What is the University’s Compliance Line?
The Compliance Line is an option for making a confidential report using either the internet or a telephone line to help the campus community identify and address compliance concerns about financial, research, HIPAA or Environment, Health and Safety (“EHS”) matters on campus in a positive, constructive environment.
This internet and telephone reporting service is not maintained on the University’s systems and is not maintained by University employees. Reports can be filed anonymously and the reports are held securely and confidentially on the external systems.
EthicsPoint, based in Portland, Oregon, is the commercial service provider for the University’s Compliance Line. This commercial service provider was chosen for the quality and security of its service after careful review of several vendors’ proposals.
University Compliance Line internet access: https://secure.ethicspoint.com/domain/en/report_custom.asp?clientid=13027 (See left hand menu “To Make a Report” or click on “Follow-up on a Report”)
University Compliance Line telephone access: 1-866-294-8688.
Why do we need a tool like this Compliance Line?
It is University policy that all employees have a personal obligation to assist the University in maintaining integrity and ethical behavior in the University’s work. Although direct discussion with one’s supervisor is the preferred mode, in some circumstances a campus employee may feel the need for a more confidential, sometimes anonymous ability to express good faith concerns about noncompliance.
Recently revised federal guidelines for compliance programs include establishment of a channel of communication that permits anonymous reporting of potential regulatory compliance problems and concerns.
Why do we need this Compliance Line – don’t we have other channels of communication about these compliance concerns?
Yes. There are a variety of campus channels of communication for expressing financial, EHS, HIPAA and research compliance concerns and resolving them. Direct communication among the involved persons is generally preferred, but when an employee feels that such a direct conversation is not a constructive option, this is an additional method of registering good faith compliance concerns.
What’s different about this Compliance Line from other “hotlines” like the State Auditor’s hotline?
The University has an obligation for its own ethical performance, and this Compliance Line is structured to help members of the campus community knowledgeable about campus activities to work together to identify and respond to specific campus compliance issues in the areas of Research, Finance, HIPAA and EHS.
Won’t this tool just encourage individuals to gripe or to make wild charges about others?
This professional reporting system provides a clear channel of communication for good faith concerns, and it is also structured to focus the report on specific, defined University compliance problems or concerns in the areas of University financial transactions, HIPAA, research or EHS matters.
It is important to note that this Compliance Line does not cover Human Resources, Student Affairs, Academic Affairs or Public Safety issues.
Is there any monetary reward for these reports?
No. The reason for making a report is a genuine concern for the integrity of the University’s work. Although there have been various newspaper accounts of large monetary payments to whistleblowers (“Qui Tam relators”) who have reported violations of the federal False Claims Act, individuals do not receive money for relating federal False Claims Act violations by state agencies.
Why is this Compliance Line limited to financial compliance, research compliance, HIPAA compliance and Environment, Health and Safety compliance?
The federal compliance program guidelines that prescribe an anonymous reporting tool apply to certain heavily regulated activities within each of these topical areas. The University will evaluate its experience with the Compliance Line over time to determine its potential utility for other topics.
What if an individual is not sure what she or he has observed or heard is a violation of regulations or university policy, but it just does not look right to that person. What should he or she do?
The individual should file a report. The Compliance Line structure will help the individual prepare and file a report so it can be properly understood. We’d rather be alerted to a situation that turned out to be harmless than let violations go unchecked because of uncertainty.
What about reprisal or retaliation for making the report?
University policy and state law prohibit retaliation or reprisal against an individual for reporting in good faith a violation of state or federal law, rule or regulation.
May reports be filed through the Compliance Line using either the internet or the telephone?
Yes. By giving both choices, the Compliance Line helps ensure that campus employees can file a report anonymously and in the manner most comfortable or convenient to them.
Can a person file a report without access to the internet?
If a person does not have access to the internet or prefers to use a telephone, the individual can call the Compliance Line toll-free at 866-294-8688, 24 hours a day, 365 days a year.
Where do these reports go? Who can access them?
Reports through the Compliance Line are entered directly on the EthicsPoint secure server to prevent any possible breach in security. EthicsPoint makes these reports available on the EthicsPoint system only to specific individuals at the University who are charged with evaluating the type of problem and location of the incident, and who understand the importance of maintaining confidentiality. The EthicsPoint system and staff are trained and committed to ensure that no report is shared with implicated parties, their peers, or subordinates.
What happens after a report is filed?
The individual who has filed a concern report through the Compliance Line website or phone number receives a unique user name and chooses a password. Through these, the individual has the ability to return to the Compliance Line for a University response to the concern report after a specified later date. Meanwhile, EthicsPoint notifies the appropriate designated University administrator that there is a report posted to a secure access site on the EthicsPoint system. The University administrator reviews the report and begins the process of determining the facts and any appropriate action.
What if a reporter’s boss or other managers are involved in a problem? Won’t they get the report and start a cover-up?
The Compliance Line report distribution process is designed so that a report is not shared with implicated parties or their subordinates. If a University administrator is implicated, the report is available only to certain other University administrators.
What if an individual remembers something important about the incident after filing the report? Or what if the University has further questions concerning the report?
When an individual files a report at the Compliance Line Web site or via the Compliance Line toll-free number, he or she receives a unique user name and is asked to choose a password. The individual can return to the Compliance Line again either by internet or telephone and access the original report to answer questions posed by a University recipient and add further information that will help resolve open issues. We strongly suggest that individuals who have filed reports return to the site in the time specified to answer any follow-up University questions. The reporter and the University can enter into an “anonymous dialogue” where situations are not only identified but can be resolved.
Are anonymity and confidentiality guaranteed?
We cannot guarantee either anonymity or confidentiality but we have established this Compliance Line to provide maximum potential for both.
It is my understanding that any report sent from a University computer generates a server log that shows every web-site that my PC connects with, and won’t this log identify the Compliance Line report originator?
EthicsPoint itself does not generate or maintain any internal connection logs with IP addresses, so no information linking a PC to EthicsPoint is available through EthicsPoint. However, information about your web access to EthicsPoint can typically also be found both on the computer you use to contact EthicsPoint and also in various network logs used for network performance. If an individual wants to make certain that no University systems include a record of the computer connection to the EthicsPoint website, the individual may want to file a web-based report through a computer that is not on the University network, such as a computer at a public library.
Can a report be filed from home and still remain anonymous?
EthicsPoint’s experience has been that fewer than 12% of reports are generated during business hours. Most people prefer to report from the comfort of their home after hours and on the weekend.
A person can file a Compliance Line report from any computer that can access the internet. This includes home computers. An internet portal never identifies a visitor by screen name and the EthicsPoint system strips away internet addresses so that anonymity is totally maintained. Plus, EthicsPoint is contractually committed not to pursue a reporter’s identity.
Is the toll-free telephone line confidential and anonymous too? It is my understanding that University telephone logs show the phone numbers accessed through University telephones.
The toll free telephone Compliance Line reporting service is also operated by EthicsPoint and is available toll-free at 866-294-8688, 24 hours a day, 365 days a year. The caller will be asked to provide the same information that he or she would provide in an internet-based report and an interviewer will type the responses into the Compliance Line web site. EthicsPoint safeguards reports received through the telephone just as it does those received through the internet.
University telephone system logs do show telephone numbers accessed through University telephones. An individual who wishes to maintain maximum anonymity in using the telephone Compliance Line service should make the toll-free telephone call using a nonUniversity telephone.
Are follow-up reports as secure as the first one?
All Compliance Line correspondences are held in the same strict confidence as the initial report.
What about concern that the information the reporter provides through the Compliance Line will ultimately reveal the reporter’s identity.
The EthicsPoint system is designed to protect the reporter’s anonymity. However, the reporting party needs to ensure that the body of the report does not reveal the reporter’s identity by accident, for example, “From my cube next to Jan Smith…” or “In my 33 years…”. If the reporter is the only individual who could possibly know the reported facts, there may be an unintended deductive disclosure of the reporter’s identity. The University will honor and protect the reporter’s request for confidentiality to the extent possible as it fulfills its obligations in responding to the report.
What if the reporter wants to be identified with the report?
There is a section in the report for the reporter to self-identify.
What if I have other questions about this Compliance Line?
You may call the Office of University Counsel at (919) 962-1219 with any questions about this Compliance Line.