FAQ
The U-M Compliance Hotline is a new method for employees to raise concerns about questionable financial, regulatory, or patient safety behavior or practices. Reports can be made anonymously if the employee chooses.
If your question is not answered here, please contact compliancehotline@umich.edu
Q. What it the scope of the new Hotline? The scope of the Compliance Hotline is limited to financial, regulatory and patient concerns.
Q. Why is the University implementing this new Hotline? As a public institution, the University must be a responsible steward of financial resources and the public trust. The Hotline provides a universal reporting mechanism that takes advantage of the best practices in financial controls represented by the Sarbanes–Oxley Act. It is important that we create an environment in which individuals can identify instances of fiscal fraud and other serious regulatory or patient safety concerns.
Q. Does the Hotline replace existing reporting mechanisms? The University currently maintains several reporting mechanisms across campus as required by various state and federal laws and regulations.
At this time, the Hotline will not replace any existing reporting mechanisms, in either the Health System or elsewhere on campus, but rather will serve as an additional option for employees if current reporting mechanisms are unknown by or unacceptable to the employee. In many instances there are more specific places to call. For example, the Animal Concern Hotline is appropriate for issues relating to animals used in research. In addition, use of other resolution channels such as talking to one’s supervisor is strongly encouraged.
The one exception is that the UM Compliance hotline will replace the current Health System Compliance and Ethics Helpline number ((888) 296-2481). Requests for Ethics Consults will be directed to call paging at 734.936.4000 and ask for the Pediatric or Adult Ethics Committee member on call.
Q. How does an employee file a report? An employee can either call the toll-free number at 1-866-990-0111, or submit an online report via their Web site.
Q. How will the Hotline be managed? An external company with experience in managing hotlines for universities will be managing the intake of calls and triaging case reports to the University.
The vendor has no responsibility for managing any resulting research or inquiry from a report, nor does it make recommendations on the outcome. Instead, it routes information back to the University employee case manager. The case manager is the person who would normally handle confidential evaluation, investigation, and follow-up of each case according to the established University protocol in their unit. For example, the UMHS Office of Clinical Affairs will be notified of any patient safety concerns.
Q. What protocol will the company use for investigating Hotline reports? Reports are assigned to case managers by incident topic. We have paired appropriate department contacts for each incident type (for example, reports about patient safety concerns will go to the UMHS Office of Clinical Affairs.) However, each case manager knows to triage the case elsewhere if there is a more appropriate party based on the individual report and normal University procedures for follow up. Case mangers are experienced managers in departments that typically handle these types of issues. Investigations of the case may differ depending on how much information is provided by the caller, however, all case managers are familiar with the process for investigating reports.
Q. Can calls to the Hotline be anonymous? Callers may choose to remain anonymous with the understanding that in some instances anonymity may hinder a thorough investigation of the facts. A caller can describe the issue to interview specialist without identifying his or her name or contact information. At the end of the call, the hotline representative will supply the caller with a confirmation number and ask the caller to call back in 14 days. Using the confirmation number, the caller can check the status of his/her report. The call-back feature also allows U-M officials to ask questions of the caller even if he/she has requested anonymity.
Q. Callers are allowed to remain anonymous, but how will the anonymity of an accused person be protected? A very limited number of managers have been selected in each department to receive reports relevant to their units. They are the staff who would normally investigate such reports regardless of the method through which the report was received, and they are accustom to researching such reports confidentially. This situation will be handled no differently from the current processes used to research claims that are reported to unit leadership. Although the anonymity of the accused may not be protected in every instance, all reports via the hotline are considered as allegations only, and require proper investigations until any factual statement can be made.
Q: How will the callers to the Hotline be protected if they choose to identify themselves?
The University of Michigan will follow existing regulations regarding Protection of Whistleblowers. For information, please visit the Michigan Whistleblower Protection Act, or The Health Facility Whistleblower Protection Act Web sites.
Q. Why did the University contract with a third party vendor? The vendor offers important services that would be impractical or cost prohibitive for the University to provide. The company provides trained interview specialists; the option of caller anonymity, 24 hours a day 7 days a week availability; multi-lingual staff; aggregate reporting of trends and usage of the line.
Over forty other institutions of higher education using this system include University of California system, Arizona State, DePaul University, University of Chicago, Michigan State University and the University of Texas System as well as about 1000 other clients.
Most of our peer institutions have implemented this type of program in order to ensure compliance and to strengthen financial controls.
Q. What will happen to the data collected by the vendor about calls? The UMHS Compliance Officer and the Executive Director of University Audits will periodically review cases to ensure that are handled appropriately. In addition, they will receive monthly trend reports from the vendor, and will determine areas that may need further analysis. Trend reports may be shared with UM Executive Officers. Trend reports for financial issues will be shared with the University’s Board of Regents periodically as well.
Q. What current hotlines or reporting mechanisms does the U-M already operate? There are a number of existing reporting mechanisms in place, and some are shown below. Currently, the Compliance Hotline is not intended to replace any of them, but rather provide an additional central channel for receiving concerns about financial, regulatory or patient safety issues when the normal administrative procedures are not known or not feasible for the employee.
Q. Is the Hotline intended for the reporting of concerns of an academic nature?
The Hotline is intended for the reporting of compliance issues related to finance, regulatory, and patient safety. Issues related to academic/teaching concerns are outside the scope of the Hotline. If you have concerns of an academic nature, please contact the Office of the Provost.
Q. Is the Hotline appropriate for emergencies? The Hotline is not intended for emergency use. If you are in need of emergency assistance or believe a crime is in progress, you should call 911.
Q. Is the Hotline intended for student use? The Hotline is not intended for student use. Students wishing to report a compliance issue may call the Division of Student Affairs at: 764-5132.
The Compliance Hotline is not for reporting criminal or medical emergencies. For emergency assistance, please call 911.
|
