Do you know what to do when an investigator or federal agent knocks on your door? Do you staff know what to do? Is this a routine visit from the Medicare Site Visit Validation Contractor, the FBI, OIG, or an investigator from the licensing board. Help is on the way! The Red Envelope Policy is a set of easy to customize documents for your practice to provide instructions on what to do when confronted with an investigative scenario. You are likely wondering why we call it the “Red Envelope Policy”. We are so glad you asked!
When an investigator walks in the front door of your office or clinic and presents a badge, a subpoena, a search warrant, civil investigative demand, or a written request for records, it is important to have a process in place to contact management or clinic owners, while at the same time cooperate with authorities.
When an investigation is at your front door, it is not the time for front office staff to be frantically looking for the policy manual, or instructions that invariably can’t be located while panic is setting in. If the front office staff is not available the investigators may look to speak with any staff that is available, which may include interruption of patient care. By having your policy on investigations readily available and accessible in a red envelope (or red folder) in the clinic’s front office, no one at your clinic will be wondering what to do, who to call, and what to say to the investigator. A red envelope will stand out, but better yet, your policy will stand out by instructing staff as to the procedures to follow, and assuring the investigator of your intent to cooperate.
There are 3 versions of the Red Envelope Policy available:
- Red Envelope Policy Template. This template includes a “Dear Investigator” letter, a policy on investigations, and a data collection form to ensure that those present during the time an investigation is in the clinic record pertinent information. A policy on investigations will instruct your staff who to call, what to do, and how to respond to the investigator.
- Red Envelope Policy Preparation and Response. This Red Envelope Policy option builds on the Template and implements a comprehensive approach to preparation and response to investigations and unannounced visits from Medicare, the Department of Justice, Medicaid, Department of Professional Regulation, insurance fraud investigators, and other authorities.
- Red Envelope Policy Customized. Let us create a comprehensive Red Envelope Policy Tool exclusively for your organization. This customized and branded Tool will be specific to your unique lines of business, practice locations, staffing and management structure, unique State laws and/or relevant Survey & Certification requirements, as well as your compliance program elements.
Has an investigator knocked on your door? Don’t be caught off guard, this is an essential policy for your clinic in support of your compliance initiatives.