With the dramatic increase in “whistleblowers” encouraged by law and government agencies it is critical that healthcare entities have a strong process in place for conducting internal compliance investigations. Issues that necessitate an investigation may range from fraud, theft, and misconduct but also include complaints of harassment, retaliation, misuse and loss of patient information, and safety and code violations.
How the organization responds to these complaints can spell the difference between an effective program that reduces risk and an ineffective one that increases compliance vulnerability and liability.
- Determining who should conduct internal investigations
- Assessing allegations
- Planning the investigation
- Gathering evidence
- Interviewing the complainant, witnesses, and the subject of the complaint
- Completing the investigation and determining final action
- Managing the investigation from start to close-out, including the case file, documents, and reports
Richard Kusserow, CEO of Strategic Management Services, LLC, former HHS Inspector General and Supervisory FBI Special Agent. Link to Bio
Emil Moschella, JD, Senior Consultant at Strategic Management Services, LLC, has over 40 years of experience in the fields of corporate compliance, criminal investigations, and law enforcement. Link to Bio