A compliance Hotline Log is a record of calls made to a compliance hotline, including the nature of any investigations and their results. Call logs are crucial as they provide a comprehensive record of compliance communication and enable keeping track of what happens with the information. This helps improve the effectiveness of the compliance program and management operations. A compliance officer should maintain the log to track and manage hotline complaints, allegations, and concerns from receipt through final resolution. Among the objectives of compliance hotlines is to gather critical information to bring about changes in compliance program needs. There should be a Hotline Call Log that provides several key facts, such as date and time of receipt; nature of the call; tracking on who was resolving the issue; the resolution result, etc. All this information should be included in your Hotline Management Policies and Procedures. By tracking and storing information about phone calls, organizations can also gain valuable insights into employee conditions, management practices, system operations, etc. It can be a tool with valuable compliance information. However, the Log should not be confused with the case file. It should have only an outline of the information and focus on how it is being managed. Details of the reports and how they are addressed should be in the case file. As such, the logging data should include:

• The date the matter was received
• The nature of the problem reported (e.g., theft, violation of policies, etc.)
• File or case number
• Identify the official responsible for completing any actions related to the matter
• The date the case was closed
• Caller name (if disclosed), residence, and contact numbers
• Description of the problem being reported
• The program or operation involved
• Any monetary implications
• Final disposition.

Most calls will not likely be matters that directly involve compliance. They will most likely fall under the Human Resources area of responsibility. Other calls may involve clinical, procurement, or legal issues. Often, a caller may make multiple allegations, issues, or complaints in a single report. As such, it may require multi-track resolution. This underscores the importance of having protocol policies between the Compliance Office, especially with Human Resources and Legal Counsel, defining respective roles and responsibilities. Compliance officers should have procedures to manage and follow up on these types of calls. In addition, the tracking log can help identify trending issues warranting attention.

For more information regarding hotlines, contact Shelby Cole at the Compliance Resource Center (CRC) ([email protected]).