Corporate Compliance

Tip: Following up an investigative violation

Compliance Monitor, February 24, 2010

An internal investigation will help you and your organization identify potential liabilities or violations. During the process, you must use effective, corrective action when following up with a violation. Try to avoid documenting a legal violation without pursuing it with corrective action first. It is important to document the steps your organization takes in response to the findings and conclusions of your investigation. Good corrective action will:
  • Resolve the underlying issue.
  • Ask whether the problem is solved or will it happen again.
  • Ask whether the ship will right from a practical perspective.
  • Remedy past harm to the greatest extent possible.
  • Indentify overpayments and document the method used to return funds.
  • Identify individual responsibility and include appropriate response to discipline.
  • Indentify opportunities for improving systems to prevent future problems.
  • Resolve blame of an individual failure. If someone failed in their responsibility, the system permitted the failure.
  • Include reliable monitoring and auditing techniques to affirmatively determine whether the action was effective.
  • Ensure that you will have data about the issue going forward.
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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