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Developing mechanisms for reporting compliance violations
M A Dowell1, A G Russell, J H Gordon
1Miller & Holguin, Los Angeles, California, USA. mdowell@millerholguin.com
Abstract:
Both the Federal Sentencing Guidelines and the Office of Inspector General's (OIG) Compliance Program Guidance for Hospitals can assist healthcare organizations in establishing a reporting system that encourages employees to report wrongdoing. One mechanism that is commonly used is the telephone hot line. Other mechanisms that can be used in conjunction with a hot line include a drop box or post office box, written or oral reports to supervisors, an open-door policy on the part of compliance personnel, and employee exit interviews. However the reporting system is set up, it should ensure confidentiality and a policy of nonretaliation to encourage the participation of all employees. Having a sound reporting system in place will enable healthcare organizations to investigate any alleged instances of noncompliance and take corrective action before the Federal government becomes involved.
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