Healthcare News & Insights

Protect your hospital against whistleblowers

When it comes to whistleblowers, there are people who just have dollar signs dancing in their eyes at the though of sharing in the government’s recovery. But more often than not, whistleblowers are employees who are genuinely concerned about noncompliance and get frustrated when the issues are ignored. So what can you do to protect your hospital?

The answer is easy: Have an effective compliance program. But that takes work.

Here are some best practices the law firm DrinkerBiddle recommends for hospitals:

  • Make the program easily accessible to all employees. It goes without saying that every hospital should have a formal compliance program and a compliance officer to run the program, especially if they participate in federally funded healthcare programs. However, having a program isn’t enough. You must make sure all your employees get a copy of the compliance program, and remind them on a regular basis where to find the program and how to get in contact with the compliance officer. And the process of finding the program and contacting the compliance officer needs to be made as easy as possible.
  • Make reporting non-compliance mandatory. All employees should be required to report non-compliance — just encouraging employees to do it isn’t enough.  And let them know that failure to report non-compliance could result in disciplinary actions, even termination.
  • Broadcast reporting process and hierarchy. Employees need to know that they should report any non-compliance to their supervisor first. However, they also should know that if their supervisor’s response is inadequate, they must report it to the compliance officer.
  • Document all report responses. Whenever an employee files a report of potential non-compliance, it should be thoroughly investigated and your investigation should be documented. Part of the investigation should require the reporting employee to be interviewed by at least two people so they can compare stories, and that person should be kept abreast of the investigation as appropriate. By doing this, the reporting employee will see you took his or her complaint seriously and conducted a thorough investigation.

Having a good process in place for reporting and responding to non-compliance can help deter employees who are in it for the money from filing a False Claims Act (FCA) complaint, and look good for you if the government does get involved.

For information on the FCA and more tips on compliance best practices, click here.


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