Hotline Accessibility Testing - Who is Answering Yours?

Are you using an anonymous hotline service? Do you administer this service in-house? How do you know if the provider, be it contract service or employees, are meeting your expectations?  Are they competent in the necessary language, cultures, and can they assist someone with a disability? Is the most important information accurately conveyed to your responsible parties? Let me share the solution I put in place.

Feel free to contact me if you'd like information or assistance in putting a test program in place.


Introduction and Background

Many organizations maintain phone numbers permitting callers to report inappropriate activities in the workplace anonymously. While these services offer a regulatory compliance solution under Sarbanes-Oxley, they also can facilitate reporting that may otherwise not occur. How these reports are handled once received may have critical legal implication. Possibly of greater import, does the organization know whether their hotline service is truly meeting their needs.

Our organization use a third-party provider but we employed and assisted many individuals with disabilities or for whom English was not their native language. Considering some of these individuals might need assistance making a report via the hotline service, we researched and later implemented an annual testing program.


Solution

At the outset, the terms of service for the third-party provider were reviewed along with several discussions with the account manager. Following this verification of their stated capabilities, consideration was given to the conduct of the test calls. In short, the hotline would be tested for service adequacy, report accuracy, appropriateness of follow-up comments by the provider after review of the test call. The following more specific criteria were applied each call:

• Ability to communicate with the caller regardless of accent, speech impediment, or use of assisted communications for those unable to hear.

• Accurate transcription of the relevant facts the caller provides

• Potential impact, resource consumption, and response delay for inaccuracies

• Proper routing of the call back to the reporting organization

To ensure consistency of the test, a handful of generic narratives were created to assist the test caller with formulating their report. To avoid later confusion about what may or may not have been said each call would be witnessed by a loss prevention team member. This also served to separate the testing employee, or volunteer, from any further necessary involvement. At the completion of the call a short structured report with a brief narrative would be completed by the test caller and loss prevention representative.

Each call received by the hotline provider resulted in an emailed report to our organization. Within the organization this message was then routed to a short distribution list of key individuals. To avoid any confusion or wasted resources, an email would be sent by the testing loss prevention representative to that distribution list. The message would then contain specific information, such as the fictitious name of a person acting inappropriately, so members of the distribution could ignore the test message.

Test program results would be compiled and reported to the Chief Risk Officer, and shared during the annual compliance audit conducted by a third-party accounting firm.


Results

The testing program had some interesting results initially, and periodically afterward. The first test call, ironically, was routed to a peer organization. The cause of this was determined to be an outdated location list, and the street name for the location of the call origination coincided with the street name of a peer organization site. Consequently, the hotline provider altered their practices by sending a location list each quarter for verification. During another subsequent call nearly one year later the call taker had sufficient difficulty with the test caller’s speech impediment as to have incorrectly reported names. The service provider’s performance improved sufficiently that after just a few years the program was scaled back to the three calls per year. The program was extremely well-received by the third-party accounting firm when presented each year.