Potential Impacts of Sentinel Event Alert No. 57 On Healthcare Security

On March 1, 2017, the Joint Commission issued Sentinel Event Alert No. 57, “The Essential Role of Leadership in Developing a Safety Culture.” While on the surface, this alert seems to speak more to safety, healthcare security practitioners should consider the potential impact this alert could have on their healthcare organization’s security programs, especially since this alert is highlighting some key action items regarding the Joint Commissions leadership standards.

Let’s begin with who the Joint Commission considers to be a “leader.” Per SEA No. 57:

• “An individual who sets expectations, develops plans, and implements procedures to assess and improve the quality of the organization’s governance, management, and clinical and support functions and processes. At a minimum, leaders include members of the governing body and medical staff, the chief executive officer and other senior managers, the nurse executive, clinical leaders, and staff members in leadership positions within the organization.”

If you are responsible for the security of your healthcare facility or campus, then chances are you fall under this rather broad category.

It should also be noted that this is not the first time the Joint Commission has specifically focused on this standard. In July 2008, they issued TJC Sentinel Event No. 40, “Behaviors That Undermine a Culture of Safety” in preparation of this then new standard LD 03.01.01 – “Leaders create and maintain a culture of safety and quality throughout the hospital,” which went into effect Jan. 1, 2009. This preliminary SEA No. 40 focused primarily on two elements of performance of the standard (EP 4 and EP 5), while this latest iteration of SEA No. 57 includes EP 1, “Leaders regularly evaluate the culture of safety and quality using valid and reliable tools.”

Element of performance No. 1 is of direct concern to the healthcare security leader as this can be interpreted to mean the types of security assessments, surveys and tools that are being used to determine appropriate levels of and types of security. Aside from the annual hazard vulnerability that everyone must complete, security leaders should consider “just in time” tools such as OSHA’s workplace violence checklist or the National Center for Missing and Exploited Children’s “Self-assessment for Health Care Facilities” tool.

Element of performance No. 4 is “Leaders develop a code of conduct that defines acceptable behavior and behaviors that undermine a culture of safety.” This element speaks directly to your organizational policies, procedures and practices on topics such as what constitutes workplace violence and/or threatening behavior involving your employees. EP No. 5, “Leaders create and implement a process for managing behaviors that undermine a culture of safety,” follows up on EP No. 4 by determining how often such policies and procedures are taught and in what manner the information is disseminated. For example, is such education provided just once at initial employee orientation, or is security provided a role in the organization’s annual continuing education efforts?

Considering the current scope of workplace violence in the healthcare industry and the attention that it has garnered, this element of performance should definitely be looked at closely to make sure that all reasonable efforts are being made to educate employees based on up-to-date assessment findings (per EP No. 1) and current best practices/regulatory requirements. In fact, one year after SEA No. 57, the Joint Commission issued Sentinel Event Alert No. 59, “Physical and Verbal Violence Against Health Care Workers,” which reinforced the need for a culture of safety to protect caregivers and providers.

Take as an example the OSHA General Duty Clause, which reads in part, “Each employer shall furnish to each of his employees’ employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees.” This seemingly innocuous clause has been used with increasing success in recent years by OSHA surveyors to fine healthcare facilities for a lack of adequate and reasonable security measures and education to prevent workplace violence, which is a known hazard in our industry.

This practice has been bolstered recently with the landmark ruling of Secretary of Labor v. Integra Health Inc. in March of 2019. In this case involving the 2012 murder of a social worker by one of her clients, the Department of Labor issued a citation alleging that Integra “violated the OSHA general duty clause since its employees were exposed to the hazard of being physically assaulted by clients with a history of violent behavior.” After the company protested that such an incident was not a recognizable hazard as no one could predict a criminal assault by a third party, the Occupational Safety and Health Review Commission upheld the ruling stating in part that due to the client population being served and the violent history of the client in question, it was a recognized hazard and more should have been done to prevent the incident from occurring. The secretary went on to suggest the following as steps employers should take to abate workplace violence:

• Creating a written workplace violence prevention program with mandatory reporting requirements;
• Identifying clients with violent behavior/histories (including via criminal background checks);
• Clearly communicating behavioral histories/recent violent incidents to any employee who could potentially be exposed;
• Creating and implementing double coverage (a buddy system) when necessary to deal with a potentially violent client; and
• Providing all staff with a reliable way to summon assistance when needed, including while on a home visit.

We, as healthcare security professionals, should research the potential impacts of Sentinel Event Alert No. 57, compare it to the recent interpretations of the OSHA General Duty Clause in our industry and be prepared to add it to our toolbox as a reference when we are called on to validate resources and “prove our value” as a business enabler.

Bryan Warren, MBA, CHPA, CPOI is a healthcare security consultant, author and speaker and is president/chief consultant of War-Sec Security.