Conducting Internal Investigations in Health Care Organizations

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Publication Details

  • Pub Code: BCII-EBSMS1
  • Pages: 304
  • ISBN: 978-1-936230-06-8
  • Copyright 2011

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Conducting Internal Investigations in Health Care Organizations

Provides guidance on ways to address conducting an internal investigation from start to finish: from the evaluation of allegations; gathering and documenting evidence; techniques in debriefing complainants, witnesses, and subjects; writing interview and investigative reports; all the way to the resolution of cases. Written by the former HHS Inspector General and nationally renowned expert on compliance and investigations, Richard Kusserow, this resource contains seven sections of guidance and more than 30 adaptable policy and form templates, and includes an accompanying CD.

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A Practical Guide on How to Resolve Allegations of Wrongdoing

Conducting Internal Investigations in Health Care Organizations is a practical “how-to” guide and accompanying CD written by the former HHS Inspector General and nationally renowned expert on compliance and investigations, Richard Kusserow. With seven sections of guidance and more than 30 adaptable policy and form templates, this resource:

  • Addresses conducting an internal investigation from start to finish: the evaluation of allegations; gathering and documenting evidence; techniques in debriefing complainants, witnesses, and subjects; writing interview and investigative reports; and the resolution of cases.
  • Includes tips, planning steps, guidelines, factors to be considered, debriefing questions, and rules to follow at each stage of an investigation. Click here to see a list of the customizable templates
  • Contains dozens of policies, checklists, reports, form letters, and other ‘hands-on’ tools that can be tailored to your organization’s needs.
  • Illustrates and underscores key learning points with more than 80 actual abstracted complaints and cases, with additional cases serving as case studies for more detailed analysis.

The HHS Office of Inspector General stresses the critical role of conducting internal investigations effectively, particularly as they relate to potential violations of regulations and law. You need a resource that can help you perform some of these related tasks that organizations often do not perform effectively:

  1. Organize communication processes to identify potential cases outside the employee hotline;
  2. Properly assess/evaluate complaints and allegations;
  3. Appropriately plan and execute an investigation;
  4. Properly debrief complainants, interview witnesses, or interrogate subjects;
  5. Determine when cases should or should not be done under direction of legal counsel;
  6. Organize and write investigative reports; and
  7. Appropriately respond to government or contractor contacts or interest.

Conducting Internal Investigations in Health Care Organizations is a complete guide for those charged with conducting compliance and other internal investigations, with 17 chapters devoted to what you need to know and do before initiating investigations; the process by which cases are initiated and investigated; post-investigation actions; and detailed case studies applying the principles laid out in the guide. This is a must-have book for every compliance officer who has been or may someday be involved in an internal investigation or inquiry.

Table of Contents

Part I: Before Investigations Begin

  • Chapter 1: Why Conduct an Internal Investigation
  • Chapter 2: The Duty to Report and Protections for Reporting
  • Chapter 3: Evaluating Allegations

Part II: The Internal Investigation

  • Chapter 4: Initiating and Conducting Internal Investigations
  • Chapter 5: Gathering and Managing the Evidence

Part III: Investigation Interviews

  • Chapter 6: General Guidelines for Investigation Interviews
    • Interviewer Conduct
    • Establishing Rapport
    • Taking Notes
    • The Questioning Process
    • Summarizing the Interview
    • Closing the Interview
    • Taking a Statement
  • Chapter 7: Interviewing the Complainant
    • Establishing Rapport with the Complainant
    • Conducting the Interview
    • Determining Complainant Motivation
    • Closing the Complainant Interview
    • Reluctant Complainants
  • Chapter 8: Interviewing Witnesses
    • Preparing for Witness Interviews
    • Interview Preparation Steps
    • Conducting the Witness Interview
    • Assessing Credibility
  • Chapter 9: Interviewing the Subject of the Complaint
    • Interviews and Interrogations
    • Preparing to Interview the Subject
    • Interviewing the Subject
    • Confronting Subject Deception
  • Chapter 10: The Interview Report

Part IV: Post-Investigation Actions

  • Chapter 11: The Investigative Report
  • Chapter 12: Resolution of Investigation Issues

Part V: Investigations by Offices or Departments

  • Chapter 13: Investigations by Human Resources Management
  • Chapter 14: Investigations Directed by the Compliance Officer
  • Chapter 15: Investigations by the HIPAA Privacy/Security Officer
  • Chapter 16: Investigations Directed by Legal Counsel
  • Chapter 17: Investigations Requested by the Chief Financial Officer

Part VI: Compliance-Related Investigation Policy Templates

  • Complaints and Case Resolution
  • Duty to Report Wrongdoing
  • Non-Retaliation for Reporting Wrongdoing
  • Internal Investigations Anonymity/Confidentiality
  • Duty to Protect Confidentiality of Investigative Information
  • Investigator Non-Disclosure Agreement
  • Internal Investigations
  • Organization’s Right to Access Employee E-Mail and Computer
  • Internal Investigations Records Management
  • Human Resources Management Complaints
  • Human Resources Management Exit Interview
  • Unlawful Harassment or Discrimination Investigations
  • Legal Counsel’s Role in Internal Investigations
  • Investigative Response to Government Actions
  • Conflicts of Interest
  • Enforcement and Discipline
  • Internal Investigation Referrals to Regulatory and Enforcement Agencies
  • Investigation of HIPAA Complaints and Violations

Part VII: Investigation Form Templates

  • Complaint Intake Guide
  • Complainant Interview Guide
  • Witness Interview Guide
  • Subject Interview Guide
  • Checklist Reminders for Subject Interviews
  • Checklist for Internal Investigation Reports
  • Principles for Developing a Table of Penalties
  • Disciplinary Investigation
  • Sexual Harassment Complaint Form
  • Unlawful Harassment Findings
  • HIPAA Patient Privacy Complaint Form
  • Letter on Results of Investigation (No Finding)
  • Letter on Results of Investigation (With Findings)

Written By

Conducting Internal Investigations in Health Care Organizations is written by Richard P. Kusserow, Founder/CEO of Strategic Management Systems, Inc. (SMSInc), an industry-leading health care compliance consulting firm in Alexandria, Va. Prior to founding SMSInc in 1992, Mr. Kusserow was the Inspector General of HHS for 11 years, where he was responsible for all investigations, audits and inspections performed on behalf of HHS programs and operations that included Medicare, Medicaid, maternal/child health programs, and a number of social programs for the aged, infirmed and disadvantaged. He is among the top compliance consultants in the nation, providing advisory services to hundreds of compliance officers, attorneys, auditors and personnel officers charged with fact-finding, making internal inquiries, and evaluating, investigating and acting upon allegations of wrongdoing in the workplace. Mr. Kusserow has published dozens of journal articles and is the author of several books, including AIS’s 49 Steps to Implement Sarbanes-Oxley Best Practices.

Written For

  • Compliance Officers
  • Risk Managers
  • Legal Counsel
  • Human Resource Managers
  • Internal Auditors
  • Chief Financial Officers

. . . at hospitals and health systems, health plans, pharma companies, large provider groups and other health care organizations.

AIS Guarantee

Order Conducting Internal Investigations in Health Care Organizations for a 30-day risk-free inspection and test for yourself the value of this highly practical resource. If within 30 days you're not interested in keeping it, just return it to AIS and we will send you a prompt, full refund or credit. Refunds will not be made once the seal on the CD package has been broken. Please review your copy of the print version prior to breaking the seal.

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Conducting Internal Investigations in Health Care Organizations

Place your order through our secure shopping cart

Save $30! (Includes CD with customizable templates)
$245.00
was $275.00

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