Chief Compliance and Ethics Officers Healthcare

When issues are referred to legal

  • 1.  When issues are referred to legal

    Posted 12-07-2018 10:29 AM
    I would like to develop a policy for when matters are referred to legal. Currently we do not have a defined escalation process. Does anyone have a policy they can share? It sounds informal but basically legal is involved for very sensitive issues or incidents that could potentially result in investigations, lawsuits, etc. and/or when I  can't find the answer. I should also mention we do not have an attorney on staff. We seek outside counsel in the event we need it.

    Savannah Knuettel CHC
    Compliance Coordinator
    Galen Medical Group

    The views expressed herein are my own and do not represent those of my employer or clients. They are not meant to constitute legal advice or create an attorney-client relationship.
    2019 HCCA Compliance Institute

  • 2.  RE: When issues are referred to legal

    Posted 12-07-2018 11:32 AM
    I would be interested to know this as well.

    Taylor Lynch
    Compliance Manager

    2019 HCCA Compliance Institute

  • 3.  RE: When issues are referred to legal

    Posted 12-09-2018 10:40 AM

    We are in the process of drafting a standard work process flow in compliance investigations.  We are at a minimum going to request legal guidance whenever there might be a potential implication of the False Claims Act, the Anti-Kickback Statute, Fraud/Waste/Abuse laws and/or other laws.



    Jim Bowman, CHC

    Regional Compliance Manager


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  • 4.  RE: When issues are referred to legal

    Posted 12-10-2018 11:18 AM

    I assisted in writing this policy: Reporting Compliance & Ethics Concerns ("Whistleblower Policy") - University Policies - Confluence
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    Reporting Compliance & Ethics Concerns ("Whistleblower Policy") - University Policies - Confluence
    Global Compliance logs each and every report. Whether you use the Integrity Hotline Phone number or website the Rowan University-Integrity Hotline allows you to report issues and concerns you may have (regarding but not limited to), unethical behavior, inappropriate conduct, bullying, harassment, and any other violation to Rowan University policies.
    View this on Rowan >

    Go to attachment 3 for the investigation process.
    Patrick Guilfoyle BA, RN, BSN, CFE, CHPC

    Patrick Guilfoyle CHPC

    2019 HCCA Compliance Institute