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

Transcription

1 Hotline and Case Management System Now that you have them, what do you do with them? Mike Hill Chief Audit Officer, GHSU Tad Bixby Practice Director, Global Compliance

2 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 adopted an integrated approach. 2

3 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 3

4 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, ) 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. 4

5 First polling question Who in the room does not have enough work to do? Please raise you hand 5

6 6 Dilbert

7 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 7

8 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 8

9 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 Evaluation and Validation (Monitoring) 9

10 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 account. Where reports have been provided to our office. 10

11 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. 11

12 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. 12

13 13 Step 3 (Cont.)

14 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. 14

15 15 Example of Incident Report

16 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 marketing and campus communication plan. 16

17 WHY IS YOUR COMMUNICATION AND MARKETING PLAN SO IMPORTANT? 17

18 Uncovering Business Misconduct Tip Management Review Internal Audit By Accident Account Reconciliation Document Examinatin External Audit 11.60% 17.60% 15.40% 13.00% 15.10% 16.70% 11.60% 10.70% 5.30% 6.80% 11.20% 6.50% 4.60% 3.90% 8.20% 8.90% 3.90% 5.00% 6.00% 6.50% 7.40% 2.30% 5.20% 6.50% 35.80% 41.10% 43.20% 46.30% Government Public Corporation Private Corporation Non-profit 0% 10% 20% 30% 40% 50% Source: 2010 ACFE Report to the Nations on Occupational Fraud and Abuse 18

19 Communication is imperative to the receipt of quality, actionable reports Best Practice Ethics and Compliance Hotlines 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 19

20 Impact Of Ethics/Compliance Programs Would feel comfortable reporting misconduct to a supervisor? Believe they would be doing the right thing by reporting misconduct? 100% 88% 100% 92% 63% 50% 51% 50% 0% Without Program With Program 0% Without Program With Program 20 Source: KPMG Integrity Survey 2008/2009

21 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.) 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 Distribute announcement with existing employees through payroll notification. 21

22 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 through office website. 22

23 Intranet Site Global Compliance We Walk the Walk Integrated Communications Campaign Launch Educational Videos Awareness Center Posters, Brochure, Wallet Card e-counselor 23 Crack the Code Certification Online Training Course Wallpaper & Screensaver

24 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 24

25 Methods to assist in evaluation 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.) 25

26 Case Management Program Start slow and small. Build it together. Use your Triage Team members get their input. 26

27 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 27

28 28 Portal Landing Page (IntegriLink)

29 29 Enter your own reports directly into the system

30 30 Case List

31 31 Case View (IntegriLink): notes, attachments, work flow, status, etc.

32 32 Workflow Tabs (IntegriLink)

33 33 Case Search

34 34 Monthly Management Report Library

35 QUESTIONS?