The Use of Internal Investigations

Over the last few years, it has become increasingly clear that health care provider boards of directors and lead executives can be liable for the misdeeds of employees and management of the companies. For example, if an employee in charge of business development forms financial relationships with referring physicians, the liability for improper payment or recruitment incentives can lead back to the executive suite or the boardroom. Further, as a hospital’s Chief Financial Officer develops means by which patients will be billed, whether for governmental programs, uninsured patients, or private payors, and these payment schemes end up raising legal concern, the fallout can reach the highest levels of the hospital system.

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