First off, a mea culpa. It turns out that there was an educational presentation by CMS to (nominally) discuss the final Emergency Preparedness rule, with a focus on the training and testing requirements (you can find the slide deck here; the presentation will be uploaded sometime in the next couple of weeks or so) and I neglected to make sure that I had shared that information with you in time for you to check it out. My bad!
That said, I don’t know that it was the most compelling hour I’ve ever spent on the phone, but there were one or two (maybe as many as three) aspects of the conversation that were of interest, bordering on instructive. First off, when the final rule speaks to the topic of educating all staff on an annual basis, the pudding proof is going to be during survey when staff are asked specific questions about their roles in your plan (presumably based on what you come up with through the hazard vulnerability assessment—HVA—process). Do they know what to do if there is a condition that requires evacuation? Do they know how to summon additional resources during an emergency? Do they know what works and what doesn’t work as the result of various scenarios, etc.? This is certainly in line with what I’ve seen popping up (particularly during, but not limited to, CMS/state surveys)—there is an expectation (and I personally can’t argue against this as a general concept) that point-of-care/point-of-service staff are competent and knowledgeable when it comes to emergency management (and, not to mention, management of the care environment). As I’ve noted to I can’t tell you how many folks, the management of the physical environment, inclusive of emergency preparedness/management does not live on a committee and it is not “administered” during surveillance rounds or during fire drills. Folks who are taking care of the patients’ needs to know what their role is in the environment, particularly as a function of what to do when things are not perfect (I’ll stop for a moment and let you chew on that one for a moment).
Another expectation that was discussed (and this dovetails a wee bit with the last paragraph) is that your annual review of your emergency preparedness/management process/program must include a review of all (and I do mean all) of the associate/applicable policies and procedures that are needed for appropriate response. So far (at least on the TJC front—I’m less clear on what some of the other accrediting organizations (AO)—might be doing, though I suspect not too very far from this. More on the AO front in a moment), the survey review of documentation has focused on the emergency plan (or emergency operations plan or emergency response plan—if only a rose were a rose were a rose…), the exercise/drill documentation, HVA, and annual evaluation process. But now that the gauntlet has been expanded to include all those pesky policies and procedures. I will freely admit that I’m still trying to figure out how I would be inclined to proceed if I still had daily operational responsibility for emergency management stuff. My gut tells me that the key to this is going to be to start with the HVA and then try to reduce the number of policies and procedures to the smallest number of essential elements. I know there are going to be individual response plans—fire, hazmat, utility systems failures, etc.—is it worth “appendicizing” them to your basic response plan document (if you’ve already done so, I’d be interested to hear how it’s worked out, particularly when it comes to providing staff education)? I’m going to guess that pretty much everybody addresses the basic functions (communications, resources and assets, safety and security, utility systems, staff roles and responsibilities, patient care activities) with the structure of the E-plan, which I guess limits the amount of reviewable materials. There was a question from the listening audience about the difficulty in managing review of all these various and sundry documents and the potential for missing something in the review process (I am, of course, paraphrasing) and the response was not very forgiving—the whole of it has to be reviewed/revised/etc. So, I guess the job is to minimize/compact your response plans to their most essential (the final rule mentions the development of policies and procedures, but doesn’t stipulate what those might be) elements and guard them diligently.
The final takeaways for me are two in number. Number 1: Eventually, there will be Interpretive Guidelines published for the Emergency Preparedness final rule, but there is no firm pub date, so please don’t wait for that august publication before working towards the November implementation deadline. Number 2: While there is an expectation that the AOs will be reviewing their requirements and bringing them into accordance with the CMS requirements, there is no deadline for that to occur. Something makes me think that perhaps they are waiting on the Interpretive Guidelines to “make their move”—remembering it’s not going to be fair any time soon. I think the important dynamic to keep in mind when it comes to our friends at CMS (in all their permutations) is that they are paying hospitals to take care of their patients: the patients are CMS’ customers, not us. Which kind of goes a ways towards explaining why they are not so nice sometimes…
I’ve been watching this whole thing unfold for a really long time and I continue to be curious as to when the subject of managing workplace violence moves over into the survey of the physical environment. I think that, as an industry, we are doing a better job of this, perhaps as much as a function of identifying the component issues and working them through collaboratively as anything, but I don’t know that the data necessarily supports my optimistic outlook on the subject. One think I can say is that our friends at the Occupational Safety & Health Administration are going to be closing out the comment period soon (April 6, to be exact) on whether or not they need to establish an OSHA standard relative to preventing violence in healthcare and social assistance—if you have something to add to the conversation, I would encourage you to do so.
I do think that there are always opportunities to more carefully/thoughtfully/comprehensively prepare the folks on the front lines as they deal with ever greater volumes of at-risk patients (a rising tide that shows little or no sign of abating any time soon). They are, after all, the ones that have to enforce the “law,” sometimes in the face of overwhelming mental decompensation on the part of patients, family members, etc. As an additional item for your workplace violence toolbox, the American Society for Healthcare Risk Management has developed a risk assessment tool (with a very full resource list at the end) to help you identify improvement opportunities in your management of workplace violence. As I think we all know by now, a cookie-cutter approach rarely results in a demonstrably effective program, but what I like about the tool is it prompts you to ask questions that don’t always have a correct or incorrect response, but rather to ask questions about what happens in your “house.”
This topic somehow brings to mind some thoughts I had recently relative to the recalcitrance of some of my fellow travelers (meaning folks I encounter while traveling and not those that might have been encountered during the era of McCarthyism…) when it comes to following the directions of the TSA folks or other “gatekeepers” who keep things moving in an orderly fashion. I have seen folks in suit and tie pitch an absolute fit because they couldn’t skip to head of the line, had three carry-on bags instead of the allowed two, or had liquids in excess of what is allowed. I understand being a little embarrassed in the moment for the bag thing or the liquid thing, but to give the person who identified the issue a hard time makes no sense to me. And I think that sometimes our frontline staff fall victim to this type of interaction and have to suffer the consequences of an unhinged (OK, that may be a little hyperbolic, but I suspect you know what I mean) patron—even if they don’t have to endure someone taking a swing at them during these moments of tension. There was a day when the customer was always right, but now far too often, the customer is nothing more than an entitled bully and we have to make sure that our folks know we have their backs.
…when up pops somebody, eventually…
Interesting story in the news last week about someone infiltrating the perioperative area at a hospital in the Boston area (the news story identifies the hospital, so no need to do that here, IMHO). Every time I see one of these types of stories, it makes me glad that I do not still have operational responsibilities for a hospital security department. (In many ways, I have made something of a career of embracing thankless jobs in the healthcare realm; well, maybe not completely thankless, but it can be tough for folks at the bottom of the healthcare food chain. But enough about that.) Apparently, this individual was able to gain access to the perioperative areas, including the restricted portions, without having an identification badge. Now I will say that, based on my observations, the healthcare industry is much better about wearing ID badges, but I will also say that the OR is a tough spot to practice enforcement of your ID policy, especially during the busy times. And then there is the subject of tailgating, which is a time-honored tradition, particularly when you move to an electronic/badge access solution for controlling who gets where in your organization. And, short of installing turnstiles at all your entry points (now wouldn’t that create some noise?), tailgating is going to continue to be a vulnerability relative to security. Much as learning that the NSA was listening in on lots of conversations, I didn’t find this particular news story, or indeed the event, particularly surprising. In all likelihood it happens more than we know—from salespeople to distressed families to the media, the list of potential candidates for such an incursion is rather lengthy. (I’m sure you can add to that list and please feel free to do so!) The source article for the above story indicates that the individual was identified as an interloper when “physicians caught on” (I could be glib and throw out a “maybe she didn’t know the secret handshake,” but that would be catty), so I guess it’s good to make sure that you have good participation from your medical staff in the matter of ID badge compliance.
All that said, and in full recognition that logic doesn’t always prevail, I have a sneaking suspicion that this might just join active shooter response on the regulatory survey security hot topic list (remember when nuclear medicine deliveries were the flavor of the month?). I think anyone having survey over the next little while would be well-served in considering how to respond to queries regarding access control in your ORs and other areas.
It is a most delicate balance: protecting folks and yet providing access to all the patients we serve. Maybe there will be some grant money floating around that could be used for this purpose—nah!
Patients with high-risk behaviors pose a danger to healthcare staff and other patients and are difficult for healthcare employees to manage. In this live webcast, expert speakers Tony W. York, MS, MBA, CHPA, CPP, and Jeff Puttkammer, M.Ed., will discuss the patient factors that often lead to violent events in the workplace, provide a clear understanding of environmental influences and triggers that contribute to violence, and supply tools and resources to help you reduce the risk of a violent event in your facility. The program is scheduled for Wednesday, January 20 from 1 to 2:30 p.m. ET.
Employees have the power to influence their own safety, but they often lack the proper training. Give your staff the knowledge they need to deal with high-risk patients and keep themselves and their facility safe!
At the conclusion of this program, participants will be able to:
- Define high-risk patient behavior (more than just mental health patients)
- Explain how a balanced approach to patient-focused care and personal safety impacts patient satisfaction and work-related injuries
- Identify how workspace design and medical equipment placement can promote or reduce the safety of staff, patients, and visitors
- Define policies, procedures, and practices aimed at reducing safety risks associated with at-risk patients
- Understand the critical role staff education and training plays in helping provide the culture, tools, and competencies required to successfully reduce and manage patient-generated violence
While the events of recent weeks seem to focus our attentions on the darker side of humanity, before jumping into this week’s “serious” topic, I did want to take a moment to wish you all a most joyous Thanksgiving. Your continued presence in this community is one of the things for which I am thankful, so I will, in turn, thank each one of you for that presence—without you, there wouldn’t be much purpose to this little rant-o-rama! And a special thanks to Jay Kumar from HCPro, who manages to keep things going!
And so, onto the business at hand. In the aftermath of the Paris terror attacks, the folks at the Department of Homeland Security are encouraging hospitals and other healthcare organizations to review our security plans and to work towards exercising them on a regular basis (you can read the full notice here). The notice contains a whole bunch of useful information, including indicators to assist in identifying suspicious behaviors and to build a truly robust process for reporting suspicious activity. It’s always tough to say how much of an event could have been prevented if folks were more skilled in identifying threats before they are acted upon, but I guess we always have to use such events as a means of improving our own situations. At any rate, I think it would behoove everyone in the audience to take a look at the materials referenced in the notice. A lot of times, I think we find ourselves “casting about” for direction when it comes to the practical application of how we become better prepared, particularly in the healthcare world of competing priorities. I also know that it is sometimes challenging to get folks to seriously participate in exercises—I don’t know that we’ll ever completely get away from having to deal with what I will characterize as moderate indifference. The events in Paris (and Mali) only point out that this is a risk shared by everyone on the planet, whether we would want it or not. And the more we educate folks to recognize threatening situations, the better able they will be to keep themselves safe. I wish there were a simple solution to all this, but in the meantime, the strategy of increased vigilance will have to do.
Every once in a while I like to dip into the ol’ mail bag when I get a question that I either haven’t answered before or conditions/practices have changed enough to update an initial response. In this particular instance, we’re covering some territory that I’m pretty sure we’ve not aired previously (as near as I can tell…).
Q: I would like to get your take on patient elopement (or simply leaving without signing, or refusing to sign AMA forms), and the longstanding practice of having security staff, maintenance staff, etc., pursue these patients. These types of things make corporate legal departments cringe, and it leaves Plant Operations directors caught in the middle of “should we respond or not” debates.
A: Thanks for your question. I really think that your description of the reaction of legal departments to the “pursuit” of eloped/eloping patients is pretty much on the money and that’s why (in my mind), they are the ones that need to be the determining factor when establishing a response protocol for elopement. I have certainly worked with organizations for whom a “simple pursuit” protocol has ended very badly with patients injured, and in a couple of instances, worse (I’ll refrain from the details) during response to an elopement. Someone who is eloping tends to want to elude (or otherwise outrun) their pursuers and sometimes they’re not paying attention to where they are going (I liken it to chasing a toddler—the “state of mind” of some of your elopers is not so very far from a toddler—they spend a lot of time looking over their shoulder and not looking where they are going). At the hospital at which I used to work, the legal folks said if the patient eloping leaves the property, then you let them go and call the local authorities (recognizing that their response is going to be dependent on what’s going on in the community) and work (which you can certainly interpret to mean “hope) towards a good outcome. Unless someone is really mentally incapacitated, you can usually figure out where they are going, so that becomes information that can be shared with law enforcement.
All that said, it is of critical importance to have a specific response plan (you can leave a little leeway for specific cases, but you really need to have a consistent overall approach) that has been developed in collaboration with clinical (including physicians), legal, and support leadership. Everyone has to be on the same page if we are not going to be putting anyone (and that includes the folks responding) at risk.
I know this is something that faces healthcare organizations all across the country including, I suspect, some of the folks out there in the audience. So I put the question to you: How are you managing response for eloped patients? Is it a “let them go and call the cops” response protocol or more of a “bring ’em back” response? I suspect that we could have some interesting dialogue on this one, so please weigh in as you can.
In a February 18 Joint Commission leadership blog post, Mark Crafton, TJC’s executive director of communications and external relations, focuses on the benefits of investigating different approaches for mitigating violence in hospitals. At least that’s where the conversation starts, but it ends up in kind of an interesting (and to my eyes, unexpected) direction: the question of whether hospital security officers are a more effective deterrent/mitigation strategy when they are armed. (N.B.: In Crafton’s post, he refers to security “guards”; call me whatever you like, but I think the term “guard” just doesn’t ring well with me. I’m okay with the terms “security staff” or “security officers,” but “guards” just gives me the vapors—metaphorically speaking, of course.)
In the course of the posting, Crafton points to an article in the Chattanooga Time Free Press that will likely generate some debate among healthcare security professionals, and I tend to agree with that thought. Apparently the article was the result of a healthcare system’s decision to disarm their security staff and adopt the “soft” uniform look (e.g., blazers, etc.) to more effectively emphasize the security officer’s role as a more customer-oriented (my description) countenance. Now we’ve touched on the subject of arming security officers in the past (it’s been a really long time) and it’s probably way past the time for looking at this topic, particularly as the good folks at CMS have some rather strong thoughts on the subject:
CMS does not consider the use of weapons in the application of restraint or seclusion as a safe, appropriate health care intervention. For the purposes of this regulation, the term “weapon” includes, but is not limited to, pepper spray, mace, nightsticks, tazers, cattle prods, stun guns, and pistols. Security staff may carry weapons as allowed by hospital policy, and State and Federal law. However, the use of weapons by security staff is considered a law enforcement action, not a health care intervention. CMS does not support the use of weapons by any hospital staff as a means of subduing a patient in order to place that patient in restraint or seclusion. If a weapon is used by security or law enforcement personnel on a person in a hospital (patient, staff, or visitor) to protect people or hospital property from harm, we would expect the situation to be handled as a criminal activity and the perpetrator be placed in the custody of local law enforcement.
The use of handcuffs, manacles, shackles, other chain-type restraint devices, or other restrictive devices applied by non-hospital employed or contracted law enforcement officials for custody, detention, and public safety reasons are not governed by this rule. The use of such devices are considered law enforcement restraint devices and would not be considered safe, appropriate health care restraint interventions for use by hospital staff to restrain patients. The law enforcement officers who maintain custody and direct supervision of their prisoner (the hospital’s patient) are responsible for the use, application, and monitoring of these restrictive devices in accordance with Federal and State law. However, the hospital is still responsible for an appropriate patient assessment and the provision of safe, appropriate care to its patient (the law enforcement officer’s prisoner).
As you can well imagine, equipping security staff with weapons of almost any stripe can result in the classic slippery slope. My personal practice was to have a clear delineation between security staff and law enforcement responders. Security staff were provided ongoing crisis management education and worked closely with clinical staff to proactively manage at-risk situations. Law enforcement response was summoned when appropriate and the use of weapons was solely at the discretion of those responders. I know those lines can get pretty blurry in the heat of the moment, but specific roles are, I think, the best starting point for an effective security program.
At any rate, Crafton goes on to discuss the following: the cases for armed/not armed security staff; armed staff as authority figures vs. armed staff as a potential for raised anxiety of patients who are already distressed/stressed; and how do you make patients and staff safe, etc. There are, of course, good arguments on both sides, but ultimately (and this is one of the common threads when it comes to TJC standards and expectations), it is the responsibility of each organization to determine how best to manage, in this case, security risks. It doesn’t seem likely that peace, love, and understanding are going to be breaking out any time soon; the role of the security officer has never been more important.
As you are all no doubt familiar, sometimes those educational topics surrounding safety can come across as a bit dry and that dryness all too frequently ends up being the focal point of safety presentations. Now, one of the fun little quirky things that you run into when flying is that every time you get on a plane, you have to go through orientation (if only we as healthcare safety professionals could “capture” an audience as frequently as the airlines do) and sometime those orientations are very much less than compelling. And so, I thought that you might find the following offerings from NPR and The Telegraph of some interest, entertainment, and perhaps some inspiration. As I like to say during my consulting visits, this stuff doesn’t have to be torture. At any rate, I hope you enjoy these, and maybe you’ve got some homegrown footage you’d want to share (or perhaps already have shared); there’s no reason we can’t all partake of such splendor.
I don’t hear too many stories like this anymore, but I can tell you, as a former manager of security services at a hospital, this is one that really gives me pause.
In September, at a hospital out in San Francisco, a patient disappeared from her room, after which a search ensued with no result. The awful thing is that the patient was found in a locked stairwell about two weeks later by an engineering staff member doing rounds. You can find the San Francisco Examiner story that caught my eye (as well as several related stories).
Now I’m sure the investigation will yield some indication of what happened, but I’m also thinking that the whole story may never be revealed. Was that stairwell inspected prior to the point when the engineering staff person made their rounds? How was the search conducted? Was there a conscious decision to limit the search to unsecured areas? At what point do you suspend the search?
I’m certainly not going to Monday-morning quarterback such an awful circumstance, but the question I ask myself is this: can you stop looking when you’ve not found the person you’re looking for? Again, it’s my understanding that the stairwell in question was secured, but how many times have you encountered a security system that was absolutely impregnable—my experience has been that the human element is all too frequently the means of defeating the certain security measure. So has this particular tragedy caused anyone to look at, or even rethink, their search protocols? Are there areas you might not consider as being accessible that might warrant at least inclusion in a comprehensive search grid? I’d be interested in what you all think about this one.