Tip: Conducting a limited investigation
Compliance Monitor, November 4, 2009
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Internal investigations will not always lead to a million dollar settlement conducted in an attorney-client procedure. Sometimes, a more limited investigation of a problem is appropriate for your facility. Remember that any employee complaint, based on credible allegations, deserves an investigation. Even investigations that do not identify a problem improve your ability to demonstrate that your compliance function is effective. If a non-compliance issue requires a milder approach to the investigation, follow these rules:
- Along with a limited review, conduct a probe audit to learn more about alleged issues
- Address any overpayments revealed, if applicable
- Consider implementing new policies and procedures and conduct further training
- Review your organization’s potential obligations under the Sarbanes-Oxley Act to report problems involving publicly funded companies
- Document your efforts to bring the provider into compliance
This week’s tip was adapted from the Internal Investigations Handbook. For more information about the book or to order your copy, visit the HCMarketplace.
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