About EthicsPoint

What is EthicsPoint?

EthicsPoint is a comprehensive and confidential reporting tool created by NAVEX that enables Mass General Brigham Health Plan employees, providers, members, brokers and vendors to report any suspected violations of, or raise questions or concerns relating to non-compliance, fraud, waste, abuse and/or other misconduct.

Why do we need a system like EthicsPoint?

EthicsPoint is another communication channel that Mass General Brigham Health Plan’s internal and external constituents (employees, vendors, members, brokers, providers, and any other business partner) may use to report issues of unethical or noncompliant behavior. EthicsPoint provides confidential and anonymous reporting when normal communication with supervisors and others are thought to be a problem and is available 24/7 year-round. By creating open channels of communication, Mass General Brigham Health Plan creates and supports a positive work environment and maximizes productivity.

An effective reporting system augments our other efforts to foster a culture of integrity and ethical decision-making.

Reporting – General

May I report using either the Internet or the telephone?

Yes. EthicsPoint enables you to file a confidential, anonymous report via either the telephone or the Internet.

What types of situations should I report?

The EthicsPoint platform allows internal and external individuals to report any potential or actual violation of our stated Code of Conduct, state and federal laws, rules, or regulations, concerns of fraud, waste, and abuse (FWA) or any other concern of unethical behavior you may have.

If I see a violation, shouldn't I just report it to my manager, security, or human resources and let them deal with it?

When you observe some behavior that you believe violates our code of conduct, we expect you to report it. Ideally, you should bring any concerns forward to your direct manager, or other member of our management team. We recognize, however, that there may be circumstances when you are not comfortable reporting the issue in this manner. It is for such circumstances that we have partnered with EthicsPoint. We would rather you report anonymously than keep the information to yourself.

Why should I report what I know? What’s in it for me?

We all have the right to work in a positive environment and with that right comes the responsibility of acting in an ethical manner. Therefore, it is everyone’s responsibility to report acts or potential acts of noncompliance, fraud, waste and abuse, or unethical behavior. By working together, we can maintain a healthy and productive environment.

Where do these reports go? Who can access them?

Reports are entered directly on the EthicsPoint secure server. EthicsPoint makes these reports available only to specific individuals within the Mass General Brigham Health Plan’s Legal, Regulatory, and Compliance Department, who are charged with evaluating the report, based on the type of violation and location of the incident. Each of these report recipients has had training in keeping these reports in the utmost confidence.

Isn’t this system just an example of someone watching over me?

No. EthicsPoint is a positive aspect of our overall philosophy that allows us to ensure a safe, secure, and ethical work environment. You are encouraged to seek guidance on ethical dilemmas, provide positive suggestions, or communicate a concern. Effective communication is critical in today’s work environment, and this is a great tool to enhance that communication.

Reporting Security & Confidentiality

It is my understanding that any report I send from a company computer generates a server log that shows every website that my PC connects with. Won’t this log identify me as the report originator?

EthicsPoint does not generate or maintain any internal connection logs with IP addresses, so no information linking your PC to EthicsPoint is available.

If you feel uncomfortable making a report on your work PC, you have the option of using a PC outside your work environment (such as one located at an Internet café or at a friend’s house) through the EthicsPoint secure website.

Can I file a report from home and still remain anonymous?

A report from home, a neighbor’s computer, or any Internet portal will remain secure and anonymous, should you choose to report anonymously. An Internet portal never identifies a visitor by screen name and the EthicsPoint system strips away Internet addresses so that anonymity is totally maintained.

I am concerned that the information I provide EthicsPoint will ultimately reveal my identity. How can you assure me that will not happen?

The EthicsPoint system protects your anonymity. However, if you wish to remain anonymous, you - as a reporting party - need to ensure that the body of the report does not reveal your identity by accident. For example, “From my cube next to Jan Smith…” or “In my 33 years…”.

Is the telephone toll-free hotline confidential and anonymous too?

Yes. You will be asked to provide the same information that you would provide in an Internet-based report and an interviewer will type your responses into the EthicsPoint secure website. These reports have the same security and confidentiality measures applied to them during delivery.

What if I want to be identified with my report?

There is a section in the report to identify yourself if you wish.

Tips & Best Practices

I am aware of some individuals acting unethically, but it doesn't affect me. Why should I bother reporting it?

Mass General Brigham Health Plan promotes ethical behavior. All unethical conduct, at any level, ultimately hurts the company, business partners, and all employees, including you. If you know of any incidents of misconduct or ethical violations, consider it your duty to yourself and your coworkers to report it.

I am not sure if what I have observed or heard is a violation of company policy, or involves unethical conduct, but it just does not look right to me. What should I do?

File a report. EthicsPoint can help you prepare and file your report so it can be properly understood. We'd rather you report a situation that turns out to be harmless than let possible unethical behavior go unchecked.

What if my boss or other managers are involved in a violation? Won’t they get the report and start a cover-up?

The EthicsPoint system and report distribution ensure that implicated parties are not notified or granted access to reports in which they have been named. Mass General Brigham Health Plan has zero tolerance for retaliation or retribution against individuals who in good faith report suspected noncompliance, fraud waste or abuse, or any other concerns of unethical behavior.

What if I remember something important about the incident after I file the report? Or what if the company has further questions for me concerning my report?

When you file a report at the EthicsPoint Web site or through the EthicsPoint Call Center, you receive a unique, randomized number called a “Report Key” and are asked to choose a password. You can return to the EthicsPoint system again either by Internet or telephone and access the original report to add more detail or answer follow-up questions posed by a Mass General Brigham Health Plan representative. We strongly suggest that you return to the site at the time specified to answer follow-up questions. Your anonymity is maintained as you communicate through EthicsPoint as Mass General Brigham Health Plan works to investigate and resolve the reported issue.

Are these follow-ups on reports as secure as the first one?

All EthicsPoint correspondences are held in the same strict confidence and anonymity as the initial report.

What if I lose my Report Key or forget the Password I created?

To ensure that security and confidentiality is maintained, if you lose your report key or password, you will need to file a new report. Mention in the new report that it is related to a report or question you previously submitted.

Can I still file a report if I don’t have access to the Internet?

You can file an EthicsPoint report from any computer that can access the Internet. You can file from home. Many public locations, including the public library, have Internet computers. If you don’t have access to or are uncomfortable using a computer, you can call the Mass General Brigham Health Plan EthicsPoint toll-free hotline at 1-844-556-2925, which is available 24 hours a day, 365 days a year.