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After an Allegation: Conducting an Effective, Efficient Internal Investigation


The July issue of HCCA’s Compliance Today features Deloitte’s Financial Advisory Service’s Rob Cepielik (Partner), Mike Little (Senior Manager) and Greg Garrison, (Senior Associate). The article, After an allegation: Conducting an effective, efficient internal investigation, discusses the anatomy of an investigation and cites leading practices that may benefit health care organizations in their investigative efforts.

Among the responsibilities of a health care entity’s compliance officer are to ensure that the organization operates in an ethical fashion and complies with all regulatory obligations. Many laws and regulations, such as Sarbanes Oxley, the Federal Sentencing guidelines, the Securities and Exchange Commission guidelines, require that management establish a mechanism to receive confidential and/or anonymous reports from concerned employees and other stakeholders and to protect those “whistleblowers” from retaliation.

When information about an alleged impropriety comes to the attention of a health care provider’s and/or payer’s compliance officer (or department), it is important that the organization take appropriate and timely steps to analyze and investigate the situation, especially because it later may be required to demonstrate what actions it took in response to a complaint.

The attached article reviews leading practice in:

  • Assessing an allegation
  • Composing the investigative team
  • Conducting the investigation
  • Concluding the investigation
  • Reporting

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