Corporate Compliance

Tip: Gaining consensus for the appropriate level of investigation

Healthcare Auditing Weekly, November 20, 2007

You've heard the allegation, kicked the tires, and your informal inquiry determined that there is a serious possibility that a legal violation occurred. It's important, and often necessary, to involve other stakeholders in deciding what level of investigation should take place.

An initial presentation to stakeholders will begin with an explanation of why the provider may need to engage in an internal investigation.

Next, offer a recommendation for how the internal investigation should be conducted, including such elements as scope, whether to preserve attorney-client privilege and work product protection, and possible steps to be taken at the conclusion of the investigation.

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