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Active shooter and workplace violence preparedness and response: A compliance perspective

Ann McCullough (amccullough@polsinelli.com) is a Shareholder in the Denver office of Polsinelli, Tracey L. Klein (tklein@polsinelli.com) is a Shareholder in the Chicago office of Polsinelli, and Kathleen Snow Sutton (ksnowsutton@polsinelli.com) is an Associate in the Denver office of Polsinelli.

On November 19, 2018, four people were killed in a shooting at Mercy Hospital in Chicago. On May 13, 2017, a patient obtained a handgun, held four nurses hostage, and sexually assaulted one of them.[1] Unfortunately, these horrific situations are not unique. Healthcare is particularly vulnerable to violence in the workplace.[2] According to the Bureau of Labor Statistics, 70% of the victims of workplace violence were healthcare or social service workers.[3] The Joint Commission (TJC) reported that, in 2017, “criminal events,” such as shootings, homicide, physical assault, and sexual assault was the seventh most common sentinel event,[4] up from number nine in 2016.[5]

Compliance professionals have a role in developing policies and processes to prevent and respond to workplace violence. Federal law requires healthcare organizations to provide a safe working environment for employees and to manage safety and security risks.[6] ,[7] The Occupational Safety and Health Administration (OSHA) and TJC have issued guidance on steps that healthcare organizations can take to prepare for, prevent, and respond to workplace violence. Both OSHA and TJC recommend that healthcare organizations develop and implement policies and training to address violence; analyze the worksite to determine risks, including tracking reports of violence or threats of violence; develop processes to prevent and control incidents; provide support for victims; and evaluate the program and policies to reduce incidents and root causes. These resources, however, do not provide direct guidance for compliance professionals in addressing policies and processes regarding active shooters.

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