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Corporate Compliance I. How to conduct an investigation. It should include the following elements: a. Reviewing the initial complaint: What are the items you should look for in a compliant to determine validity? b. Notifying the appropriate upper management of the complaint unless they are implicated in the complaint: What are the steps to take to determine who is involved? c. Obtaining additional information as necessary and developing a plan for the investigation: What other items are important to the investigation? d. Conducting interviews with staff, residents and/or management: Delineate the types of questions to ask in the interview. e. Determining if the allegations are substantiated or unsubstantiated: Identify criteria to determine if substantiated or unsubstantiated. II. How to develop a correction action plan. The plan may suggest: 2. A recommendation for a subsequent audit or follow-up to the complaint and determination of when this is necessary. 2. A recommendation to refund any overpayments to federal government, insurance company or individual payer and when that may be the best course of action.
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