Blog Post

Developing Internal Investigation Program Capabilities

Richard P. Kusserow | May 2013

Strategic Management believes that the best interest of our clients is having them as self-sufficient in operating an internal investigations program, reserving the employing of professional investigators to only those circumstances where it is absolutely necessary. This is a far more cost effective approach to addressing investigative problems.

Our Capabilities

We provide a full range of capabilities to develop and manage an internal investigations program that is done on site and in person. Most engagements are short term of less than a week that includes:

  1. Conducting an initial gap analysis in terms of organization, staffing, training, and policies.
    • Interviews of key management on their goals for the program.
    • Meetings with Compliance, Human Resources Management (HRM), HIPAA, Safety, Risk Management Officers.
    • Develop an organization and development plan and checklist for operation of the program.
    • Reviewing recent allegations and complaints and how they were handled.
  2. Developing the infrastructure, including:
    • Investigation Policy.
    • Job descriptions for those who may conduct an investigation.
    • Protocols among various departments with investigative duties (e.g. HRM, Safety, HIPAA Privacy/Security, etc.).
    • Protocols for working with Legal Counsel (internal and external).
    • Non-retaliation Policy template.
    • Anonymity/Confidentiality Policy Procedures.
    • Case management system, controls, and policies.
    • Setting up case tracking system.
  3. Extensive training on conducting an internal investigation program:
    • Predicating cases.
    • Managing cases.
    • Investigating allegations/complaints.
    • Working under direction of legal counsel.
    • Conducting Interviews.
    • Identifying deception and reading body language.
    • Interview report writing.
    • Gathering physical evidence.
    • Developing Case Reports.
    • Process for resolving case findings.
  4. Assist with identifying best practices to avoid misconduct.
  5. Providing a 300 page book written by the Strategic Management CEO on conducting internal investigations that can be used as an ongoing resource.

Strategic Management also will be available to assist on any complicated investigation that may occur, as well as be available to provide expertise based upon the knowledge, skills, and insights gained through conducting numerous investigations, relating to:

  • High-risk assessments
  • Fraud and abuse education
  • Ethics and compliance awareness and education
  • Background investigations and screening
  • Mechanisms for reporting and investigating fraud
  • Board oversight
  • Audit of Email Systems

Strategic Management has a related organization, “Hotline Resource Center” that provides anonymous reporting by employees. This relationship provides clients with an additional internal investigation program resource for implementing and maintaining tip lines, creating a corporate culture that inspires ethical behavior and repels fraud as well as a comprehensive fraud prevention and detection program.

About the Author

Richard P. Kusserow established Strategic Management Services, LLC, after retiring from being the DHHS Inspector General, and has assisted over 3,000 health care organizations and entities in developing, implementing and assessing compliance programs.

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