Kusserow on Compliance: Debriefing complainants—24 question tips

It is very important to fully debrief any complainants and act in a very timely manner to avoid having them go elsewhere with their information—such as an attorney, government agency, media, etc. Any of these other channels could result in serious problems and possible liability. In many cases the information may come anonymously from the hotline, underscoring the importance that those answering the calls be trained on properly debriefing callers and be familiar with health care related issues.

Also, time is not a friend once information is received that may warrant immediate action. Complicating matters is that frequently a single complaint may include several different allegations, each of which needs to be addressed independently. In the debriefing process, once the story is told, specific clarifying questions need to be asked in guiding the person back through the information. This should be done by asking the standard WHO, WHAT, WHEN, WHERE, and WHY questions. These should be designed to expand on the factual details and to test and corroborate the information and be sure the chronologies of events are established.

It is important also to look for avenues and leads that will provide direction by which to either substantiate the allegations or dismiss them. Inasmuch as the allegations may relate to a specific event, something personal or organization wide, an ongoing process problem, etc. It is impossible to draft a set of question that would apply in every circumstance, however the following gives an idea about the types of questions that can be asked in a formal debriefing.

 

DEBRIEFING QUESTIONS

 

  1. What happened that led to the making of the complaint?
  2. Why are you coming forth with it now?
  3. What occurred, where, when, and how?
  4. Did the person who engaged in the conduct engage in similar conduct with anyone else?
  5. Has anyone else complained to you about similar conduct?
  6. When did it occur (date and time)?
  7. Where did it take place?
  8. How did you respond when it occurred?
  9. Who did you discuss it with and when? 
  10. What did you say? What did they say?
  11. How has this incident affected you?
  12. Has your job been affected in any way?
  13. Who else was present when the act occurred? 
  14. Where were they in relation to you? 
  15. Who else has any knowledge of the act? 
  16. Has anyone else discussed it with you? 
  17. If so, who and what did that person say? 
  18. Did anyone see you immediately after the act?
  19. Who else was involved, knows about, or witnessed it?
  20. Who else have you told (employees, supervisor, attorney, media,)?
  21. Why do you think it happened?
  22. What documentary evidence would help in the investigation?
  23. What do you believe should be done to resolve this matter?
  24. Has is happened before (an isolated event or part of a pattern)?

 

Richard P. Kusserow served as DHHS Inspector General for 11 years. He currently is CEO of Strategic Management Services, LLC (SM), a firm that has assisted more than 3,000 organizations and entities with compliance related matters. The SM sister company, CRC, provides a wide range of compliance tools including sanction-screening.

Connect with Richard Kusserow on LinkedIn.

Subscribe to the Kusserow on Compliance Newsletter

Copyright © 2019 Strategic Management Services, LLC. Published with permission.