The U-M Compliance Hotline is a method for employees to raise concerns about questionable financial, regulatory, NCAA, substance abuse or patient safety behavior or practices. Reports can be made anonymously if the employee chooses.
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How and what to report
- What it the scope of the Hotline, and what kinds of concerns should be reported?
- Why does the university have this Hotline?
- Does the Hotline replace other U-M reporting mechanisms?
- What current hotlines or reporting mechanisms does U-M already operate?
- How can I file a report through the Hotline?
- Is the Hotline intended for the reporting of concerns of an academic nature?
- Is the Hotline appropriate for emergencies?
- Can calls to the Hotline be anonymous?
- Callers are allowed to remain anonymous, but how will the anonymity of an accused person be protected?
- How will the callers to the Hotline be protected if they choose to identify themselves?
Management of the Hotline
- How is the Hotline managed?
- Why did the university contract with a third party vendor?
- Where can I learn more about the third party vendor?
- What will happen to the data collected by the vendor about calls?
Other compliance information
What it the scope of the Hotline, and what kinds of concerns should be reported?
The scope of the Compliance Hotline is limited to financial, regulatory, NCAA and patient concerns. It is not intended to handle academic or teaching concerns–those issues should be directed to the Office of the Provost.
Examples of the kinds of compliance concerns you might raise include:
- A particular transaction may be inappropriate given what you know about federal or other regulations or university policy.
- Conduct that you believe may violate the law, university policies or otherwise place the university at risk.
- Problems that you have raised with appropriate people, but which have not been corrected.
Why does the university have this Hotline?
U-M is committed to providing an environment where individuals feel comfortable discussing compliance problems, no matter how big or small—and where people can safely and confidentially come forward to identify instances of fraud or other serious concerns. As a public institution, the university must be a responsible steward of financial resources and the public trust.
Does the Hotline replace other U-M reporting mechanisms?
The university maintains several reporting mechanisms across campus as required by various state and federal laws and regulations. In addition, issues can always be reported through conventional management lines (such as by reporting to your supervisor, or to their supervisor).
The Hotline does not replace any existing reporting mechanisms, in either the Health System or elsewhere on campus, but rather serves as an additional option for reporting a concern if you are unsure how to report something, or feel uncomfortable using U-M's other reporting mechanisms, or wish to remain anonymous. In many instances there are more specific places to call. For example, the Animal Concern Hotline is appropriate for issues relating to animals used in research. In addition, use of other resolution channels such as talking to one's supervisor is strongly encouraged.
What current hotlines or reporting mechanisms does U-M already operate?
There are a number of existing reporting mechanisms in place, including specialized reporting mechanisms for specific compliance areas, and conventional management reporting lines. The Compliance Hotline is not intended to replace any of these, but rather to provide an alternative mechanism for reporting financial, regulatory, NCAA, substance abuse or patient safety issues. You can read more about the different ways you can report a concern under other ways to make a report.
How can I file a report through the Hotline?
You can either call the toll-free number at 1 (866) 990-0111, or submit an online report
via this website.
Is the Hotline intended for the reporting of concerns of an academic nature?
Issues related to academic or teaching concerns are outside the scope of the Hotline. If you have concerns of an academic nature, please contact the Office of the Provost. The Hotline is a method for employees to raise concerns about questionable financial, regulatory, NCAA, substance abuse or patient safety behavior or practices.
Is the Hotline appropriate for emergencies?
No. The Hotline is not intended for emergency use. If you are in need of emergency assistance or believe a crime is in progress, you should call 911.
How is the Hotline managed?
An external company with experience in managing hotlines for universities manages the intake of calls and triaging of case reports to U-M. This vendor, however, has no responsibility for managing any resulting research or inquiry from a report, nor does it make recommendations on the outcome. Instead, it routes information back to a select number (six) of case managers in University Audits and UMHS Compliance. A case manager then coordinates a confidential evaluation, investigation, and follow-up of each case according to established university protocols. For example, the UMHS Office of Clinical Affairs will be notified of any patient safety concerns.
Can calls to the Hotline be anonymous?
Yes. Sometimes it can take courage to report a concern. U-M is committed to safeguarding the confidentiality of individuals who submit good faith reports or inquiries, and through the Hotline, callers may remain anonymous if they wish. However, you should keep in mind that certain types of reports may be difficult for the university to pursue if you choose to remain anonymous. A caller can describe the issue to the interview specialist without identifying his or her name or contact information. At the end of the call, the Hotline representative will supply the caller with a confirmation number and ask the caller to call back in 14 days. Using the confirmation number, the caller can check the status of their report. The call-back feature also allows U-M officials to ask questions of callers, even if they requested anonymity.
Callers are allowed to remain anonymous, but how will the anonymity of an accused person be protected?
A very limited number (six) case managers in University Audits and UMHS Compliance receive reports from the vendor. A case manager then coordinates a confidential evaluation, investigation, and follow-up of each case according to established university protocols. For example, the UMHS Office of Clinical Affairs will be notified of any patient safety concerns. Although the anonymity of the accused may not be able to be protected in every instance, all reports submitted to the Hotline are treated as allegations only, and are fully investigated before any further action is taken.
How will the callers to the Hotline be protected if they choose to identify themselves?
U-M is committed to safeguarding the confidentiality of individuals who submit good faith reports or inquiries. The university will follow existing regulations to protect whistleblowers. For more information, see the Michigan Whistleblower Protection Act or the Health Facility Whistleblowers Protection Act websites.
Why did the university contract with a third party vendor?
The vendor offers important services that would be impractical or cost prohibitive for the university to provide. The company provides:
- independent, trained interview specialists
- the option of caller anonymity
- accessibility 24 hours a day 7 days a week
- multi-lingual staff
Most of our peer institutions have implemented this type of program, and most use a third party vendor to receive reports.
Where can I learn more about the third party vendor?
The university is working with a company called The Network, an industry leader in providing anonymous compliance hotline services to a variety of organizations, including universities, health care companies, government agencies, among many others. You can learn more at The Network's website.
What will happen to the data collected by the vendor about calls?
The U-M Health System Compliance Officer and the Executive Director of University Audits will periodically review cases to ensure that are handled appropriately. In addition, they will receive monthly trend reports from the vendor, and will determine areas that may need further analysis. Trend reports may be shared with U-M Executive Officers. Trend reports for financial issues will also periodically be shared with U-M's Board of Regents.
What is the difference between the Compliance Resource Center and Compliance Hotline?
The Compliance Hotline is a mechanism for reporting concerns, especially when other channels for reporting don’t work or the person reporting the concern wishes to remain anonymous. The Compliance Resource Center is a place for finding information or people to talk to about U-M’s legal compliance obligations: a web-based road map that summarizes all of the major compliance activity going on at U-M, and a consolidated directory of compliance experts.