Relating to peace officers commissioned by the Health and Human Services Commission's office of inspector general.

Contracts

• Vendor Agreements: Review indemnification clauses with third-party billing companies. Ensure protections are in place if a vendor's error triggers a criminal fraud investigation by the OIG.
• Insurance Policies: Immediately review Directors and Officers (D&O) liability coverage. Ensure the policy covers defense costs for criminal investigations, not just civil regulatory matters, as OIG inquiries may now carry criminal weight.

Hiring/Training

• Front Desk Protocols: Reception staff must be retrained to distinguish between civilian auditors and commissioned peace officers. They must know how to identify a badge/commission and whom to notify immediately.
• Legal Escalation: Establish a "Dawn Raid" protocol. If an OIG officer presents a badge or search warrant, General Counsel must be notified instantly. Staff must understand their rights regarding interviews with law enforcement versus administrative auditors.

Reporting & Record-Keeping

• Privilege Logs: Maintain rigorous attorney-client privilege designations on internal compliance audits. If OIG executes a search warrant, clear privilege logs are your primary defense against total data seizure.
• Audit Trails: Ensure Electronic Health Records (EHR) and billing systems maintain unalterable audit trails to prove data integrity during a criminal probe.

Fees & Costs

• No Direct Fees: The bill does not impose new filing fees.
• Indirect Costs: Anticipate potential increases in liability insurance premiums due to the heightened enforcement environment.