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Julie Janeway (LinkedIn), General Counsel and principal owner, Principled Healthcare Consulting will be speaking about internal and parallel investigations at the 2024 HCCA Compliance Institute. In this podcast she slices off a bit of that expertise.
A thorough investigation is needed, she advises whenever there is an issue that could require arbitration, a court case, administrative hearing, contractual dispute or reputational issues, whether by an employee, contractor or the organization itself. The same is true if there is a policy breach or alleged violation of the code of conduct.
So how best to do it? Have both an investigation plan and a preplan which designates who will be responsible for the investigation depending on what the issue is. For example, a privacy officer would likely play the lead role in a HIPAA breach allegation.
As for the plan itself, it should be thorough. The team executing it should include individuals with a wide range of skills and, she highly recommends it include an experienced investigations attorney.
What should you avoid? Several things, she cites, including retaliation, making the plan as you go along, letting supervisors or managers interview subordinates and not having insurance for when investigations happen.
The rules are largely the same with parallel investigations, which are required pursuant to statues that call for entities notified of an investigation by a governmental agency to conduct their own investigation. These absolutely must be done, or the organization may face sanctions. She highly recommends doing these investigation under attorney-client privilege.
Listen in to learn more about what to do and what not to do in an investigation. Then, don’t miss her session at the 2024 Compliance Institute, March 18-20 in Nashville.