C.o.P.s and Cops: Train Your Off-Duty Law Enforcement Officers or Else

Hospitals often employ off-duty law enforcement officers as supplemental security, but many may be doing so at their own risk. Any person employed by a health-care facility must learn about CMS’ Conditions of Participation (C.o.P.s), as well as the proper application of patient restraints and use of restrictive interventions.

Consider Developing Your Own Program
Should a hospital develop its off-duty law enforcement training program by itself or hire a consultant? This decision depends on several factors, one of which is what type of security force the organization currently deploys. If it is proprietary, then the campus must examine the pros and cons of using in-house resources. Proprietary security could be less expensive, and the off-duty officers may already be known to many employees.

An outside consultant can be hired to create such a program. A benefit to this approach is that the program is already completed and little-to-no internal resources are required. On the down side, using a consultant may be expensive, and the hospital may not have as much control over content. If a hospital uses a contract agency as its security force, the company might then offer such programs or be willing to have one of its employees assist with the creation of the program.

Education Programs Come in All Shapes, Sizes
Training can take many different forms. There are formal lecture types of programs (with or without PowerPoint presentations) that can be provided to a large audience. Smaller “lunch and learns” can be provided to an individual department or section of an organization (such as the emergency department). Self-learning modules or informational materials can be easily disseminated to a targeted audience.

Many health-care organizations use Web technologies for the sharing of information internally, and this is a great vehicle for educating staff while they are on the job. It also documents that the instruction took place. For organizations without such a network, the tried and true method of hand-outs and post-tests works well for disseminating information (especially at facilities with a smaller workforce).

It should be noted, however, that there must be a process to demonstrate all off-duty law enforcement personnel working at the facility received such training and have a clear understanding of its content. Written examinations on each topic with minimal acceptable scores is one method (for example, requiring all employees take post-tests and score at least 90 percent on each subject). These should be combined with regular competency assessments to ensure that participants retain the material. Those who fail such post-tests or competency surveys would be suspended from duty until they could demonstrate an acceptable level of aptitude and comprehension of the subject matter.

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