Tool: Model Hotline Allegations Investigation Procedure

The OIG Model Compliance Plan for Clinical Laboratories requires labs to establish mechanisms for not only receiving but promptly investigating internal complaints and reports of potential compliance violations and wrongdoing. Although there is no such thing as a one-size-fits all template, the model below includes the key elements of an investigation procedure. Just make sure you adapt it to the unique circumstances of your own lab.

Note: This procedure is designed for responding to red flags that may crop up and not as a substitute for regular and routine compliance monitoring and auditing.