URMC Compliance Program Policy Manual:
Response to Investigation

State and federal agencies have broad legal authority to investigate health care providers and review their records. The URMC entities will comply with subpoenas and cooperate with governmental investigations to the full extent required by law. The Compliance Officer is responsible for coordinating the response to investigations and the release of any information.

If a department, an employee, or a professional staff member receives an investigative demand, subpoena, or search warrant involving the institution, it should be brought immediately to the Compliance Officer. Do not release or copy any documents without authorization from the Compliance Officer or legal counsel. If an investigator, agent, or government auditor comes to the institution, contact the Compliance Officer immediately. In the Compliance Officer's absence, contact the organization's CEO or a Vice President. Ask the investigator to wait until the Compliance Officer or his designee arrives before reviewing any documents or conducting any interviews. The Compliance Officer or his designee is responsible for assisting with any interviews, and the institution will provide counsel to employees, where appropriate. If personnel are approached by government investigators and agents, they have the right to insist on being interviewed only at the facility during business hours or with counsel present.

If a professional staff member receives an investigative demand at his or her private office and the investigation may involve one of the URMC entities, the staff member is asked to notify the Compliance Officer immediately.

Employees of the URMC entities are not permitted to alter, remove, or destroy documents or records of their employer. This includes paper, tape, and computer records.

Subject to coordination by the Compliance Officer, the System entities and their employees will disclose information required by government officials, supply payment information, provide information on subcontractors, and grant authorized federal and state authorities with immediate access to the facility and its personnel. Failure to comply with these requirements could mean that the organization will be excluded from participating in the Medicare and Medicaid programs.

Subcontractors who provide items or services in connection with the Medicare and/or Medicaid programs are required to comply with these policies on responding to investigations. Subcontractors must immediately furnish the Compliance Officer, legal counsel, or authorized government officials with information required in an investigation.