Have You Tested Your Compliance Hotline Lately?

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

The Kansas Medicaid fraud and abuse complaint email inbox went unchecked for 17 months.

According to a report issued by the Kansas Office of the Medicaid Inspector General, 209 emails were unread. 95 of these emails “alleged fraud, waste, abuse, or illegal acts related to Medicaid, MediKan, or SCHIP, or were seeking information on how to report suspected fraud.” 42 of these emails contained “partially or wholly substantiated allegations of Medicaid or SCHIP fraud, waste, abuse or illegal acts….

How did it happen?

The complaint inbox went unchecked from August 2, 2017 to January 9, 2019.

On June 1, 2017, the Kansas OIG, which oversees the Kansas Medicaid program – and had been completely unstaffed since 2014 – was moved form the Kansas Department of Health and Environment (KDHE) to the Kansas Attorney General’s Office. Because the OIG was unstaffed, there were no staff to notify the AG’s office to check the complaint inbox. Further, a KDHE administrative employee monitored the account until her departure in August 2017 – but nobody checked the inbox after she left.

Could this happen to you?

When I conduct a compliance program annual review, I test the compliance reporting methods. This means calling hotlines, sending test emails, and chatting with live hotline operators. I have had a lot of lovely chats, and received many encouraging email replies and return calls.

But I have also gotten a fair amount of busy signals, email bounces, annoying fax machine noises and disconnected phone messages. And the most disappointing of all: days, weeks, or months of silence when nobody gets back to me.

When is the last time you tested your compliance reporting methods? And if yours fails, who will your employees call instead?

2 COMMENTS

  1. Great post and great advice Margaret! I think this is also a best practice simply to check the quality control of our hotline vendor services. Like any call center, hotline vendors have a good amount of turnover and we have to make sure operators are professional, asking the right questions and that language services are translating appropriately, etc. Thanks for posting!

  2. Thank you, Joseph – and great idea! I agree – that check-in is crucial to make sure hotline vendors are representing the compliance culture contracting with them. This is a great item to include in any compliance program annual review. Thank you for weighing in!

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