Knowledge Library Best Practices for Conducting Internal Investigations
Thursday, January 26, 2017

Best Practices for Conducting Internal Investigations

In 2016, more than nearly a quarter million whistleblowers contacted the OIG directly or through their hotline, most stating that they first tried to raise their concerns internally, but either had no avenue to do so, or their information was not acted upon.  How an organization responds to complaints can spell the difference between an effective program that reduces risk of liabilities and one that increases exposure to them.

Join Richard Kusserow, a career investigator with the FBI and former Inspector General of the DHHS, along with Kashish Chopra, JD, MBA, CHC, for practical guidance in developing and executing an effective internal investigations program. Learn pitfalls to avoid when conducting investigations, gain perspective on how effective investigations can manage compliance risks, and investigation-related policies and procedures to help with your program organization and management.


  • Practical considerations in establishing  an internal investigation
  • Identification of key policies and procedures for program management
  • Perspective on the roles Legal, Compliance, and Human Resources in investigations
  • The 7 steps to an investigation:
    1. Gathering background information
    2. Planning the investigation
    3. Initiating the investigation
    4. Executing interim actions in an organization
    5. Gathering documentary evidence and conducting interviews
    6. Writing the final investigation report
    7. Closing the case and communicating findings
  • Guidance on how to conduct interviews, fact finding, and the art of questioning
  • Interview tips for dealing with deception


Richard Kusserow served for twenty-two years as a Special Agent and Supervisor for the FBI and as the Inspector General (IG) for HHS, where he was responsible for fraud/abuse oversight.  As the IG, his office investigated thousands of health care fraud cases. Mr. Kusserow established Strategic Management in 1992 and it has provided a broad range of advisory services including compliance assessments, financial/legal fact-finding, program analyses, policy development, and specialized investigations. His firm provides interim and designated compliance officer. He provides specialized expertise on fraud and abuse, sanctions, exclusion, and debarment processes and possesses special and unique expertise involving fraud and abuse laws and regulations, such as the Anti-Kickback Statute, and qui tam actions. Strategic Management has provided compliance consulting assistance to over 2,500 companies, facilities, organizations and entities, large and small, for-profit and non-profit. His firm has been selected many times as an approved Independent Review Organization and Compliance Experts.

Kashish Chopra, JD, MBA, CHC, a licensed attorney, conducts research and analysis, and provides advice to clients related to a number of compliance, regulatory, and legal issues. This includes addressing compliance program guidance by the HHS OIG, the Affordable Care Act, Medicare, Medicaid, Federal Anti-Kickback Statute, Stark Law, AdvaMed Code of Ethics on Interactions with Health Care Professionals (AdvaMed Code), corporate governance and other compliance topics. She drafts monthly regulatory reports, keeping clients up to date enforcement actions. She has served as an interim compliance officer, conducted internal investigations, and also routinely provides advisory services to clients.  Ms. Chopra frequently works on-site with clients to implement, evaluate, and enhance their compliance programs, and assists with the firm's Independent Review Organization (IRO) services to help clients fulfill their obligations under Corporate Integrity Agreements. Ms. Chopra previously worked in-house with the legal and compliance team for a global medical device manufacturer; worked with Public Health Law Research for the Robert Wood Johnson Foundation program; and as a trained mediator of matters in Family Court. Ms. Chopra is also acknowledged for her research contributions to The Oxford Guide to Treaties (2012).  Ms. Chopra has over a decade of experience as a speaker, trainer and presenter, included presentations at Harvard, Yale, and University of Michigan, among others.

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