20 key questions to be answered
The biggest challenge to conducting successful compliance investigations is knowing how to conduct successful witness interviews. Many find a list of predetermined questions to ask witnesses in a compliance investigation useful. However, care needs to be taken that this approach limits the information the investigator will get from the interview. This is because it constrains the conversation within a rigid framework. Begin with simple questions about an individual’s position, how long they have worked for the organization, identify their supervisor, etc. This will allow the individual to relax a little bit before going into substantive questioning. Keeping the interview as a fluid conversation will likely result in more productive results. It is always preferable to use open-ended questions to let a witness tell their story in their own way, such as “Tell in your own words about….” The following 20 questions can be used as a guide to frame your interviews and can be used as a reminder at the end of the interview to ensure all the key points have been addressed:
- What happened?
- Where did it happen?
- When did it happen?
- Who did it?
- Has it happened before?
- How often?
- Who else was present?
- Do you know of others who may have been affected by the incident or behavior?
- Who else may have seen or heard the incident or behavior?
- How did you react?
- How did any others present react?
- Did you ever indicate that you were upset or offended by the incident or behavior?
- Have you discussed the incident or behavior with anyone?
- Has anyone else reported this?
- How has the incident or behavior affected you?
- How has the incident or behavior affected your job?
- Have you sought medical treatment or counseling because of the incident?
- Do you have any evidence or documentation about the incident or behavior?
- Is there anyone else who may have relevant information?
- Is there any other relevant information that I haven’t asked you about?
For more information on conducting compliance investigation interviews or securing investigator training, contact Richard Kusserow at Rkusserow@strategicm.com .
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 © 2020 Strategic Management Services, LLC. Published with permission.
