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:

Organize communication processes to identify potential cases outside the employee hotline;

Properly assess/evaluate complaints and allegations;

Appropriately plan and execute an investigation;

Properly debrief complainants, interview witnesses, or interrogate subjects;

Determine when cases should or should not be done under direction of legal counsel;

Organize and write investigative reports; and

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.

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

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