Flexibility Within a Framework: Conducting Effective Internal Compliance Investigations

Health care associate Sumaya Noush coauthored an article with VillageMD Associate General Counsel Megan Harkins for the Society of Corporate Compliance and Ethic's CEP Magazine that discusses how having an investigation framework to operate within provides organizations the flexibility to tailor the internal investigation strategy and address common challenges to conducting internal investigations.

Noush and Harkins outline steps that can be used to conduct effective internal investigations, including 1) know when to investigate, 2) define the scope of the investigation, 3) standardize the internal investigation approach, 4) consult legal advisers, 5) interview witnesses and 6) report investigation findings. The authors also provide key takeaways to remember while conducting internal investigations.