In the wake of the recent shootings at Chicago Mercy Hospital, there has been renewed attention to the irony that many of the facilities and institutions designed to treat the sick and injured have themselves become the site of potential violence.
Workplace violence is a potential threat in every organization, but it is particularly prevalent in healthcare. FBI statistics show that 45 percent of all workplace violence incidents occur in the healthcare industry. U.S. healthcare workers are three to four times as likely to experience workplace violence than workers in other industries, and up to 75 percent of healthcare workers have suffered physical or verbal abuse from a patient or someone connected to the patient. To put those numbers in context, consider that the Department of Labor reports that workplace violence in the healthcare industry accounts for almost as many serious injuries as all other industries combined.
Growing awareness of workplace violence in healthcare is raising formal standards for security and workplace violence prevention measures. When the Centers for Medicaid and Medicare Services (CMS) passed the Emergency Preparedness Final Rule in 2016—formally requiring healthcare organizations participating in the Medicare or Medicaid programs to conduct annual, all-hazards security assessments and emergency preparedness/active shooter training and drills—it dramatically upped the regulatory ante and spurred additional progress in medical facilities across the country. And failure to comply results in becoming ineligible to receive Medicare and Medicaid reimbursements—which equates to up to 70 percent of the budget for some medical facilities.
Given both the rapidly changing regulatory environment and the changing threats to medical facilities, what follows is a closer look at how decision-makers at medical facilities can identify and mitigate these risks to design a comprehensive workplace violence prevention program:
Key to compliance
According to OSHA guidelines, a thorough workplace violence prevention program should include the following five elements:
- Management commitment and employee participation and engagement
- Work site analysis and hazard identification—including an evaluation of current security posture
- Hazard prevention and control
- Safety and health training encompassing hazard recognition and response procedures and protocols
- Record keeping and program evaluation, including incident tracking, training, assessments, etc.
It is critical that all five of these elements work together as part of a cohesive and interrelated whole. If any of these five pieces are missing, the facility’s ability to minimize and mitigate workplace violence could be compromised.
It is important to remember that the CMS Final Rule also has specific requirements organizations must meet. For instance, active shooter protocols and drills are required as part of the CMS Final Rule, but not under OSHA guidelines.
Define and assess risks
The first step that administrators and decision-makers should take is an extensive risk assessment conducted by a trained security expert. Outside perspective is helpful to ensure that internal security/risk management personnel do not consciously or subconsciously underestimate risk mitigation liabilities in an effort to validate their own efforts.
A security professional with demonstrated experience in the healthcare space should conduct an exhaustive on-site assessment that includes both an independent perspective and a detailed series of interviews with facility personnel. Subsequently, he or she will be able to assign a risk level that accounts for site- and facility-specific impact potential and considers a wide range of factors, including schedule, security protocols and other operational realities (equipment, services, staffing levels, etc.), geographic threats like regional crime levels, and other internal and external data points.
Size, location, and focus impact risks
The size, location, and nature of the healthcare facility can significantly impact the nature of the risk factors at play and can increase vulnerability to certain types of threats. For instance, if the only urgent care facility in 50 miles can’t operate because of a threat or a violent incident, that could create a potentially dangerous situation.