Do you have an environment that encourages staff to report regulatory violations?  Are you confident that your staff will notify you of improper or illegal activity they are aware of in your facility?  How do you encourage staff to participate in risk reduction?

The days of turning a blind eye or hoping an issue will go away are over.  Administrators need to uncover improper or illegal activity as early as possible to minimize damage.  It’s better to know about a problem in advance than find out about it from an outside inspector, an auditor, or worse – a lawsuit.  The longer it is allowed to continue, the more damage there can be to your facility.  Additionally, your facility is open to outside scrutiny and possible public damage.  In most cases, facilities have an opportunity to resolve issues internally before they reach governmental or legal status. 

Here are a few areas to look at that can encourage your staff to assist in uncovering improper activity:

1. Staff must BELIEVE that they can provide information about a perceived violation and that their identity will be kept confidential.  This includes efforts to protect their identity during the investigation and sensitivity to the fact that information provided could reveal the accuser if not handled properly.  Having a policy in place that says that all information will be kept confidential is just step one.  What procedures do you have in place to ensure confidentiality?

2. Staff must BELIEVE that they can report violations without fear of recrimination or harm to their reputation or career.  Along with confidentiality, this is the greatest barrier that must be overcome to have a staff that is willing to expose wrong-doing.  

3. Internal investigators and auditors must acknowledge personal conflicts of interest.  Friendships, business relationships and family relations should be considered and investigators may need to remove themselves if there is even a perceived relationship that could impact the fairness of an investigation.  This can be especially difficult in a smaller facility where everyone knows everyone.  Outside assistance may be required to maintain fairness.

4. Staff must SEE that reports are taken seriously, investigated, and action is taken when wrong-doing is uncovered.  However, you don’t want to expose anyone by releasing specific information.  One way to handle this could be with an annual scorecard – There were 75 reports of improper activity, 75 reports were investigated, 35 were dismissed, 12 were handled with a discussion with the accused that led to a behavior change, 23 accused were provided with additional training and 5 of the accused were dismissed for improper behavior.  Another way to handle this is to provide individuals who report violations with inquiry numbers and a website where they can check the status of an inquiry.  Many 3^rd party hotline services provide this benefit.

5. Remind staff that they can just as easily get into trouble for knowing and not saying anything as they can for saying something.  They will be held responsible for activities they knew about but did not report.  It is the duty of every staff member to report improper activity.

6. Listen to your staff member before they go to a higher level to be heard.  Don’t wait for the state Medical Board or other association to investigate a report.  It is imperative that your facility launches its own investigation when a staff member reports a violation.

Checking your position around each of these items can help develop a safer and more transparent work environment which can reduce risk and improve patient care. 

If you do uncover wrong-doing, the government encourages voluntary disclosure and self reporting.  

In March, HCCS will be presenting a free webinar on voluntary disclosure and self reporting.  Click here for more information