No [PROVIDER] employee is permitted to engage in retaliation, retribution or any form of harassment against another employee for reporting compliance-related concerns. Any retribution, retaliation or harassment by [PROVIDER] employee will be met with disciplinary action. [PROVIDER] employees cannot exempt themselves from the consequences of wrongdoing by self-reporting; although self-reporting may be taken into account in determining the appropriate course of action.
To protect the rights of the employee, providers may wish to include the following suggested elements as part of their corporate compliance policy:
- [PROVIDER] employee should report actual or potential wrongdoing, misconduct, or violations of the compliance program to their supervisor, Compliance Officer, or Compliance Hotline immediately;
- [PROVIDER] supervisors should maintain an open-door policy and take aggressive measures to assure [PROVIDER] employee that there is no subsequent retaliation, retribution, or harassment for reporting a problem;
- If [PROVIDER] employee has a concern, it should be addressed in order of the following individuals:
- Immediate Supervisor;
- Manager/Director; or
- Administrator/Vice President.
- If [PROVIDER] employee is uncomfortable reporting the issue in the aforementioned manner, the [PROVIDER] employee should report directly to the [COMPLIANCE HOTLINE, ANONYMOUS DROP BOX, POST OFFICE BOX, ETC.]; and
- Confidentiality regarding [PROVIDER] employee concerns and problems are maintained at all times, insofar as legal and practical, informing only those personnel who have a need to know.