Failure to prepare and maintain a “best practices” active shooter response protocol may result in charges of neglect and fraud and cause the submission of false claims
Compliance Perspective – Active Shooter
Policies/Procedures: The Compliance and Ethics Officer with the Administrator will review the Active Shooter Response section in the facility’s Emergency Preparedness Plan.
Training: The Compliance and Ethics Officer with the Administrator will ensure that all staff are trained to respond to an active shooter situation according to the facility’s active shooter response protocols.
Audit: The Compliance and Ethics Officer with the Administrator should personally conduct periodic active shooter drills to ensure staff competency in implementing active shooter response protocols.
ACTIVE SHOOTER PREVENTION AND RESPONSE
An FBI study several years ago reported that active shooter incidents were becoming more frequent, and healthcare facilities were among the most likely places for a shooting to take place. The Special Agent and Director of the FBI’s Active Shooter Initiative at the time said the study “demonstrated the need not only for enhanced preparation on the part of law enforcement and other first responders, but also for civilians to be engaged in discussions and training on decisions they’d have to make in an active shooter situation.”
After a recent incident in an Illinois hospital, the Office of the Asst. Sec. for Preparedness and Response echoed the FBI’s sentiments. They are encouraging healthcare providers to review the government’s “Planning and Response to an Active Shooter: An Interagency Security Committee Policy and Best Practices Guide.” 
In the Illinois shooting, a pharmacist, police officer and an emergency room doctor were all killed by a gunman. Additionally, there have been five other shootings in or around healthcare facilities across the country this year.
“While we can’t predict such an event, we can improve our awareness,” the office said in an email. “It is critical for you to prepare your facility and staff as thoroughly as possible for the threat of an active shooter through your emergency response planning.”
