Corporate Compliance

How to identify the scope of an internal investigation

Healthcare Auditing Weekly, October 22, 2003

The scope of your internal investigation will depend on the reason you are performing it. Certain facts will mandate that you cast a broad net. Other situations may call for an internal investigation that is limited in terms of your interviews and research.

To determine the scope of an internal investigation, consider the issues that the investigation raises. Develop a list with internal counsel of various issues that would trigger an internal investigation. Include the following potential problems on that list:

Broad scope
1. Violation of health care statutes and regulations, such as the following:

·  Submissions of fraudulent billing

·  False claims

·  Upcoding

·  Kickbacks and overpayments

2. Issues involving patient care, including allegations of abuse or neglect, may also require a broad investigation because of the potential damage to the company.

These investigations tend to be broader in scope due to the potential for government involvement.

Narrow scope
Consider performing a limited investigation for internal problems that do not involve third parties, such as embezzlement or theft of the company's property. These can often be dealt with through a very limited and focused investigation.

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