Writing an Objective, Defensible Investigative Report
Written By Dr. Stacey R. Atkins, PhD, MSW, LSW, CPC, CIGE
An internal investigative report represents the culmination of an internal forensic audit or compliance investigation conducted within your organization. It is the most critical deliverable in any inquiry, transforming data, interviews, and evidence into actionable conclusions. According to the Office of Inspector General’s (OIG) 2023 guidance, well-documented investigations not only demonstrate compliance program effectiveness but also protect organizations from regulatory exposure. This article provides tips to writing an objective and defensible investigative report. For more information on how to conduct internal investigations and drafting your findings, consider registering and certifying as an Internal Forensic Healthcare Auditor (CIFHA) with the American Institute of Healthcare Compliance, a Licensing/Certification Partner w/CMS.
Introduction
In healthcare, the investigative report serves as both the historical record of an inquiry and the foundation for corrective action. Unlike informal summaries or audit notes, investigative reports must withstand scrutiny from regulators, accreditation bodies, and, in some cases, legal proceedings.
A report that is clear, factual, and defensible establishes credibility and demonstrates that the organization maintains a culture of compliance.
According to the U.S. Department of Justice’s 2024 Evaluation of Corporate Compliance Programs, documentation that reflects diligence, transparency, and follow-up is a decisive factor in evaluating the effectiveness of a compliance program. Similarly, the OIG, 2023 identifies timely reporting and accurate documentation as hallmarks of program integrity. Investigative reports thus become more than administrative records; they are compliance evidence.
The American Institute of Healthcare Compliance emphasizes that reporting is not merely a conclusion but an analytical phase requiring objectivity, ethical awareness, and technical precision.
Investigators are expected to synthesize complex data, maintain neutrality, and communicate findings in language that is factual and free from bias. When written properly, the investigative report transforms an incident into an opportunity for systemic improvement and risk reduction.
The Role of the Investigative Report
The investigative report is the official artifact that captures the who, what, when, where, why, and how of an inquiry. In many cases, the report becomes part of the audit trail reviewed by internal and external regulators.
A typical report lifecycle includes several stages—drafting, legal review, management approval, dissemination, and closure. During drafting, investigators must balance thoroughness with clarity. Legal counsel often reviews the document for privilege, tone, and factual accuracy, ensuring it aligns with both organizational policy and legal expectations. Once finalized, reports are stored in secure repositories, contributing to the organization’s compliance data archive.
Collaboration between departments is necessary. Compliance, Risk Management, Human Resources, and Legal must work together. The OIG’s 2024 Compliance Program Effectiveness Resource Guide notes that interdisciplinary collaboration ensures findings are contextualized, recommendations are actionable, and accountability is shared. Reports that integrate multiple perspectives are more defensible and effective.
Key Elements of a Defensible Investigative Report
1. Clear Purpose and Scope
Every investigation should begin with a clearly defined purpose and scope. This section establishes the reason for the inquiry, outlines the questions to be answered, and defines the parameters of review. The scope should specify dates, departments, and records included. Ambiguity in this section can lead to confusion or accusations of overreach.
2. Accurate Summary of Allegations
The summary should precisely capture the complaint or triggering event. Avoid loaded language or assumptions of intent. The investigator should record who made the allegation, what was alleged, and how the issue was reported, whether through a hotline, audit, or direct disclosure. The summary sets the foundation for factual neutrality.
3. Methodology and Data Sources
Transparency in how evidence was collected and reviewed is vital for credibility. A strong methodology section identifies interviews conducted, documents examined, and systems accessed. According to Deloitte’s 2024 Internal Investigations Report, transparency in data collection fosters confidence among regulators and leadership.
4. Chronological Narrative of Events
A chronological approach provides structure and logic. The Government Accountability Office’s (GAO) 2023 Fraud Risk Framework recommends organizing findings in sequence to demonstrate due diligence. Timelines clarify causation, highlight delays, and show that each step followed procedural fairness.
5. Presentation of Evidence
Evidence must be presented clearly and factually. Data tables, summaries, and appendices can help. Use neutral phrasing such as “the documentation indicates” or “records show.” Avoid speculation or conclusions not supported by evidence.
6. Analysis and Interpretation
This section bridges fact and meaning. Investigators should explain how findings relate to policies, procedures, or laws. The Association of Certified Fraud Examiners (ACFE, 2024) advises separating analysis from fact statements to maintain objectivity.
7. Conclusions and Recommendations
A defensible conclusion synthesizes validated evidence and identifies corrective actions. Recommendations should be measurable and achievable, such as policy revisions, training, or audits. Avoid subjective commentary—focus on remediation, not blame.
8. Documentation and Appendices
Supporting documentation should be referenced systematically. Attachments should include interview notes, data extracts, or relevant policies. Appendices demonstrate transparency and provide traceability for external reviewers.
Analytical Techniques for Investigative Reporting
Modern investigations increasingly rely on data analytics to support conclusions. According to PricewaterhouseCoopers (PwC’s) 2024 study on compliance analytics, quantitative analysis can identify outliers, correlations, and anomalies that qualitative methods may overlook. Tools such as data visualization dashboards, trend charts, and heat maps can make complex findings accessible to leadership and regulators. For example, an investigator might analyze billing records to identify patterns of upcoding or duplicate claims. By visualizing data trends over time, the investigator can present evidence more persuasively.
The American Institute of Healthcare Compliance curriculum teaches participants how to interpret financial and operational data, integrating forensic accounting with compliance interpretation. The analytical phase also includes peer review and quality assurance.
According to the Society of Corporate Compliance and Ethics (SCCE, 2024), peer review provides an additional safeguard against bias or oversight. It ensures consistency across investigations and maintains trust in the process.
A Real-World Example: The Case of NorthView Behavioral Health
In 2024, NorthView Behavioral Health conducted an internal investigation after a report alleged improper overtime coding by nursing supervisors. The trained investigator used data analytics to compare scheduled shifts with payroll records, revealing discrepancies across three departments.
- Interview transcripts and electronic timecard reviews confirmed manual overrides without documentation.
- The investigator followed American Institute of Healthcare Compliance reporting principles, organizing the findings chronologically and using data tables to illustrate patterns of discrepancy.
- The final report avoided subjective conclusions, instead focusing on systemic control gaps.
NorthView’s leadership responded by implementing automated shift validation, strengthening oversight protocols, and scheduling quarterly forensic audits. Because the report was objective, transparent, and data-driven, the organization self-disclosed to state regulators and avoided civil penalties. This case demonstrates how defensible reporting can convert a compliance issue into a model of organizational integrity.
Ethics, Language, and Professional Judgment
The ethics of reporting extend beyond accuracy to encompass tone and fairness. Investigators must avoid language that implies guilt or bias. According to the OIG’s 2023 Compliance Guidance, neutral phrasing and avoidance of adjectives that imply motive are essential to credibility. Investigative writing should mirror the impartiality of a court transcript, focusing on fact patterns rather than assumptions.
Professional judgment also plays a role in deciding what to include or omit. Transparency must be balanced with confidentiality and privilege. Collaboration with legal counsel helps determine which sections of a report may be privileged and how to handle sensitive information.
Turning Findings into Action
A defensible report achieves its true value only when findings lead to action. Compliance officers should ensure that recommendations translate into corrective and preventive actions (CAPAs). These may include revising policies, retraining employees, or enhancing data monitoring systems. The OIG (2024) recommends that compliance programs document each corrective action and assess its effectiveness through follow-up audits.
Action plans should be SMART—Specific, Measurable, Achievable, Relevant, and time-bound.
For example, if an investigation reveals inconsistent documentation practices, the CAPA may include targeted documentation training within 60 days and follow-up reviews within 90 days. By tying findings to measurable outcomes, organizations demonstrate accountability and compliance maturity.
Feedback loops are also critical. According to the GAO’s 2023 framework, integrating lessons learned into annual compliance reviews prevents recurrence of systemic issues. Trained investigators are equipped to design these loops, bridging the gap between investigative insight and continuous improvement.
Conclusion
The quality of an investigative report defines the credibility of the entire investigation. It is both a record and a reflection of an organization’s ethics. A defensible report is factual, impartial, and actionable, attributes that align with the standards set forth by OIG, Department of Justice (DOJ), and other oversight agencies. When written properly, the investigative report becomes a tool for learning rather than liability.
Certified Internal Forensic Healthcare Auditor-trained professionals are uniquely positioned to produce such reports. By combining forensic insight, analytical precision, and ethical clarity, they help organizations move from compliance response to proactive risk management. In a healthcare environment where accountability is paramount, the ability to write an objective, defensible report is both a compliance requirement and a professional hallmark of excellence.
About the Author
Dr. Stacey R. Atkins, PhD, MSW, LMSW, CPC, CIGE
Dr. Atkins is a Compliance Specialist working as a team member in the Education Department of the American Institute of Healthcare Compliance. Her career spans leadership roles with the Office of the State Inspector General, Department of Behavioral Health and Developmental Services, and HRSA, among others.
References
- American Institute of Healthcare Compliance – 2025 Certified Internal Forensic Healthcare Auditor curriculum.
- Office of Inspector General (OIG). (2023). General Compliance Program Guidance.
- Office of Inspector General (OIG). (2024). Compliance Program Effectiveness Resource Guide.
- U.S. Department of Justice (DOJ). Evaluation of Corporate Compliance Programs.
- Association of Certified Fraud Examiners (ACFE). (2024). Report to the Nations on Occupational Fraud and Abuse.
- Government Accountability Office (GAO). (2023). Fraud Risk Management Framework.
- Deloitte. (2024). Internal Investigations and Reporting Trends in Healthcare.
- PwC. (2024). Effective Documentation in Corporate Investigations.
- Society of Corporate Compliance and Ethics (SCCE). (2024). Peer Review in Compliance Investigations.
- Journal of Health Care Compliance. (2023). Ethics and Documentation Standards in Healthcare Audits.
- Harvard Business Review. (2023). Transparency and Accountability in Organizational Reporting.
- U.S. Department of Health and Human Services (HHS). (2024). Health Care Fraud and Abuse Control Program Annual Report.
Copyright © 2025 American Institute of Healthcare Compliance All Rights Reserved