Hotline and Case Management System Now that you have them, what do you do with them?

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Hotline and Case Management System

“Now that you have them, what do you do

with them?”

Mike Hill

Chief Audit Officer, GHSU

Tad Bixby

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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

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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

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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.

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First polling question

Who in the room does not have

enough work to do?

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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

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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

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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

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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.

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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.

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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.

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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.

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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

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WHY IS YOUR COMMUNICATION

AND MARKETING PLAN SO

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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

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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

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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

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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

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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

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Global Compliance “We Walk the Walk”

Integrated Communications Campaign

e-Counselor Intranet Site e-mail Launch Awareness Center

Posters, Brochure, Wallet Card Educational Videos

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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

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Surveys

(These may be annual or bi-annual)

• Survey Monkey, Boomerang, etc.

Focus Groups

(Senior Leadership, Faculty and

Administrative Staff, you may want to combine

these groups at times for discussion and

feedback.)

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Case Management Program

Start slow and small.

Build it together. Use your

Triage Team members – get

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Reasons to implement system

• Enhancement to internally managing institutional

issues

• Increased case/issue management within one

department and/or between two or more

departments

• Resource for tracking case/issue topics and reference

(library) system

• Provides data base for analytical reporting and

research

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