Psst!

The third rung of the ROPE Ladder includes an effective reporting system so that your personnel can alert you to potential problems efficiently and effectively.

While it is best when personnel can communicate problems known firsthand with clear and thorough data, potential problems are often identified through partial or indirect information, including rumors. Like it or not, your compliance team needs to pay attention to rumors, since news of fraud and abuse often surfaces in gossip before it does in authorized reporting channels.

However, all rumors are not created equally. Your compliance team should take three steps to address some basic questions when deciding how to respond to the myriad rumors circulating at every home care company.

1. First, examine the severity and type of issue involved. Assess whether the rumor, if true, could result in extreme penalties, such as exclusion from government programs or stiff sanctions. If so, the matter clearly needs to be examined. It's worse in the government's eyes if your compliance team had knowledge of a potential compliance problem and failed to take action on it. On the other hand, if the potential repercussions are insignificant, your compliance team probably has more relevant issues to address. Reports of an employee placing personal calls from the office, for example, would not merit additional inquiry.

2. Second, examine the source of the rumor. Ask: Does the source have merit? How widely circulated is the rumor? Definitely examine widespread rumors. After all, it's important to dispel falsehoods and disseminate the facts to employees. Conversely, if a rumor is known only to a relatively small group, your compliance team should consider how and why they heard the rumor. Also, if a pattern of rumors centers on a particular department, it's likely time to perform an audit of that department.

   It may be difficult to pinpoint the source of a rumor since people often are reluctant to name names. To zero in on a rumor's credibility, ask an “informant” questions such as:

   • When did you first hear about this issue? How long has this been going on? Follow-up with questions related to specific time and location.

   • Do you know of anyone else who knows about this? Who is in charge of the area the rumor concerns? Who was present during a conversation about the rumor?

   • Is there anything in writing concerning the rumor, such as a memo, form, e-mail, letter or meeting minutes?