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HHS Releases Guide to Help Health Care Facilities Prepare for Active Shooter Incidents

on Monday, 19 January 2015 in Health Law Alert: Erin E. Busch, Editor

The Department of Health and Human Services’ Office of the Assistant Secretary for Preparedness Response recently released a guide to help health care facilities incorporate active shooter planning into their emergency operations plans. Publication of the guide comes at a time of enhanced focus on national preparedness efforts, following the signing of the Presidential Policy Directive 8: National Preparedness in March 2011. The guide does not establish any new requirements, but is intended to facilitate discussion and assist in institutional planning.

Recognizing that health care facilities face several challenges in their emergency planning efforts, the guide stresses the importance of having emergency plans in place, training staff, working with first responders and reacting quickly in emergency situations. To achieve these objectives, the guide offers several recommendations, including the following:

  • Construct a plan with input from internal and external stakeholders. The guide lists elements of an effective plan, and suggests specific issues for discussion related to lockdown, evacuation routes, shelter-in-place locations, and staff training.
  • Create a facility security plan and practice its practicability. The guide suggests appropriate contents of a security plan and evidence-based strategies for implementation, including using plain language—not just code—to communicate in emergencies.
  • Train staff to identify signs of potentially volatile situations to enhance prevention and detection. The guide outlines pre-attack behavior that could be indicators of concern.
  • Establish a Threat Assessment Team with diverse representation to ensure warning signs observed by multiple people are examined and addressed, and to develop a course of action.
  • Practice drills of active shooter incidents. The guide provides specific examples of “Run, Hide, Fight” and also stresses the importance of helping staff overcoming denial and delay to respond quickly.
  • Work with staff to interact with first responders in a cooperative way, that will help law enforcement gain information quickly and neutralize the threat. The guide suggests training with community partners, sharing emergency plans, and providing critical information before an incident occurs, such as location of utility controls, medical supplies, fire extinguishers, and how to access secure areas in the health care facility.
  • Engage in appropriate activities after the active shooter incident, including implementation of a mass casualty plan and post-event assessments. The guide offers strategies to provide care to family members of victims, and highlights psychological first aid training.
  • Ensure that HIPAA and other state and federal laws are not violated. Appendix A to the guide outlines how HIPAA applies in active shooter scenarios.

Health care facilities should work to develop emergency operation plans that promote the protection of life and preservation of property, and ensure that the plan can be executed by staff when needed. This guide provides strategies that health care facilities can use to facilitate open discussions with stakeholders, and to create and execute an effective emergency operations plan. The guide is available here.

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