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Benchmark Guide: Healthcare Whistleblowing & Incident Management

Key differences between healthcare and global benchmarks

Executive summary

Author: Jeffrey Miller, JD, Director-in-Charge, Granite GRC*

The impact of whistleblowing in the workplace

Throughout the decades, whistleblowers have made a tremendous impact on improving the ethics and compliance of their companies and societies. This includes high-profile whistleblowers like Edward Snowden, the former National Security Agency contractor who leaked classified information about the U.S. government’s mass surveillance program, which has had a profound impact on privacy and surveillance laws. Lesser-known whistleblowers, like Mark Whitacre, the president of the Bioproducts Division of Archer Daniel Midland, exposed illegal price fixing of food additives by his company and was involved in embezzlement. These individuals exposed wrongdoing and drove significant changes in their respective industries and public policy. Their actions not only changed the course of events but also inspired future generations to take up the whistleblower mantle. 

Whistleblowing is increasingly recognized and protected. As a result, its impact has grown astronomically. From the establishment of the United States False Claims Act, passed into law in 1863, to the 2003 140-nation United Nations Convention Against Corruption, and its progeny around the world, support for whistleblowers has become common among the vast majority of countries around the world.  

2025 whistleblowing statistics

As the 2025 NAVEX hotline data shows, companies with internal whistleblower mechanisms received 1.65 Reports per 100 Employees. For companies with 1,000 employees, that means about 17 reports per year; for 10,000 employees, a median of 165 reports per year. Following internal investigations, almost half of these reports (44%) were substantiated. These whistleblowers are critical to protecting the integrity of companies and industries across communities and cultures. 

Differences in incident and case management for healthcare

Nowhere is the positive effect of whistleblowers more evident than in healthcare.

According to NAVEX benchmark data for 2025, healthcare providers and healthcare-related companies received significantly more whistleblower reports than companies outside of healthcare – 3.96 Reports per 100 Employees. For companies with 1,000 employees, that means nearly 40 reports per year; for 10,000 employees, nearly 400 reports per year.

Compared to most other industries, healthcare is highly regulated and focused on protecting one of our most vulnerable populations – those individuals who are sick or dying. More requirements may lead to more violations of requirements, and concern about vulnerable people may result in higher sensitivity to individual injury.  

As a result, many may not be surprised that healthcare providers and companies incur more hotline reporting. Interestingly, the NAVEX benchmark data also shows that healthcare whistleblowers are more likely to identify themselves than to opt for anonymous reporting: 59% of healthcare whistleblowers name themselves in their reports, compared to 45% across all industries. When healthcare whistleblowers report inappropriate or unsafe care, untoward personal and financial relationships, fraudulent billing, waste, abuse, privacy violations, or other ethical concerns, they help ensure accountability, uphold regulatory compliance, and safeguard patient welfare.  

Effective healthcare case management in practice

To be most effective, it is essential that compliance, privacy and risk management professionals across healthcare understand the scope, dynamics and implications of whistleblower incentives, requirements, protections and activities.

From the whistleblower protections found in the U.S. False Claims Act, to the other whistleblower protections found in the Health Insurance Portability and Accountability Act (HIPAA), the Affordable Care Act (ACA), the Sarbanes-Oxley Act (SOX), the Occupational Safety and Health Administration and Department of Labor protections (OSHA), and the National Defense Authorization Act (NDAA), these professionals are assigned the duty and the opportunity to safeguard their companies and employees through appropriate and productive interactions with whistleblowers.  

Not only can these positive interactions enhance compliance and ethics within companies and the industry, but they can also protect companies from damaging legal actions, such as prosecutions and lawsuits and the related fines, judgments, other penalties and reputational harms.  

Throughout the decades, whistleblowers have had a tremendous positive impact on improving the ethics and compliance of their companies and societies. Compliance, privacy, and risk management professionals have both the duty and the opportunity to work with these whistleblowers to safeguard their companies and employees through appropriate, productive interactions.

*Jeffrey Miller is Director-in-Charge of Granite GRC, a NAVEX strategic partner that works with clients around the world on mitigating risk, ensuring compliance and optimizing operations in a continuously evolving legal and regulatory landscape. Granite GRC can be reached through your NAVEX account executive or at Granite GRC Consulting.

01. At-a-glance comparison

Healthcare vs. global reporting

Healthcare organizations operate in a markedly different reporting environment than the global benchmark – and the data makes that clear. 

With 3.96 Reports per 100 Employees, healthcare reporting volume is more than double the global median of 1.65, signaling a sector with elevated operational complexity and regulatory exposure. At the same time, healthcare employees are less likely to report anonymously (41% vs. 55% globally), suggesting either greater confidence in speak-up protections or a more structured reporting culture within clinical and administrative environments. 

Healthcare programs also demonstrate strong investigative outcomes. Overall Substantiation Rates in healthcare organizations reach 50%, compared to 44% globally, with named reports substantiated at 58% and anonymous reports at 39% – both exceeding global medians. This combination of higher volume and higher substantiation indicates that healthcare organizations are not simply generating more reports, but surfacing credible concerns at scale. 

Risk Type reporting also differs. Business Integrity issues account for 35.2% of healthcare reports, compared to 20.3% globally, reflecting the sector’s heightened exposure to Fraud, Waste, Abuse and Patient Quality of Care reports. 

Importantly, healthcare organizations resolve cases faster, with a 21-day median closure time, versus 28 days globally – a notable achievement given the reporting intensity. 

Taken together, the data portrays a sector that is highly active, operationally exposed and investigation-intensive – but also disciplined and responsive.

02. Reports per 100 Employees

Median reporting value

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.

A medical professional wearing a green surgical gown, cap, and face mask stands in a dimly lit room. They are looking to the side, with medical equipment partially visible in the background.

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 employee awareness of compliance channels. 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.

03. Anonymous Reporting

Median reporting value

How to calculate: To calculate the percentage of anonymous reports, divide the number of reports submitted by an anonymous reporter by the total number of anonymous and named reports received. To calculate the percentage of named reports, divide the number of reports submitted by a named reporter by the total number of anonymous and named reports received.

A healthcare professional wearing blue scrubs, a colorful surgical cap, and a stethoscope around the neck stands against a white background. They hold a tablet and wear an ID badge on a lanyard.

Healthcare employees are more likely to self-identify

Healthcare organizations report a lower rate of Anonymous Reporting than the global benchmark – 41% in healthcare compared to 55% globally. This 14-percentage point gap represents a meaningful structural difference in how employees engage with reporting channels. 

Lower anonymity typically reflects stronger confidence in non-retaliation protections and a greater willingness to attach one’s name to a concern. In healthcare environments, where teams are often closely connected and hierarchies are clearly defined, reporting behavior may also be more normalized within established supervisory structures. There may be a cultural emphasis on accountability and transparency, particularly in settings tied to patient safety and regulatory compliance. 

However, lower anonymity should not automatically be interpreted as stronger trust. It is a positive signal only when supported by visible, consistently enforced anti-retaliation safeguards. If employees believe concerns will be handled fairly and confidentially, named reporting can strengthen investigations and improve resolution quality. If that confidence erodes, reporting volume and candor may follow. 

For healthcare leaders, the takeaway is clear – anonymity rates should be evaluated alongside retaliation prevention efforts, leadership behavior and employee perception data. The goal is not to drive anonymity up or down, but to ensure employees feel safe choosing either path.

04. Follow-Up to Anonymous Reports

Median reporting value

How to calculate: Find the number of reports where the anonymous reporter returned to the system at least once. Divide this number by the total number of anonymous reports received. Please note, we do not count multiple follow-ups to the same report per metric. If an anonymous reporter returned to the system two times, that report would be counted once.

Two smiling healthcare workers in scrubs and name badges walk together under a covered walkway. One holds a clipboard, the other a coffee cup. Both appear cheerful and supportive, with one arm around the others shoulders.

Follow-up gap in healthcare

Healthcare organizations report a rate of 25% Follow-Up to Anonymous Reports, compared to 31% globally – a six-percentage point gap that carries operational implications. 

Anonymous follow-up plays a critical role in investigation quality. When reporters re-engage through secure portals, investigators can clarify facts, request documentation and narrow the scope of inquiry. This additional context often strengthens case clarity and can improve substantiation outcomes. 

In high-volume environments like healthcare, where reporting density reaches 3.77 Reports per 100 Employees, limited anonymous engagement can constrain investigative depth and efficiency. Cases become more difficult to resolve, require broader fact-finding, or result in inconclusive outcomes because of incomplete information. 

The variance does not necessarily signal distrust. In healthcare settings, time pressures, rotating shifts, and clinical demands may limit an employee’s ability to access a reporting portal. However, improving anonymous engagement represents a meaningful opportunity. 

Healthcare organizations can consider simplifying anonymous case re-entry, reinforcing confidentiality messaging at intake and optimizing reporting platforms for mobile and shift-based workforces. Even incremental gains in follow-up rates can enhance investigation quality in an already high-intensity reporting environment.

05. Substantiation Rate

Median reporting value

How to calculate: For overall Substantiation Rate: divide the number of allegation reports that were closed as substantiated or partially substantiated by the total number of allegation reports that were closed as substantiated/ partially substantiated or unsubstantiated as defined. We also note that there is a category described as “insufficient information” which is excluded from these calculations.

A doctor in blue scrubs discusses information on a tablet with a woman sitting in a clinic. A young child stands beside her, holding her hand. They are in a bright, modern medical office with a window and examination table.

Healthcare reports show stronger signal quality

Healthcare organizations not only report at higher volume, they also substantiate concerns at higher rates than the global benchmark. Overall Substantiation Rate reaches 50% in healthcare, compared to 44% globally

The variance becomes even more pronounced when examining reporter type. Named reports are substantiated at a rate of 58% in healthcare, versus 50% globally. Anonymous reports are substantiated at 39% in healthcare, compared to 34% globally

Across all categories – overall, Named and Anonymous – healthcare exceeds global substantiation benchmarks. 

This suggests that reports within healthcare environments are more likely to reveal confirmed misconduct or policy violations. The particularly strong Substantiation Rate for named reports indicates that when employees attach their identity to a concern, it often reflects a well-founded issue. At the same time, Anonymous Reports in healthcare still outperform global benchmarks, reinforcing the overall signal quality of the reporting channel. 

Taken together, this combination of higher reporting volume and higher substantiation reflects a compliance function managing both intensity and credibility. Healthcare compliance teams are not simply processing more reports – they are investigating a higher proportion of cases that result in confirmed findings. This points to disciplined investigative processes, structured case management and a workforce that understands what constitutes reportable misconduct.

06. Risk Category spotlight

Median reporting value

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 Hotline & 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.

A woman in a white lab coat stands between shelves filled with organized file folders in what appears to be a medical records archive room.

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.

07. Case Closure Time

Median reporting value

How to calculate: Calculate the number of days between the date a report is received and the date it is closed for each report. Then, calculate your mean Case Closure Time by dividing the total sum of all Case Closure Times by the total number of cases closed. For median values, find the middle point of the data – this is an important metric to explore, as it helps reduce the impact of outliers that can skew overall metrics.

A group of medical professionals walking and smiling. Two women in white coats are in the foreground, one with curly hair and the other with short hair. In the background, a woman and a man in blue scrubs are partially visible.

Faster resolution in healthcare vs. global

Healthcare organizations report a median Case Closure Time of 21 days, compared to 28 days globally – resolving cases seven days faster than the global benchmark. 

This difference is notable on its own, but even more significant when considered alongside healthcare’s broader reporting profile. With 3.96 Reports per 100 Employees, a 50% overall Substantiation Rate and 35.2% of reports concentrated in Business Integrity, healthcare compliance teams are managing both high volume and high-impact cases. Maintaining a 21-day median closure time in this context reflects meaningful operational discipline. 

Faster resolution can signal that investigative workflows are structured and responsive. It may also indicate operational urgency embedded in case management processes, particularly in environments where financial integrity and patient quality concerns require timely intervention. Centralized intake systems, defined escalation pathways and mature case management practices often contribute to this level of efficiency. 

At the same time, speed should be evaluated alongside consistency and quality. Timely closure strengthens employee trust and reduces organizational risk – provided investigations remain thorough and corrective actions are clearly documented. 

In healthcare, where reporting intensity and substantiation rates both exceed global norms, resolving cases efficiently while maintaining rigor underscores the maturity of the compliance function and its alignment with enterprise risk priorities.

08. Strategic considerations for healthcare leaders

Turning insight into action: What this means for healthcare leaders

The variances between healthcare and global benchmarks are not simply statistical differences. They point to structural realities that require intentional program design. 

First, align investigative capacity with sustained reporting intensity. 
With 3.96 Reports per 100 Employees on average, compared to 1.65 globally, healthcare compliance teams operate in a higher-demand environment. Staffing models, triage workflows and analytics capabilities should be calibrated to this baseline – not to global averages. 

Second, strengthen anonymous follow-up engagement. 
Healthcare trails the global benchmark in follow-ups to anonymous reports (25% vs. 31%). Improving re-engagement through simplified case access and reinforced confidentiality messaging can materially enhance investigation quality. 

Third, monitor retaliation confidence. 
Lower anonymity rates (41% vs. 55% globally) may reflect trust – but only if anti-retaliation safeguards are visible and consistently enforced. Employee perception data should align with reporting patterns. 

Fourth, reinforce Business Integrity controls. 
With 35.2% of healthcare reports tied to Business Integrity compared to 20.3% globally, organizations must ensure controls address Fraud, Waste, Abuse and Patient Quality of Care risks. 

Finally, preserve investigation quality while maintaining efficiency. 
Resolving cases in 21 days versus 28 globally is a strength. The priority is sustaining speed without sacrificing rigor, documentation or corrective action discipline.

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