2026 Benchmark Guide: Healthcare Whistleblowing & Survey Insights

1. Reports per 100 Employees

Healthcare operates at a materially higher intensity

One of the clearest distinctions between healthcare and the global benchmark is reporting volume. Healthcare organizations report a median of 3.96 Reports per 100 Employees, compared to 1.65 globally – a reporting density that is 2.4 times higher. 

In practical terms, healthcare compliance teams operate in settings defined by constant patient interaction, complex reimbursement structures, regulatory oversight and workforce intensity. Each of these dynamics increases both the likelihood of reportable events and awareness of compliance channels among employees and others. Higher reporting volume can signal a healthy speak-up culture – but it also indicates sustained investigative demand. 

Importantly, this level of activity establishes a different baseline for program design. Healthcare organizations should not benchmark capacity against global averages alone. Investigative staffing, workflow design and case management systems must be built to support nearly four Reports per 100 Employees on an ongoing basis. 

For leaders, the question is not simply whether reporting volume is high or low. It is whether the organization is resourced and structured to respond consistently, thoroughly and at scale – without sacrificing quality or timeliness.

How to calculate: Find the number that reflects all the reports gathered by all reporting channels, divide that number by the number of employees in the organization and then multiply it by 100. For this metric to accurately compare to the calculation we’ve provided, organizations should not exclude any reports, regardless of Intake Method, Risk Type, Substantiation Rate or Risk Category.

2. Risk Category spotlight

Business Integrity in healthcare

Healthcare organizations report a significantly higher concentration of Business Integrity concerns than the global benchmark. The median percentage of Business Integrity reports in healthcare is 35.2% of total reports, compared to 20.3% globally – a nearly 15-percentage point difference. 

This divergence is not unexpected. Within the NAVEX Risk Categories, Business Integrity includes Fraud, Waste, Abuse, as well as Patient Quality of Care – two risk types especially prominent in healthcare environments. 

Given the sector’s complex reimbursement models, payer scrutiny, government oversight and patient safety mandates, elevated reporting in this category reflects structural exposure rather than anomaly. Billing integrity, documentation accuracy, reimbursement compliance and quality-of-care standards are deeply embedded in daily healthcare operations. 

This concentration signals that financial integrity and billing-related concerns remain central risk drivers. It also underscores that Patient Quality of Care issues are surfacing through compliance channels, reinforcing the alignment between ethics programs and clinical risk management. 

In healthcare, compliance does not operate solely as a workforce conduct function. It sits at the intersection of ethics, financial oversight and clinical accountability. The higher share of Business Integrity reports highlights that healthcare reporting patterns are shaped by core operational and regulatory realities, not simply cultural dynamics.

How to calculate: First, ensure each report is sorted into one of the six Risk Categories or the 24 Risk Types as defined in the Whistleblowing & Incident Management Benchmark Report. Then, divide the number of reports in each of the six categories by the total number of reports. Please note, when we are using the median for each category, the total won’t necessarily add up to 100%. In calculations involving Risk Category or Risk Types frequency, we categorize the reports and find the frequency among all reports without grouping by organization. Frequency values should total 100%, or close to it due to rounding.

3. Healthcare E&C programs report similar maturity to the global average

NAVEX evaluates program maturity using the Ethics & Compliance Initiative (ECI) High-Quality Program framework, which assesses programs across five stages ranging from underdeveloped to optimizing. 

NAVEX uses the ECI High-Quality Program self-assessment for program maturity. The ECI HQP maturity levels are defined as: 

1. Underdeveloped: It is new and/or lacks many high-quality program (HQP) elements 
2. Defining: It has a few high-quality program (HQP) elements, but still lacks many important attributes 
3. Adapting: It contains a number of high-quality program (HQP) elements reflecting some important attributes, but with room to further mature 
4. Managing: It contains many high-quality program (HQP) elements and can be considered effective or good, but not a high-quality program (HQP) that is managed well 
5. Optimizing: It contains the majority of, if not all, high-quality program (HQP) elements

Despite operating in a more highly regulated and operationally exposed environment, healthcare organizations report program maturity levels broadly aligned with global peers. This suggests that while healthcare compliance teams face elevated reporting volume and risk complexity, many organizations are still navigating the same maturation challenges seen across industries.

4. How healthcare organizations measure the effectiveness of their ethics and compliance programs

Healthcare organizations increasingly rely on operational compliance data to understand whether their programs are working. This year, we asked how leaders are measuring the effectiveness of their ethics and compliance program and note several differences when comparing healthcare responses to the global average. 

Healthcare organizations place greater emphasis on operational compliance indicators, including policy reviews, hotline reports and investigation findings. 

Interestingly, the least-used measure for healthcare organizations is regulatory scrutiny, at 36%; this is also the least-used measure for global respondents (34%). The findings suggest healthcare organizations prioritize internally generated compliance intelligence over external scrutiny when evaluating program effectiveness.

5. Which internal challenges are increasing for healthcare?

When comparing the challenges, healthcare organizations report different challenges than their global peers, with expanded responsibilities without additional resources emerging as the top challenge in the past 12 months for healthcare. However, this is a top challenge globally with 38% of respondents reporting this as their top challenge as well, but it appears to be more acutely felt in healthcare organizations. 

Healthcare organizations also appear to be more challenged than their global peers, with manual processes, technology limitations and difficulty coordinating across functions. Across all measured challenge areas, healthcare respondents reported greater pressure than the global benchmark – reinforcing the operational strain on compliance teams across the sector.

6. Healthcare investments in program activities

Healthcare investment priorities reflect a growing focus on visibility, oversight and proactive risk identification. Compared to the global benchmark, healthcare organizations are more likely to prioritize risk assessments (55% vs. 45%) and monitoring and audits (45% vs. 40%). 

Globally, training and awareness remain the leading investment priority at 53%. Healthcare organizations place comparatively less emphasis on training in favor of activities that strengthen operational oversight and risk visibility.

7. Internal audits and risk assessments are most effective in making the investment case

Across industries, many organizations highly rate results from internal audits or risk assessments as being highly effective in making the case for increased investment in compliance programs.  

The next most effective way to make an investment case for both healthcare and global organizations is regulatory changes or anticipated enforcement (49% and 45%, respectively). 

Together, these findings suggest healthcare organizations are most successful in securing compliance investment when requests are tied to measurable operational risk and regulatory exposure.

8. Training is essential in strengthening speak-up culture

Training remains one of the most important tools healthcare organizations use to strengthen speak-up culture. Healthcare and the global cohort both report training employees on the importance of speaking up as the top action taken to strengthen reporting culture in the past 12 months.  

Notably, 62% of healthcare organizations report this as the top choice, compared to 53% for the global cohort – a nine percentage point difference. Healthcare organizations are also slightly more likely to train managers on how to receive and respond to reports (43% vs. 40%), reinforcing the importance of frontline leadership in sustaining reporting culture.