How to Conduct an Internal Investigation of Your Behavioral Health Residential Program

In a previous blog post, we discussed how residential treatment programs should respond to requests for information regarding resident safety. These requests often come from licensing agencies, payers, and other parties.
Sometimes, however, a behavioral health facility can launch an internal investigation. Here’s what you should know about conducting one in your organization.
Conduct internal investigations regularly
They say that “prevention is better than a cure,” and that’s true for behavioral health facilities. Instead of waiting for a whistleblower to call attention to a serious issue, you can identify areas for improvement before they become big problems.
Internal investigations might seem inconvenient, disruptive, and time-consuming. However, consider the potential risks of not conducting one:
Failure to discover or correct problems that can impact client outcomes
Negative effects on the provider’s reputation and public image
Burdensome, potentially indefinite monitoring of the facility by outside parties
Licensing agencies may suspend admissions or revoke your license
Reduced referral sources and potential non-payment from payers, creating financial burdens
Have a plan for your behavioral health investigation
Establishing a goal and intentions for the internal audit are crucial for its success. This will help guide your process.
A few key questions can help you plan.
What is your purpose for the investigation?
Who should lead and conduct the investigation?
When should the investigation be performed? (Consider the potential disruption that things like staff interviews may have on the workday)
How will you respond to any issues you find?
To whom should you report your findings?
Make sure the investigation targets specific issues. Have a clear definition or description of what those issues are.
Start your internal audit as soon as possible. Make sure you can wrap up before any reporting deadlines you may need to follow.
Interview staff members in your investigation. If some individuals are hesitant to speak up, consider developing a way to request feedback anonymously. Review all relevant documentation, including clinical and billing, as well as video footage. Be aware of HIPAA rules regarding the disclosure of protected health information.
Consider outside counsel for your behavioral health facility
Even when you’re conducting an internal investigation, you don’t have to go it alone. Hiring legal counsel has many benefits, and can help ensure a better outcome for any investigation. An outside legal expert can:
Help preserve independence and objectivity during an inquiry
Encourage behavioral health staff to speak more freely about their issues or concerns
Show that the organization is serious about addressing resident safety concerns
Help identify improvement and training opportunities
Represent the organization to other groups
Maintain a transparent behavioral health work environment
Outside of conducting regular internal audits, behavioral health facilities should encourage a transparent, professional environment in which staff, clients, or families with a concern can speak up. If violations are found, behavioral health organizations should disclose them voluntarily.
Taking safety concerns seriously can help behavioral health providers stay compliant and keep problems small. This will ensure the best outcome for both the providers and their clients.
Conducting an internal investigation? Appropriate documentation goes a long way in helping your inquiry go smoothly. The BestNotes EHR solution offers a documentation app that follows federal, state, and accreditation standards, updating changes automatically, so you can maintain compliant records without anxiety. Contact us today to learn more, or schedule a free demo.