Kusserow on Compliance: Compliance investigation witness interview questions

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:

  1. What happened?
  2. Where did it happen?
  3. When did it happen?
  4. Who did it?
  5. Has it happened before?
  6. How often?
  7. Who else was present?
  8. Do you know of others who may have been affected by the incident or behavior?
  9. Who else may have seen or heard the incident or behavior?
  10. How did you react?
  11. How did any others present react?
  12. Did you ever indicate that you were upset or offended by the incident or behavior?
  13. Have you discussed the incident or behavior with anyone?
  14. Has anyone else reported this?
  15. How has the incident or behavior affected you?
  16. How has the incident or behavior affected your job?
  17. Have you sought medical treatment or counseling because of the incident?
  18. Do you have any evidence or documentation about the incident or behavior?
  19. Is there anyone else who may have relevant information?
  20. 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.

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Copyright © 2020 Strategic Management Services, LLC. Published with permission.