Failing to satisfy the Centers for Medicare and Medicaid Services (CMS) Conditions of Participation (CoPs) has serious consequences for a hospital. Non-compliance leads to an "immediate jeopardy" status, which indicates a patient is likely to suffer serious injury or death, or such has already occurred. If unresolved, this can also lead to the loss of participation in the Medicare and Medicaid program.
An article in Campus Safety calls out several CoPs as having particular implications for a hospital's security staff.
The right to personal privacy: This impacts the security department in terms of the use of surveillance equipment. CCTV and other such technology is generally fine in non-patient care areas, the article says. However, in patient care areas surveillance should only be used where there is an extreme need for continuous observation.
The right to receive care in a safe setting: This CoP requires the security department to take appropriate measures to safeguard especially vulnerable patients, such as infants and those with behavioral health issues. Protecting emotional as well as physical health and safety are covered by this condition.
The right to be free from abuse or harassment: When a patient must be restrained, special care must be taken that no abuse takes place. Security staff should be trained on when and how to interact with patients, and to use alternatives to physically touching patients in order to subdue them.
A major consideration for complying with this CoP is that use of a weapon is never considered appropriate by CMS as part of a healthcare intervention. Use of a weapon is only appropriate in a healthcare setting as a response to criminal activity, says the article. Also considered inappropriate by CMS is the use of handcuffs and other law-enforcement restraints outside of a law enforcement action.
Read the article.