INTERNAL INVESTIGATIONS
Generally, associates from Compliance & Risk Dynamics (CRD) work under the direction of in-house or outside counsel, with the benefit of retaining attorney-client privilege.
Internal Inquiries and Investigations
In many circumstances, situations arise that requre further detail and inquiry. These situations can range from human resource issues, complaints of care, over-billing or over-utilization, to potential fraud.
Staff associates for CRD are trained to handle such matters in a planned, forthright, and professional manner. Working for the client, CRD staff spends time understanding the issue for inquiry and work with healthcare staff to develop an appropriate approach to understand what happened, identify systems vulnerabilities, determine who was responsible and identify solutions.
In many circumstances, situations arise that may require further inquiry. These matters need to be handled delicately and discretely. In certain circumstances, the solution requires further training and education instead of a more onerous solution.
Compliance Officers and Counsel can lose their objectivity and become engaged in the minutiae if they become actively involved in an internal investigation. CRD can allow oversight of the process without having the Compliance Officer or Counsel involved in interviews, report preparation of debrieifings. The Compliance Officer can maintain objectivity with their report to executives, the board or the Compliance Committee.
In many cases, CRD personnel pair with detached staff (removed from conflict or direct knowledge or involvement) from the healthcare facility to form interview teams in the conduct of the inquiry.
Services
The field of compliance is very broad and an ever changing landscape. Components of a solid compliance program might consist of:
· Staff education
· Risk Assessment
· Training
· Investigations
Deficit Reduction Act of 2005
Back in February of this year, President Bush signed the Deficit Reduction Act of 2005 (the “Act”)… and, what it means to you and your corporate compliance program (or lack thereof) could be huge!!