Investigation Interview Guide

How to prepare for, conduct, and document interviews during a diversion investigation — from witnesses to the subject of the investigation.

PREPARATION
Pre-Interview Preparation

Before conducting any interview, ensure you have a complete picture of the evidence.

1. Gather & Review All Data
  • ADC transaction logs for relevant time window
  • MAR records for the patients in question
  • Camera footage synced to transaction times
  • Waste documentation records
  • Scheduling — who was on shift, who was near the subject
  • Previous reports or concerns involving the subject
2. Build a Timeline
  • Plot every relevant transaction chronologically
  • Overlay camera footage timestamps
  • Mark witness-verified events vs. unverified
  • Identify gaps, inconsistencies, and anomalies
  • Determine which events need explanation
3. Plan the Interview Order
  • First: The reporting person (if applicable)
  • Second: Colleagues who worked same shifts
  • Third: Supervisor / charge nurse
  • Fourth: Other witnesses (patients, family, security)
  • Last: The subject of the investigation
SEQUENCE
Interview Order & Strategy
Order Who Goal Technique
1 Reporting person Get the initial account while it's fresh. Understand exactly what they saw/heard, when, and why they decided to report. Open-ended: "Tell me what you saw from the beginning." Avoid leading questions. Record verbatim if possible.
2 Colleagues / peers Corroborate patterns — does the subject's behavior align with what the data shows? Gather observations from multiple sources. Behavioral questions: "Have you noticed anything different about [subject]'s medication handling? Have they mentioned any personal stressors?"
3 Supervisor / charge nurse Get the operational perspective — any previous concerns? Performance issues? Pattern of absences or incident reports? Fact-focused: "Have you received any reports about [subject]'s CS handling? Any discrepancies you've noticed in their documentation?"
4 Other witnesses Fill gaps in the timeline. Security can confirm access logs. Patients can confirm whether they received medication. Specific: "On [date] at [time], did you observe [event]?" Cross-reference with what others said.
5 The subject Present evidence, get their explanation, assess their credibility. HR/legal must be present. Union rep if applicable. Structured confrontation — present data patterns, not accusations. "Help us understand these transactions."
TECHNIQUE
Questioning Techniques & Sample Questions
Open-Ended Questions (Witnesses)
  • "Tell me about how controlled substance waste is handled on your unit."
  • "Describe what you observed on [date/time]."
  • "What happened next?"
  • "Is there anything else about that shift that stood out to you?"
  • "How would you describe [subject]'s behavior around medication handling?"
  • "Have you noticed any changes in [subject] recently?"
Behavioral Questions
  • "Does [subject] typically volunteer for CS-related tasks?"
  • "Have you ever seen [subject] waste CS without a witness present?"
  • "Has [subject] ever asked to borrow your login or badge?"
  • "How does [subject] react to questions about their CS handling?"
  • "Have you noticed any physical changes in [subject] recently?"
Subject Interview Questions
  • "Walk me through your process for administering [drug] to [patient] on [date]."
  • "The ADC log shows you removed [dose] for [patient] at [time]. Can you describe what happened?"
  • "The camera footage at [time] shows [observation]. Can you explain what we're seeing?"
  • "Your waste rate is [X]% — that's [Y]x higher than the unit average. Can you help me understand why?"
  • "The MAR shows [patient] received [dose], but the family reports [patient] was in pain. How would you explain that?"
  • "Is there anything going on in your personal life that might be affecting your work?"
  • "Is there anything you want to tell me about these transactions?"

DO NOT make accusations. DO NOT express personal opinions. DO present data and give the subject a chance to explain. DO document everything verbatim.

DOCUMENTATION
Documentation Standards
What to Document
  • Date, time, and location of each interview
  • Who was present (full names, titles)
  • Who participated and who observed
  • Verbatim notes — use quotation marks for key statements
  • Non-verbal observations (demeanor, body language, emotional state)
  • Documents or evidence shown during the interview
  • Subject's responses, explanations, and any admissions
  • Any request for union representation or legal counsel
  • Duration of the interview
  • Signature of the interviewer and any witnesses
How to Document
  • Write notes during the interview — do not rely on memory
  • If possible, have two interviewers: one asking questions, one taking notes
  • Read back key statements to confirm accuracy
  • Have the subject sign and date their statement if they provide a written version
  • If the subject refuses to sign, document the refusal
  • Store interview notes in a secure, access-controlled location
  • Maintain a separate chain-of-custody log for physical evidence shown during the interview

Critical: Never destroy or alter interview notes, even if the investigation concludes that no diversion occurred. Original notes are discoverable in legal proceedings. Preserve everything.

LEGAL
Legal Considerations
Union Representation
  • If the subject is covered by a collective bargaining agreement, they have the right to union representation if the interview could lead to discipline (Weingarten rights).
  • Inform the subject of their right to representation.
  • If they request a rep, pause the interview until the rep arrives.
  • Union rep is an observer, not a participant — they cannot answer for the employee.
HR Involvement
  • HR must be present for any interview that could lead to disciplinary action.
  • HR ensures consistency with organizational policy and past practice.
  • HR manages employee notification requirements (state-specific).
  • HR coordinates any leave, suspension, or accommodation decisions.
Law Enforcement
  • If the investigation confirms significant diversion, law enforcement referral may be appropriate.
  • Involve legal counsel before contacting law enforcement.
  • Do not make promises of confidentiality if the matter may become criminal.
  • DEA notification (Form 106) is a regulatory requirement, not a criminal referral.
WARNING
Red Flags During the Interview
Behavioral Red Flags
  • Defensiveness disproportionate to the questions — "Are you accusing me of something?" before any accusation was made
  • Blame shifting — "Everyone on my unit does it" or "The cabinet is always wrong"
  • Over-explaining — offering excessive detail about routine transactions without being asked
  • Minimizing — "It was just a small amount" or "I was going to waste it later"
  • Memory gaps at critical times — "I don't remember that specific patient" when data shows a clear pattern
  • Physical signs of impairment — tremors, pupils, runny nose, drowsiness, unusual sweating
Statement Red Flags
  • Inconsistencies with data — "I always waste with a witness" but records show no witness for 40% of waste events
  • Inconsistencies with other witnesses — "I was at the nurses station the whole time" but three colleagues recall them being elsewhere
  • Statements that shift over time — version A on first interview, version B on follow-up
  • Refusal to answer — "I don't want to talk about this" or "I need to speak to a lawyer"
  • Offering alternative suspects — "You should look at [coworker]" when the question is about their own transactions