AUDIOCONFERENCE ON TAPE OR CD
Sponsored by The Compliance Officer’s Handbook
presented on October 16, 2006
When a healthcare organization identifies a potential compliance problem that could lead to civil or criminal liability, it is necessary to conduct an internal investigation. Compliance officers must know which steps to take when confronted with these issues, and how to anticipate and deal with the many practical considerations that arise in connection with an investigation.
In this current atmosphere of heightened regulatory enforcement environment, it’s critical that compliance officers learn how to conduct efficient and competent internal investigations, and demonstrate their commitment to investigating concerns and seeing the matter through to appropriate resolution. We can help.
Listen to HCPro's audioconference, Internal Investigations:Innovative strategies to identify and address noncompliance, where you’ll learn how to conduct a practical investigation that will be credible to both internal and government stakeholders. Our speakers will share tips to help you gain internal support and credibility, which are critical components of a thorough and successful investigation.
This audioconference will cover the following topics:
- Government focus on internal investigations-through the United States Sentencing Guidelines and OIG Compliance Program Guidance.
- How to establish and preserve attorney-client privilege and work-product protection.
- When and how to disclose the results of internal investigations to the government.
LEARNING OBJECTIVES
By the end of this audioconference, you should be able to
- decide when a compliance concern warrants an internal investigation
- determine which roles the compliance officer, legal counsel, and others should play during investigations
- execute an investigation work plan to guide your way through the process
- follow strategies to stay on the right side of the law throughout the investigation
- know what to do if an investigator shows up at your organization’s front door asking for information
- determine when and how to self-report findings
- learn best practices for conducting an investigation, from what to tell employees to how to maintain attorney-client privilege
AGENDA
- What is an internal investigation?
- How to determine the scope of an investigation
- Who should conduct an internal investigation?
- Compliance Officer
- Outside counsel
- Independent auditors and experts
- Attorney vs. non-attorney directed investigations – does it really matter?
- The cost issue
- Attorney-client privilege and the work product protection
- How to preserve privileges and protections
- How to conduct your investigation
- Empower the compliance officer to coordinate the investigation internally
- Develop and maintain a list of any individuals involved with, or who have knowledge of, the investigation
- Develop a strategy for document reviews and witness interviews
- What to tell employees
- Who to interview
- Other steps
- What to do if the government is investigating your organization
- What to do when an agent shows up at your front door
- Which actions can give rise to an obstruction-of-justice charge
- Investigation follow up
- When a routine refund is not routine
- Advantages and disadvantages of self-reporting
- Information to include in a self-report
- Q&A
Participants should have an intermediate knowledge of the elements included in an effective compliance program and OIG guidance relevant to their industry segment.
MEET OUR SPEAKERS
Frank Sheeder, Esq., is a partner in the health care section of the Dallas office of Jones Day. His practice entails representation of a variety of healthcare providers in administrative, civil, and criminal matters, such as discrete internal investigations, voluntary disclosures, whistleblower actions, defense of criminal allegations, responding to government requests for information, and resolution of OIG initiative cases.
Al Josephs is the senior director policies and training for Tenet's Ethics and Compliance program in Dallas, TX, and is responsible for ethics and compliance training provided throughout Tenet's system of hospitals. He also manages and coordinates the development of Tenet's policies and procedures along with related training.
WHO SHOULD LISTEN?
Compliance officers and staff, department directors and managers, and senior management in hospitals that seek Medicare and/or Medicaid reimbursement
Purchase a tape or CD of the program and listen when you can. It's a perfect training tool for new staff or as a refresher for veteran staff.
Save money when you purchase multiple copies! Ask your customer service representative about money-saving
discounts and bulk orders. Call toll free 800-650-6787 or e-mail
customerservice@hcpro.com.
