To evaluate the performance of its compliance hotline vendor, Peiman Saadat, corporate compliance officer at AdvantageCare Physicians in New York City, uses “secret shoppers” every quarter to report fictional compliance concerns. The litmus test is whether the vendor relays the facts of complaints as Saadat knows they were reported, in their entirety. “I report this to both the board and compliance committee,” Saadat said.

Secret shoppers are one way to improve the operations of the hotline, which generates data that can be used to address the immediate concerns reported by callers and “further analyzed to mitigate existing or potential risks,” Saadat said Oct. 17 at the Compliance & Ethics Institute sponsored by the Society of Corporate Compliance and Ethics in Phoenix, Arizona.^[1]

Hotlines won’t accomplish much, however, if people don’t know about them, said Saadat, whose organization includes 38 medical offices. Compliance departments should be publicizing the hotline as much as possible. Pick a number that’s easy to remember and a slogan, he advised, and consider adding a website for people to report compliance issues. Younger people prefer to go online and not talk on the phone, he noted. “I’m pretty sure it’s going to be the web page taking over soon.” Reinforcing the availability of the hotline is critical and it “shouldn’t always come from you,” Saadat said. “It should come from leaders.”