Common Challenges to Internal Compliance Investigations and How to Deal With Them

Credits in

General Icons 1.00 General

Practice Areas:

Corporate & Securities

Icon About This Course

Attorneys are often the second line of defense but are the first people called when allegations of internal misconduct arise. This course offers suggestions on how to judiciously leverage limited internal resources and identify allegations that should be investigated by an external third party. With increased scrutiny of corporate compliance programs, now is the time to implement and continuously refine internal investigation approaches to define the organization’s culture of compliance.

Organizations often uncover allegations of internal misconduct, such as violations of the law or the organization’s internal rules, policies, or procedures, from any number of sources within and outside of their four walls. Unfortunately, organizations often lack seasoned investigators and/or a well-documented internal investigation approach to reliably respond to the alleged misconduct. This often results in ineffective and inefficient investigations without meaningful lessons learned to prevent future misconduct. How an organization navigates alleged misconduct can affect its reputation and standing as much as, if not more than, the alleged misconduct itself. Now more than ever before, the increased federal and state law enforcement interest in corporate compliance across a large number of industries warrants organizational leaders to evaluate their internal investigation approach (if any) and use it to help define the organization’s culture of compliance.

Attorneys of all levels are encouraged to attend this course to learn how to plan for internal investigations.

Learning Objectives:

  • Explain what an internal investigation is and detail its origination
  • Learn when to conduct an internal investigation
  • Explore how to appropriately scope an internal investigation
  • Detail common challenges that arise before, during, and after an internal investigation


Production Date: 1/12/2024

About the Presenters

Megan Harkins, Esq.

VillageMD

Practice Area: Health Law

Megan Harkins counsels VillageMD stakeholders on a variety of strategic and operational matters related to innovation in value-based care. These matters include: continuous federal and state regulatory updates, pharmacy integration, Center for Medicare and Medicaid Innovation (CMMI) Model participation, delegated service compliance, human resource issues, scope of practice compliance, telemedicine, among many other day-to-day questions that arise from any of the 26 markets or supporting workforce members.Prior to joining VillageMD, Megan was an Equal Justice Works Fellow at Legal Council for Health Justice. During law school, Megan served as a legal intern for several Chicago-based legal aid organizations, client advocate ...

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Sumaya Noush, Esq.

McDermott Will & Emery LLP

Practice Area: Health Law (+ 1 other areas)

Sumaya M. Noush counsels regional and multistate hospitals and health systems, specialty hospitals, academic medical centers and other healthcare organizations on a variety of strategic and operational matters. These matters include: mergers, asset and membership/stock transactions, joint ventures, hospital and physician affiliations, disaffiliations, dissolutions, divestitures, management of ownership transitions, entity structure formation and governance, medical staff bylaws, credentialing, peer review and privileging as well as survey, certification and accreditation matters.Sumaya closely partners alongside clients as they explore strategies for the future health of their communities, their missions and their business goals. She frequently advises her clients through the challenges of ...

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