Counsel, Enterprise Investigations

We are looking for an experienced attorney skilled in compliance investigations to be part of the Legal Department's Enterprise Investigations unit.

Our team of seven internal investigators is responsible for assessing and investigating reports and allegations of healthcare fraud (including False Claims Act, Anti-Kickback statutes, and Stark Law), conflicts of interest, theft and fraudulent schemes, contract and procurement concerns, data privacy issues, discrimination, harassment, failure to report or escalate, and other inappropriate behavior.

Working within Cigna's Legal Department, our internal investigators frequently partner with, and act under the supervision and direction of counsel.

They are responsible for cultivating a culture that emphasizes integrity, and a working atmosphere that promotes open and candid discussions regarding ethics or compliance concerns; acceptance of responsibility for actions taken; effective oversight; and operational transparency with key stakeholders

Specific Duties Include



* Manage a case list comprised of complex compliance, ethics, and employment investigations, including conducting case intake meetings, background research, interviews, and stakeholder debrief meetings;


* Assist with the review, analysis, and resolution of reports received through Cigna's Ethics Help Line and other channels, including complaints involving allegations of fraud, corruption, privacy concerns, conflicts of interest, discrimination, harassment, retaliation, failure to escalate, and other inappropriate behavior;


* Ensure that compliance and ethics inquiries, and reports of alleged employee misconduct are promptly assessed, responded to, timely and thoroughly investigated, and resolved;


* Partner with Cigna's team of e-discovery and forensic investigators to identify, preserve, and obtain relevant documents and data;


* Conduct internal investigations, to include reviewing relevant documents, communications and data, and conducting interviews of relevant individuals, including privileged internal investigations conducted under the supervision and direction of in-house and/or outside counsel;


* Ensure that investigative actions, files, findings, and outcomes are thoroughly and timely documented, memorialized, accurate and complete; prepare reports of interviews and other investigative reports; and ensure that findings and conclusions from internal investigations are timely and effectively communicated to relevant stakeholders;


* Collaborate with Human Resources and Employee Relations on any employment actions arising from internal investigations;


* In collaboration with partners in Enterprise Compliance and the relevant business segment, conduct root cause analyses and determine whether any remedial or corrective actions may be appropriate, and whether matters and/or findings or conclusions should be disclosed to federal and/or state agencies;


* Ensure that appropriate policies and...