Care Delivery (inclusive of Comprehensive Primary Care and CloseKnit) Ethics & Compliance Hotline FAQ
If you see something, say something. Speaking up is the correct thing to do!
About EthicsPoint
What is EthicsPoint?
EthicsPoint is a comprehensive and confidential reporting tool created by NAVEX that helps coordination with the workforce and the community we serve to address fraud, waste, abuse, and other misconduct in the workplace while cultivating a positive work environment and customer experience.
Why is Care Delivery (inclusive of Comprehensive Primary Care and CloseKnit) using the EthicsPoint system for the Ethics & Compliance Hotline?
Providing channels for open communication and trust reinforces a positive environment where individuals can speak up without fear of retaliation. An effective reporting system strengthens our efforts to foster a culture of integrity where we can act with unquestionable ethics.
Reporting – General
Can I report a concern using the website or telephone?
Yes. The Ethics & Compliance Hotline, administered by NAVEX, enables you to file a report online or by phone. You can choose to provide your name or remain anonymous. Please be aware that failure to provide detailed information or witness names could hinder the ability to investigate.
What types of concerns should I report?
You should report potential or known violations of Care Delivery’s Code of Conduct as well as other compliance concerns. If you see behaviors that fall short of Care Delivery’s (inclusive of Comprehensive Primary Care and CloseKnit) mission or values, report them.
Should I report a concern to my leader or Human Resources?
When you become aware of behavior that you believe violates the Code, we expect you to report it. You should bring concerns to your direct leader or another member of management. However, if you are uncomfortable reporting to management, you can report your concern through the Ethics & Compliance Hotline.
Why should I report what I know?
We all have the right to work in a positive environment, and with that right comes the responsibility of acting ethically and speaking up if you have concerns or if someone is not acting appropriately. It is a requirement of the Code to report all suspected violations of the Code, any law or regulation, or Care Delivery (inclusive of Comprehensive Primary Care and CloseKnit) policy.
Does management really want me to report?
Yes. In fact, we need you to report. You may have knowledge of an activity that could cause concern. Your reporting can minimize the potential negative impact on the company, our workforce, and the patients we serve. Also, reporting concerns may help identify issues that can improve Care Delivery’s culture.
Reporting Security & Confidentiality
Where do these reports go? Who can access them?
Concerns are entered directly on the EthicsPoint secure server. NAVEX makes these reports available to the Ethics & Compliance Department who then collaborates with other business areas, as necessary, to evaluate the report based on the type of concern and location of the alleged incident. All assigned investigators have been trained to handle these reports with the utmost confidentiality.
If I use my work computer to log the issue, can it be tracked?
NAVEX does not generate or maintain any internal connection logs with IP addresses, so no information linking your PC to the Ethics & Compliance Hotline is available. If you feel uncomfortable making a report on your work computer, you can use a personal or public computer (such as one located at an internet café or a friend’s house) to report concerns via the Ethics & Compliance Hotline secure website, at https://caredelivery.ethicspoint.com administered by NAVEX. Please do not include Protected Health Information (“PHI”) or Personally Identifiable Information (“PII”) for online reports submitted utilizing personal or public devices.
Can I file a report from home and remain anonymous?
An anonymous report from home, a neighbor’s computer, or any internet portal will remain secure and anonymous. An internet portal never identifies a visitor by screen name, and the EthicsPoint system strips away internet addresses to maintain anonymity in the Ethics & Compliance Hotline. Please do not include Protected Health Information (“PHI”) or Personally Identifiable Information (“PII”) for online reports submitted utilizing personal devices.
I am concerned that the information I provide to the Ethics & Compliance Hotline will reveal my identity. How can you assure me that will not happen when I submit an anonymous report?
The Ethics & Compliance Hotline allows you to remain anonymous and any reports made are not traced. We work to maintain anonymity and confidentiality to the greatest extent possible. However, if a matter requires the involvement of law enforcement authorities, information may be shared as required by law. In addition, sometimes it is impossible to investigate suspected misconduct without identifying the person who reported it.
To help retain your anonymity as a reporting party, you must ensure that the information you provide does not unintentionally reveal your identity. For example, “From my workstation next to Jan Smith…” or “In my 33 years…”. Everyone is reminded that Care Delivery will not tolerate illegal retaliation against any employee or contingent worker who in good faith reports any suspected or observed misconduct, non-compliance, or other legal or ethical concern, or who cooperates with an investigation.
Is the telephone hotline confidential and anonymous?
Yes. You will be asked to provide the same information as the online report, and you can also opt to provide your name or remain anonymous. An interviewer will type your responses into the Ethics & Compliance Hotline system. These reports have the same security and confidentiality measures applied during delivery.
Can I choose to be identified with my report?
Yes, the report has a section where you can identify yourself.
Tips & Best Practices
I suspect some individuals are acting unethically, but it doesn't affect me. Why should I report it?
Care Delivery (inclusive of Comprehensive Primary Care and CloseKnit) is committed to upholding the highest ethical standards. Unethical conduct at any level ultimately hurts the company and all employees, including you. If you know or suspect incidents of misconduct or ethical violations, consider it your duty to yourself and your coworkers to report the concern.
I don’t know if what I saw or heard violates company policy or involves unethical conduct, but it does not feel right. What should I do?
File a report to the Ethics & Compliance Hotline. The NAVEX call center can help you prepare and file your report so it can be properly understood. We'd rather you report a concern that turns out to be harmless than let possible unethical behavior go unchecked.
What if my direct leader or other management is involved in a violation? Won’t they receive notification about the report and start a cover-up?
The Ethics & Compliance Hotline and report distribution process ensures that implicated parties are not notified or granted access to reports where they have been named.
What if I remember something important about a concern after I file the report? Or what if the company has additional questions about my report?
When you file a report through the Ethics & Compliance Hotline, you receive a unique, randomized number called a “report key” and are asked to choose a password. You can return to the Ethics & Compliance Hotline via website or phone using your report key and password to access the original report to provide more detail or answer questions. We strongly suggest you follow up in a timely manner to answer any additional questions that the company submitted. You and the company now have entered an “anonymous dialogue,” where situations are not only identified but can also be resolved, no matter how complex.
Are follow-ups on reports as secure as the first one?
Yes. All correspondence is held in the same strict confidence as the initial report.
What if I lose my report key or forget the password I created?
To ensure security and confidentiality, you will need to file a new report if you lose your report key or password. In the new report, mention that it is related to a report or question previously submitted.
Can I file a report if I don’t have access to the Internet?
If you don’t have access to or are uncomfortable using a computer, call the toll-free Ethics & Compliance Hotline at which is available 24 hours a day, 365 days a year.