Compliance Investigations: How to Prevent the Response from Making Things Worse
Thursday, April 13, 2017
9:00 am – 10:30 am HST
11:00 am – 12:30 pm AKT
12:00 pm – 1:30 pm PT
1:00 pm – 2:30 pm MT
2:00 pm – 3:30 pm CT
3:00 pm – 4:30 pm ET
Investigations and corrective actions can create more problems than they solve.
There are many ways providers become aware of compliance concerns, including complaints, routine auditing and monitoring, and contact from outside auditors and investigators. Providers aware of a potential compliance concern must investigate and correct any deficiencies. When undertaking an internal investigation, providers must be careful that the investigation does not create evidence that can be used against them later and that corrective efforts do not become or appear to become a way to cover up noncompliance. Investigations and corrective actions can create more problems than they solve. It is important to carefully consider how to handle internal investigations – from documentation to responses – before you begin.
This session will address whether to involve outside counsel and perform the investigation under privilege and how to clearly document findings and actions taken to correct – not hide – problems. In addition, this webinar will cover whether the noncompliance requires a payback and how best to return money to the government to avoid future false claims allegations based upon failure to return inappropriately received reimbursement.
- Internal investigations – when outside counsel is important
- Whether noncompliance is intentional or negligent and what that means for your investigation
- Identify if noncompliance is a matter of enrollment or whether identified noncompliance calls into question the appropriateness of reimbursement received
- Implement your plan of correction – how to document changes to make a clear record of corrections and when they became effective
- Importance of documenting both the investigation and corrections to demonstrate intent
- When to consider self-disclosure
- Key concerns of self-disclosure, versus simply refunding the money through reversing claims or a check
- TAKE-AWAY TOOLKIT
- Sample investigation policy
WHO SHOULD ATTEND?
This informative session is designed for administrators, management executives, owners, and compliance officers.
PLEASE NOTE: Webinar content is subject to copyright and intended for your individual organization’s use only.