A Practical “Whistleblower” System for Public Service Organizations
Recent events have brought forth “whistleblower” systems in the consciousness of public service administration. Notoriety aside, a facility that readily answers employee concerns on compliance to ethical, legal and personnel policies has been recognized to not only boost employee engagement but also mitigate agency risk. Suggestion boxes and managers' “open door” policies suffered from lack of employee participation and concomitant managerial information. Hotlines appeared during the last decade that enabled employees to report or inquire about observed or heard violations of agency ethical, legal and personnel policies.
NAVEX Global in its “2019 Hotline Benchmark Report," cited research finding that increased usage of internal reporting systems correlated with improved operating performance. Also proposed were the benefits of hotline and incident management systems such as greater operating efficiency, fewer material lawsuits, lower litigation costs, fewer external reports to federal and state regulatory authorities on matters relating to OSHA, HIPAA, cybersecurity, or ADA, stronger organizational governance practices and misuse of financial and physical assets. The report implied that hotline usage brings about stronger worker engagement, better regulatory and organizational compliance and continuous improvement of service to the public.
While an effective ethics and compliance hotline is an essential part of an agency’s management process, its cost need not be prohibitive. In the NAVEX Global report mentioned above, organizations in the study currently receive 1.6 hotline reports per 100 employees on the average.
To achieve viability, a hotline must have the following components:
An independent or off-site hotline service that receives and manages reports and inquiries for 24 hours daily, seven days a week. This service must accommodate reports whether these are made by phone or by web. An essential feature of the hotline is a database containing a dictionary of allegations by which to classify allegations.
A hotline coordinator who receives information from the hotline service provider, and coordinates its disposition in accordance with standard procedures. This coordinator must be familiar with the agency, its management, operational processes and policies. This individual has access to designated operational, human resources, legal and security policy expertise. An independent but experienced individual may serve as coordinator instead of an employee. The coordinator must issue monthly management reports to the ethics and compliance committee of the Board of Directors.
Written standard operating procedures containing rules of engagement by which the hotline coordinator interacts with the hotline service and the agency’s policy experts. These procedures guide also the disposition of allegations and the development of management information. Included are guaranties for the anonymity of the reporter and provide severe penalties for any retaliation. In situations where similar public service agencies share a common coordinator and a hotline provider, memorandum of understanding and contracts must be executed.
Annual employee hotline training on making retaliation-free inquiries and reports on violations of agency ethical, legal, personnel and security policies.
The following exemplifies an ethics and compliance hotline experience in an actual public service agency illustrating how an ethics and compliance system functions:
Agency services: Human services.
Hotline reports per 100 employees: 3 per year.
Referral to law enforcement agencies: 3 % of hotline reports.
Main allegations as a percent of reported allegations: dysfunctional employee behavior (42%), health, safety and environmental (13%), personal conflict of interest (11%) and mishandling of HIPAA information (10%).
Hotline coordination resource: 0.25 full-time equivalent employee at the administrator's office.
Hotline report management: an independent organization that offers turn-key hotline and policy services.
This agency seeks to better define retaliatory behaviors and to continually improve awareness of the hotline as an employee's resource.
By Noel Jagolino, management consultant, 2019
Content contributor, Mgmtlaboratory.com
Staff Note: Hotline consultation via email and voicemail is available free of charge to governmental entities and related agencies. Requests for assistance can be made through Contact@mgmtlaboratory.com. We refer value-priced on-site consultation and training to affiliate consultants such as Mr. Noel Jagolino.
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