Little Data Matters Too: Analyzing Compliance Hotline Data

Margaret C. Scavotto, JD, CHC
President, Management Performance Associates

Data uses truly are getting bigger and bigger. Compliance officers who don’t mine data might feel left in the dust. But your compliance program likely holds pockets of valuable and readily accessible data, even if you aren’t high tech.

Consider hotline calls as an example. (If you don’t have a hotline, your records of drop box or in-person compliance reports will also work). As long as you log compliance reports, you have data. Here are some examples of data you can track without software, an IT background, or a big budget:

• Number of reports each quarter or year
• % of reports that are anonymous
• Breakdown of reports by reporting method (e.g. in person, drop box, hotline)
• Breakdown of reports by risk area (e.g. HIPAA, documentation, vendor gifts)
• Breakdown of reports by department or supervisor

Once you organize your data, look for trends. Does your data tell a story? Here are some examples of stories we have discovered when analyzing compliance report data:

• Reports often increase when a provider increases its promotion of compliance awareness and encourages reporting.
• Anonymous reporting sometimes decreases as a new compliance officer gains the trust of staff.
• A surge in HIPAA complaints could indicate that staff need more HIPAA education. But, if the surge follows recent HIPAA education, it could mean staff
  are now reporting problems they did not previously recognize.
• If complaints are concentrated in a single department, this could indicate this department needs help adhering to compliance protocols.

You won’t know your data’s story until you investigate. But collecting and organizing your data is the first step.

Wondering where you stand? NAVEX Global’s 2018 Ethics and Compliance Hotline and Incident Management Benchmark Report provides a yardstick. According to the NAVEX Global report:

• The median number of reports is 1.4 per 100 employees
• 39% of reports are collected by non-hotline methods, like walk-ins, emails, and the open door policy
• 56% of reports are anonymous (compared to 65% in 2009)

The NAVEX Global report is not specific to healthcare, and it includes worldwide data. But its statistics can provide a comparison point for those beginning to mine their own data. It would also be helpful to compare new information with your historical data (if and when you have it), and measure results against your organization’s goals.

Over time, your use of little data can lead to a better understanding of your organization, and create a big impact.