FAQs:

What is EthicsPoint?

EthicsPoint is a confidential reporting tool hosted by NAVEX to assist Vaya Health members, providers, employees and other stakeholders to report potential Medicaid fraud and other misconduct, all while promoting quality services for members and cultivating a positive work environment for employees.

Why do we need a system like EthicsPoint?

We respect member rights and want to provide a simple way for members and caregivers to report concerns.

We believe that our employees are our most important asset. By creating open channels of communication, we can promote a positive work environment and maximize productivity.

Medicaid managed care organizations such as Vaya are required to have a mechanism for members, providers and employees to report potential fraud, waste and abuse of public healthcare funds as well as potential violations of the False Claims Act.

We manage millions of dollars in taxpayer funds. An effective reporting system will support our efforts to foster a culture of compliance, integrity and ethical decision-making to help safeguard those funds.

What type of situations should I report?

The EthicsPoint system is designed for members (or persons acting at their request) to file complaints and grievances about Vaya Health or the providers in our network. EthicsPoint also allows any member of the public to report concerns about Vaya Health or our contracted providers. Issues can range from potential fraud and False Claims Act violations to quality of care or health and safety issues, as well as concerns about confidentiality, billing and documentation, conflict(s) of interest, customer service, member rights or misuse of public resources. The system is also designed to allow employees to file privacy and security incidents and provider investigation referrals, or any other compliance or human resources concern the employee may have.

Why should I report what I know?

You may have initial knowledge of an activity that may be cause for concern. Your reporting can minimize the potential negative impact on Vaya Health and the members we serve. By working together, we can prevent fraud, waste and abuse of healthcare expenditures and preserve public dollars to help fund additional services and supports for our communities. We can also work together to address urgent health, safety or quality of care issues affecting our members. Offering positive input may help identify issues that can improve Vaya's performance for other members and families. We recognize that there may be circumstances when you are not comfortable sharing your identity when you report concerns. We would rather you report anonymously than keep the information to yourself. We want your feedback to help us continue to improve our organization and the performance of our contracted providers.

I am aware of some individuals involved with unethical or inappropriate conduct, but it doesn't affect me directly. Should I report it?

All unethical or inappropriate conduct, at any level, ultimately hurts the organization and the members we serve. Even if the behavior you observed doesn't impact you directly, we want to know about it so we can address the problem and correct the issue moving forward.

I am not sure if what I observed is a violation of the law or involves unethical conduct, but it just does not feel right to me. What should I do?

File a report. The EthicsPoint system can help you prepare and file your report so it can be properly understood. We would rather you report a situation that turns out to be harmless than let potentially inappropriate behavior go unchecked because you were unsure.

May I report using either the Internet or the telephone?

Yes. With EthicsPoint, you can file a report via either our toll-free hotline (1-866-916-4255) which is hosted by NAVEX and available 24 hours a day, 365 days a year, or via any computer that can access the Internet.

What should I do if the telephone number is not working?

If the toll-free hotline number listed above is not functioning, please make your report online through EthicsPoint. Please indicate in the report that the telephone number did not work.

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

Yes. You will be asked to provide the same information you would provide in an Internet-based report and then the interviewer will type your responses directly into EthicsPoint's secure environment. Hotline-based reports have the same security and confidentiality measures applied to them as Internet-based reports.

Can I still file a report if I don't have access to the Internet at home?

You can file an EthicsPoint report from any computer that can access the Internet. Many public locations, including most public libraries, have Internet computers. If you don't have access or are uncomfortable using a computer, please call our toll-free hotline listed above.

What if I want to be identified with my report?

There is a section in the report where you may identify yourself, if you wish.

Where do these reports go? Who can access them?

Reports are entered directly to a secure server hosted by NAVEX (not by Vaya Health) to prevent any possible breach in security. EthicsPoint makes these reports available on a “need to know” basis only to specific individuals within Vaya Health who are charged with evaluating the report and assigning it for investigation as needed. Each of these individuals, as well as the staff charged with investigating reports, is trained in keeping these reports in the utmost confidence.

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

The EthicsPoint system is designed to protect you. In fact, NAVEX is contractually committed not to pursue or reveal a reporter's identity. A report by telephone or from a work computer, home computer, a neighbor or friend's computer, or any Internet portal will remain secure and anonymous. The EthicsPoint system strips away identifying information, such as an IP address or telephone number, so that anonymity is maintained. To further ensure your anonymity, you - as a reporting party - need to be careful not to reveal any identifying details as part of your report.

What if I remember something important about the incident after I file the report?

When you file a report, either using the Internet or through the 24/7 toll-free hotline, you receive a unique report key and are asked to select a password. With the report key and your password, you can return to the EthicsPoint system again, either by Internet or telephone, and access the original report. At that point, you can add more details.

What if you have questions for me concerning my report?

EthicsPoint provides functionality that enables company representatives to post questions for you, even if you report anonymously. When you receive your report key, you will also be provided with the amount of time we expect for the report to be processed. When that time has passed, we recommend you check to see if any questions have been posted and respond if you can. This helps us determine the best way to resolve reported issues.

Are these follow-ups as secure as the initial report?

All EthicsPoint correspondence is held in the same strict confidence as the initial report.

For Employees

It is my understanding that any report I send from a Vaya Health computer generates a server log that shows every website my PC connects with; if I report from work won't this log identify me as a report originator?

EthicsPoint does not generate or maintain any internal connection logs with IP addresses. No information linking your desktop or laptop to EthicsPoint is available. In fact, NAVEX is contractually committed not to pursue a reporter's identity. However, if you still feel uncomfortable making a report from a Vaya computer, you have the option of using a computer outside of our work environment (such as your personal home computer or one located at an Internet café, the library, at a friend's house, etc.) through the EthicsPoint secure website. Many people choose this option, as our data shows that fewer than 12% of reports are generated during business hours.

If I become aware of a potential compliance or human resources issue within Vaya Health, shouldn't I just report it to my manager and let them deal with it?

Reporting through EthicsPoint helps us identify trends and track the nature and type of reports that are filed. We encourage all employees to discuss concerns with your supervisor, director, department head or member of Executive Leadership if you feel comfortable doing so. However, we know there may also be circumstances when you are not comfortable reporting the issue through the regular chain of command (for example, if your concern is about your supervisor). This is why we partnered with NAVEX for the EthicsPoint system. We would rather you report anonymously (when permitted) than keep the information to yourself.

Does management really want me to report?

We certainly do. In fact, we need you to report. You know what is going on in our organization - both good and bad. We all have the right to work in a positive environment. With that right comes the responsibility of acting in an ethical manner and letting the appropriate people know if someone is not acting appropriately. By working together, we can maintain a safe, ethical, and productive workplace. You may have initial knowledge of an activity that may be cause for concern. Reporting can minimize the potential negative impact on Vaya Health and the members we serve. In the current competitive healthcare marketplace, organizational misconduct can threaten the livelihood of Vaya Health as a whole. Finally, sharing good news and compliments may help identify issues that can improve organizational culture and performance.

Isn't this system just an example of Vaya monitoring me?

The EthicsPoint system is not a tool for monitoring staff. You are encouraged to seek guidance on ethical dilemmas, provide positive suggestions, or communicate a concern. Effective communication is critical in today's workplace and this is a great tool to enhance that communication. We have carefully chosen the best reporting tool to meet our compliance obligations while maintaining a positive reporting environment. A seemingly harmless lapse in ethics can have disastrous effects on an otherwise healthy organization. If you know of any incidents of misconduct or ethical violations, you should consider it your duty to yourself and your coworkers to report.

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

The EthicsPoint system and report distribution protocols are designed so that implicated parties (up to and including ELT members if applicable) are not notified about or granted access to reports in which they have been named. More importantly, Vaya Health follows a strict non-retaliation policy. We never retaliate against individuals who report concerns in good faith.