Jeannine LeCompte, Publishing and Research Coordinator
Internal investigations most often occur after an issue is detected through internal compliance checks, staff notifications, or advisories from third parties. This differentiates them from “tips” or complaints provided by anybody through a “hotline” or similar advisory system—but does not make them any less important.
Once an issue has been identified in this manner, it should be thoroughly investigated with the same vigor and thoroughness that an “outside” complaint would be handled. The investigation should, like a conventional investigation, focus primarily on finding out the facts of the matter.
Obviously, the severity or otherwise of the reported issue determines the first course of action. For example, if it is determined that a problem in the logistical supply chain might at some stage lead to a problem, then there is clearly no immediate threat to life. If, however, it is determined that the problem—no matter what it is—could have an impact upon resident or staff safety, then immediate action is required.
An incident/accident report is the first step in reviewing the circumstances of the event. No matter the nature of the incident, the first priority must always be resident and staff safety. Then notify the administrator, attending physician, family, and others in accordance with the facility’s policy. If the event falls under abuse regulations, then begin an abuse investigation in addition to following the incident report review procedures.
If the situation implies no immediate threat to life—or after all such threats have been neutralized—then the next step should be the securing of all evidence. This means preserving all physical evidence, and the capture in writing (or in any other durable format), of all the circumstances which led to the issue arising or being noticed.
The evidence gathering process should identify all persons involved, determine the true cause of the issue through the root cause analysis process, and also indicate responsibility. For this purpose, a list of potential witnesses and evidentiary documentation should be compiled.
Witnesses should be interviewed as soon as possible, and all required documentation must be captured and copied. The investigation procedure must also ensure that there is a process for reviewing all the evidence.
The investigation should be logical, and it is important to understand that it is not necessary to investigate every event to the same depth. The severity of the incident will be the determining factor in this regard.
In the case of possible instances of fraud, waste, or abuse, it is important to have a clear understanding of the official definitions of those offenses. Only then will the investigator be able to correctly determine the appropriate level of response.
