochures,
business/wallet card, computer screen saver/wallpaper, etc.
• Periodic communications using newsletter and/or e-blast
Global Compliance “We Walk the Walk”
Integrated Communications Campaign
e-Counselor Intranet Site e-mail Launch Awareness Center
Posters, Brochure, Wallet Card Educational Videos
Step 8
Gauge Awareness of Hotline Program
• Important to evaluate and measure impact of communications strategies and tactics
– Quantity and quality of Hotline reports
– Customer/constituent complaints and concerns
• Claims typically rise in poor economic times as employees are laid off or fear being terminated
– Industry issues, including investigations, sanctions and settlements involving competitors and partners
– Human resources trends, including attrition and complaints – Staff and business leader feedback and suggestions
