Collection professionals rely on dialers heavily. It would therefore be extremely hurtful to an agency if the dialer and those in charge of running it did not have a sound compliance strategy. This strategy should include working closely with the vendor of the solution used, agency administrators, and even the clients.

brownlee scott“We are a healthcare collection agency and have put in place several best practices to ensure that dialing operations remain compliant,” said Scott Brownlee, vice president and CCCO of Grimley Financial Corporation. “We work with our clients to ensure they have explicit express consent language on their intake forms that includes “pass through” language to third-party collection intervention. We scrub daily for cell phones and only preview/ manually dial any cell phones that are not marked for express consent. We cross reference the consumers’ zip codes with their telephone area codes and apply the most conservative dialing time constraints to every account.

“We scrub each campaign to eliminate multiple listings of the same telephone number to prevent multiple calls on the same day. We do not execute redials on anything except busy signals and tri-tone signals on the same number within a campaign. We do not use multiple number waterfall strategies (we only dial one number per consumer, meaning we do not load any additional numbers on an account in a campaign). We have eliminated all message broadcasting, including opt-in outbound calls (pending the final outcome of the published FCC changes). We process all do-not-call requests on the same day they are received. We are prepping for “owner verification” of a number given the likelihood of the enactment of the “1 strike ruling” even if the call is a no answer. We only broadcast complete caller ID of numbers that belong to us, either our toll free number or our published local number.”

The process of selecting a dialer is best served by effective communication between the agency and vendor to make sure all legal and preferential requirements are met.

payne bryce“When looking for a compliant predictive dialer vendor, it’s important to recognize if the vendor can properly articulate the compliance concerns your company is facing,” said Bryce Payne, vice president of sales for TCN, Inc. “Do they appear to truly understand the compliance regulations and how these rules evolve on a routine basis? What functionality do they have that addresses those concerns? As a rule of thumb, always be sure to collect references from clients in your similar space before moving forward with a particular vendor.”

Once an initial dialer program is established, maintaining the synergy is a task all its own. The key to this is staffing.

“An agency must also have a dialer manager who is in charge of ensuring campaigns are built and run properly, that the dialer is maintained (current agents, end dispositions, daily updated compliance related database measures, do not call updates, and ensuring downstream result returns are processed properly),” said Brownlee. “Analytically, they must also work with the collection managers to maintain productivity, generate per-agent and per-hour effectiveness statistics, and tracks other key performance indicators to ensure agents are performing at maximum efficiency. The dialer manager must have both complete accountability for the dialer environment and the authority to implement process change to keep the company current with regulatory compliance, client work standards, and internal company policy and procedures. Lastly, the dialer manager needs to have the ability to prepare and present reporting packages that support the suggested strategies they are utilizing or proposing, identifying any positive/negative trends and continually troubleshoot work product for ways to improve performance in a compliant fashion.”