Resource: Sample Corporate Compliance HelpLine Policy

By Greg Radinsky,^[1] JD, MBA, CHC, CCEP

[Facility Name]
POLICY TITLE: Corporate Compliance HelpLine	ADMINISTRATIVE POLICY AND PROCEDURE MANUAL
POLICY #: [NUMBER]	CATEGORY: Corporate Compliance
System Approval Date: [DATE] Site Implementation Date:	Effective Date: [DATE] Last Reviewed/Revised: [DATE]
Prepared by: Office of Corporate Compliance	Superseded Policy(s)/#: N/A

GENERAL STATEMENT of PURPOSE

[ORGANIZATION NAME] is committed to the timely identification and resolution of all issues that may adversely affect employees, patients, or the organization. Therefore, [ORGANIZATION NAME] has established communication channels to report problems and concerns, including a Corporate Compliance HelpLine number (PHONE NUMBER) and website [WEBSITE ADDRESS]. The HelpLine is available 24 hours, seven days a week. Individuals are encouraged to report any problem or concern either anonymously or in confidence via the HelpLine as they deem appropriate. Individuals also have the option of contacting the Office of Corporate Compliance Office directly via telephone at [PHONE NUMBER] or fax at [FAX NUMBER] during regular business hours or in-person at [ORGANIZATION NAME].

The Corporate Compliance HelpLine is an avenue by which individuals or interested parties may report any issue or question associated with any of the [ORGANIZATION NAME]’s policies, conduct, practices or procedures believed by the individual to be a potential violation of criminal, civil or administrative law, or any unethical conduct.

All individuals are protected from non-intimidation and non-retaliation for good faith participation in [ORGANIZATION NAME]’s Compliance Program. Failure to report a compliance issue may be grounds for disciplinary action.

Examples of potential compliance issues include, but are not limited to:

Inappropriate coding
Inappropriate charging/billing
Inappropriate charge code selection/chargemaster
Inappropriate claims submission
Overpayments
Medical necessity issues
Cost reporting issues
False or fraudulent documentation issues
Requests from Fiscal Intermediary/Carrier
HIPAA or Patient Privacy issues
EMTALA issues
Failure to follow policies and procedures
Failure to follow Code of Ethical Conduct
Drug diversion (illegal sale or redistribution of drugs)
Physician relationship issues such as potential violations of the Stark law or Anti -Kickback statute
Potential violations of the Anti-Kickback Statute related to vendors (e.g., inappropriate gifts)
Provider or Supplier Excluded from the Federal or State Health Care Programs
Inappropriate Conflict of Interest
Retaliation or Intimidation

POLICY

[ORGANIZATION NAME] will maintain a Corporate Compliance HelpLine that individuals may use to report problems and concerns, which may be done anonymously.
Individuals who report problems and concerns via the Corporate Compliance HelpLine or to the Corporate Compliance Office in good faith are protected from any form of retaliation, intimidation and/or retribution. See also [ORGANIZATION NAME] Policy #[NUMBER] - Detecting and Preventing Fraud, Waste and Abuse, [ORGANIZATION NAME] Policy #[NUMBER] - Non-Retaliation and Non-Intimidation, and Human Resources Policy Part [NUMBER] – Conduct in the Workplace/Progressive Discipline.
Information concerning the Corporate Compliance HelpLine will be posted in prominent common areas of [ORGANIZATION NAME] facilities.
All individuals who receive compliance inquiries are expected to act with the utmost discretion and integrity in assuring that information received is acted upon in a reasonable and proper manner. Everyone who receives or is assigned responsibilities for assisting with compliance inquiries shall keep the inquiries confidential to the extent possible.

SCOPE

This policy applies to all members of the [ORGANIZATION NAME] workforce including, but not limited to: employees, medical staff, volunteers, students, physician office staff, and other persons performing work for or at [ORGANIZATION NAME]; faculty and students of the [ORGANIZATION NAME] School of Medicine conducting Research on behalf of the School of Medicine on or at any [ORGANIZATION NAME] facility; and the faculty and students of the [ORGANIZATION NAME] School of Graduate Nursing & Physician Assistant Studies.

PROCEDURE/GUIDELINES

Process

The Office of Corporate Compliance will ensure that all compliance inquiries are addressed in an appropriate and timely manner, as well as in accordance with this and all related policies and procedures. No attempt will be made to identify a caller to the Corporate Compliance HelpLine who requests anonymity. Whenever callers disclose their identity, it will be held in confidence to the fullest extent practical.
Upon receipt of the disclosure, the Chief Corporate Compliance Officer or his/her designee shall gather all relevant information from the disclosing individual where practicable. The Chief Corporate Compliance Officer/designee shall make a preliminary, good faith inquiry into the allegations to ensure all the necessary information has been obtained to determine whether a further review should be conducted.
In accordance with [ORGANIZATION NAME] Policy #[NUMBER] - Corporate Compliance Investigative Resolution Process, [ORGANIZATION NAME] shall conduct an internal review of the allegations and ensure that proper follow-up is conducted for any disclosure that is sufficiently specific, so that it reasonably permits a determination of the appropriateness of the alleged improper practice and provides an opportunity for taking a corrective action.
Calls will be logged in a case-tracking database upon receipt and placed in care of the custody of the Office of Corporate Compliance.
The investigation and response process may involve other departments, as appropriate, for advice and/or further investigation.
The Office of Corporate Compliance will communicate any matter deemed potentially unlawful to the Office of Legal Affairs for determination.
The Chief Corporate Compliance Officer will periodically report on Corporate Compliance HelpLine activity to the Executive Audit and Compliance Committee and the Audit and Corporate Compliance Committee of the [ORGANIZATION NAME] Board of Trustees and other committees as appropriate.

REFERENCES to REGULATIONS and/or OTHER RELATED POLICIES

[ORGANIZATION NAME] Policy #[NUMBER] – Non-Intimidation and Non-Retaliation Policy

[ORGANIZATION NAME] Policy #[NUMBER] – Corporate Compliance Investigative Resolution Process

[ORGANIZATION NAME] Policy #[NUMBER] – Detecting and Preventing Fraud, Waste and Abuse

Human Resources Policy Part [NUMBER] – Conduct in the Workplace/Progressive Discipline

CLINICAL REFERENCES

N/A

FORMS

[ORGANIZATION NAME] Hospital Inhouse Directory Form
APPROVAL:
System Administrative P&P Committee	[DATE]
System Committee/Clinical Operations Committee	[DATE]