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Investigations by Third Parties

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Policy No.: '''6109'''<br />
Effective Date: '''10/16/04'''<br />
Revised Date: '''0208/1215/1820'''<br />Reviewed Date: '''0208/1215/1820'''<br /><br \>'''<big>Investigations by Government Officials, Regulatory Agencies, and Other Third Parties</big>'''<br /><br \>
== Purpose ==
Government investigators, regulatory agencies or other third parties may contact staff or arrive unannounced at UNMC or at the homes of staff members and seek interviews, documents, information or request to search the premises. The purpose of this policy is to establish procedures for an orderly response that protects the interests of UNMC and provides for appropriate cooperation. Examples of regulatory agency visits, investigations, or requests for information that are subject to this policy include but are not limited to the following:
#'''Regulatory Agency Visits'''
#* UNMC staff members who are notified of a visit by a regulatory agency should notify their supervisor, director and/or dean (as appropriate to the type of visit) and the Compliance Officer at 402-559-9576 or 402-559-6767.
#* Any requests for protected health information (PHI) pursuant to an investigation by a regulatory agency require notification of the Privacy Officer at 402-559-5136 prior to providing patient information.
#* During the visit, the regulatory agency official(s) should be escorted at all times by an individual who is knowledgeable about the area(s) visited.
#* Most regulatory agency visits are permitted pursuant to state or federal law, and the regulator may request copies of documents to assess compliance without providing a subpoena. Staff who are unsure about whether documents should be provided to regulators should ask their supervisor, the Compliance Officer at 402-559-9576 or 402-559-6767 or the Associate General Counsel for Health Sciences (care of the University’s General Counsel’s office at Varner Hall at 402-559472-9005 1201) for guidance.
#* Supervisory personnel and the Compliance Officer should be informed of any serious compliance issues that may arise during the visit as soon as possible, and shall be provided with reports of findings at the end of all visits.
#'''Investigations by Government Officials/Law Enforcement/Other Third Parties'''
#* If a UNMC staff member becomes aware of any contact by an agent, representative, investigator, auditor or attorney from any governmental agency, law enforcement agency, or other third party (hereinafter, "investigator"), the staff member should ask to see the investigator's identification and business card for name and agency affiliation. If contact is by telephone, ask the investigator to fax a business card or other identification. Ask for the investigator's agency name and phone number and call him/her back to verify identity.
#* Inquire as to the reason for the visit, if rationale has not already been provided.
#* Contact a supervisor, director or dean, and the Compliance Officer at 402-559-9576 or 402-559-6767. If the Compliance Officer is unavailable, contact the Associate General Counsel for Health Sciences (care of the University’s General Counsel’s office at Varner Hall at 402-559472-90051201). The Compliance Officer and/or Associate General Counsel for Health Sciences shall notify the University of Nebraska Office of the Associate General Counsel of the investigation and coordinate with them as necessary.
#* If the subject matter of the investigation is not in the staff member's area of responsibility, the Compliance Officer should be contacted, so the investigator can be directed to the correct area.
#* '''Subpoenas/Search Warrants'''. If the investigator asks to search a UNMC facility or obtain any documents from UNMC, ask if there is a subpoena or search warrant to be served; and if so, make a copy of the document. Immediately contact the Associate General Counsel for Health Sciences to review the subpoena or warrant to verify it is valid and to provide advice on responding to it. If he/she is unavailable, the University of Nebraska Office of the Associate General Counsel should be contacted to review the documents. The Compliance Officer and/or Associate General Counsel for Health Sciences shall escort the investigator, along with personnel familiar with the area to be searched.
==Additional Information==
*[mailto:sarah.glodencarlson@unmc.edu Chief Compliance Officer], 402-559-9576 or 402-559-6767
*Associate General Counsel for Health Sciences, (care of the University’s General Counsel’s office at Varner Hall at 402-559472-9005 1201)
*[https://support.security.unmc.edu Office of Information Security]
This page maintained by [mailto:dpanowic@unmc.edu dkp].

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