Speaking with Government Agents
Objective
To set forth CUIMC policy and procedures regarding requests for information from Federal, State, or other government agents.
Policy
It is the policy of the University to cooperate with requests for information from governmental agents in accordance with applicable law.
Procedures
Interview Requests
If a government agent requests or initiates an interview with you:
- Request identification and ask for a business card. It is important to have the name of the agent and the agency that he or she represents. If the agent does not have a business card, ask that the agent provide his or her contact information on a piece of paper.
- A government agent may contact you by phone, letter, and/or personal visit to your office or home. Because proper identification cannot be obtained over the telephone, we suggest you defer and respond when the agent’s identity can be verified.
- Do not feel intimidated or rushed by the agent. It is your choice entirely whether to speak with the agent.
- If you do choose to speak with the agent:
- It is the University’s preference that the interview take place in person, rather than over the telephone, and that a University representative be present. Accordingly, we request that you contact the Office of the General Counsel and the OFBC prior to your interview. It is appropriate to tell the agent that you will speak with him or her, but that you must first make the appropriate arrangements.
- The University will provide you with legal representation for the interview, although depending on the nature of the interview and the matter, you may need to obtain your own counsel at some juncture.
- No interview or discussion should take place in a patient care area or an area frequented by visitors.
Search Warrants or Subpoenas
If a government agent serves you with a search warrant or subpoena:
- Request identification and ask for a business card.
- Contact both the Office of the General Counsel and the OFBC. All search warrants and subpoenas must be directed to the Office of the General Counsel. However, you must comply with a valid search warrant even if it is served after hours, when you are unable to direct it to the Office of the General Counsel and the OFBC.
- It is appropriate to ask that the agent write down exactly what documents are sought. Request a receipt for any documents that are taken. When possible, you should make a descriptive list of the documents.
Other Document Requests
If a government agent requests documents from you but does not serve you with a search warrant or subpoena:
- Request identification and ask for a business card.
- Contact both the Office of the General Counsel and the OFBC before providing the agent any documents.
In the event you are contacted by a government agent, the Office of the General Counsel, 212-854-0287, and the OFBC, 212-305-3842, are available to provide assistance.
Office for Billing Compliance
Policy#: OFBC 10014
Original Date of Issue: 1996
Revised: 3/22/2023
Reviewed: 3/1/2024