Q: Why do I need an anonymous hotline?
A: Not only is it a good business practice to have an anonymous compliance hotline, the law requires it. For example, 42 CFR § 483.85(c)(6) states,
"The facility takes reasonable steps to achieve compliance with the program's standards, policies, and procedures. Such steps include, but are not limited to, utilizing monitoring and auditing systems reasonably designed to detect criminal, civil, and administrative violations under the Act by any of the operating organization's staff, individuals providing services under a contractual arrangement, or volunteers, having in place and publicizing a reporting system whereby any of these individuals could report violations by others anonymously within the operating organization without fear of retribution, and having a process for ensuring the integrity of any reported data."
Q: What could happen if I don't have an anonymous hotline?
A: As part of the Requirements of Participation (RoP) published October 2016, nursing centers must have a Compliance and Ethics Program that meets certain requirements, which includes the use of an anonymous hotline. Starting November 28, 2019, CMS and state survey agencies will be authorized to issue survey deficiencies under federal Ftag F895 to facilities that do not have an effective Compliance Program.
Q: What will our poster look like?
Q: How many posters will we get?
A: We will send you 4 custom made posters, which is sufficient for a medium sized facility. If you are a larger facility, we can send an additional 2 at nominal cost.