Keep complaints in-house with confidential hotline

An ethics expert urges health care organizations to open a confidential hot-line for employees to call to report misconduct. Organizations can use the information from a good hotline to make disclosure before an outside agency discovers any improper acts, says Mark Pastin, PhD, president of the Council of Ethical Organization, which promotes ethics and compliance in a variety of industries, including health care. The early disclosure shows the organization is capable of self-governing and not in need of extended external supervision.

"To be most effective, this hotline should be open at all times and must be made available to previous employees. By creating an environment in which others will report improper acts, corporations can isolate those committing or covering up these acts and take appropriate remedial action," says Pastin. He says a hotline gives the employee an alternative outlet for reporting misconduct, rather than going to an external agency or the media or initiating litigation.

For the hotline to be effective, employees must have confidence in its confidentiality. He said neither supervisors nor managers should have access to the phone logs or the names of those who use the hotline. He says compliance personnel manning the hotlines must understand the importance of preserving the anonymity of those reporting a problem.

In addition, the corporation must have a firm, separate and well-publicized policy prohibiting retaliation against employees who make good-faith reports of potential improprieties. He advises the policy be published separately from employee handbooks, which are seldom read.

"Creating an effective hotline can be difficult because it thwarts the natural line of command in a corporation," Pastin says. "However, when weighed against the alternatives — employees going to external agencies, the press or the courtroom — creating a hotline as part of a complete compliance program suddenly becomes not only very attractive, but essential."