To stay on top of compliance and employee problems, health care organizations need to have a solid set of policies and procedures to respond to any allegations of mischief within the organization. The Office of Inspector General at the Department of Health and Human Services in its compliance guidance to segments of the health care industry lists the essential elements of a comprehensive compliance program, and four of these elements involve action based on some degree of inquiry and investigation.
The four elements are:
(1) The maintenance of a process, such as a hotline, to receive complaints, and the adoption of procedures to protect the anonymity of complainants and to protect whistleblowers from retaliation;
(2) The development of a system to respond to allegations of improper/ illegal activities and the enforcement of appropriate disciplinary action against employees who have violated internal compliance policies, applicable statutes, regulations or federal health care program requirements;
(3) The use of audits and/or other evaluation techniques to monitor compliance and assist in the reduction of identified problem areas; and
(4) The investigation and remediation of identified systemic problems and the development of policies addressing the nonemployment or retention of sanctioned individuals.
According to Richard P. Kusserow, former inspector general of HHS, organizations first and foremost must respond to employee complaints; without a prompt response, employees will not see the importance of reporting concerns because it will appear the organization is not committed to compliance. At minimum, this response requires an internal inquiry into the alleged circumstances. But if the inquiry is not done properly, the problem can morph into something much more serious.
To conduct internal inquiries or investigations, health care organizations need to train employees, usually in the compliance or human resources offices, in the fundamentals of an investigation, including planning the scope of the investigation, gathering information and evidence, conducting interviews and reporting findings. Kusserow, in his book Conducting Internal Investigations in Health Care Organizations, emphasizes that no matter how small an organization is or how small a problem may seem, each problem that comes to light needs some degree of effective investigation to determine its authenticity and to resolve it.
http://aishealth.com/blog/compliance/investigate-investigate-investigate
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