Employee Management

 

 

https://sm.asisonline.org/Pages/Federal-Misconduct.aspxFederal Misconduct2018-11-01T04:00:00Zhttps://adminsm.asisonline.org/pages/mark-tarallo.aspx, Mark Tarallo<p>​Dealing with employee misconduct is never a pleasant task for any manager, including security managers. If the workplace happens to be part of the U.S. federal government, that task can be even trickier.</p><p>U.S. regulations specify the formal legal process that most federal agencies must follow when taking disciplinary action against employees for acts of misconduct. There are also regulations on the built-in procedural rights that many federal employees are entitled to when faced with these actions. Depending on the nature of misconduct, however, a federal agency sometimes may use alternative disciplinary approaches, instead of the formal legal process. </p><p>The U.S. Government Accountability Office (GAO) was recently asked to examine how federal agencies address employee misconduct. It found that, in 2016, federal agencies formally disciplined an estimated 17,000 employees for misconduct, or less than 1 percent of the federal workforce. Based on Office of Personnel Management (OPM) data, federal agencies made 10,249 suspensions, 7,411 removals, and 114 demotions for misconduct.</p><p>As part of its report, Federal Employee Misconduct: Actions Needed to Ensure Agencies Have Tools to Effectively Address Misconduct, GAO asked management experts for promising practices based on lessons learned from real workplace situations that federal agencies could use to respond to employee misconduct. These recommended best practices included:</p><p>•  Senior agency officials should strive to set positive conduct examples, because the "tone at the top" is influential in employee misconduct.</p><p>•  Additional training would help supervisors identify and deal with misconduct, so agencies should sponsor ongoing training for managers. Also, supervisors should be held accountable for identifying misconduct and responding to it in a timely manner. </p><p>•  Internal collaboration is key to effectively addressing misconduct. Effective lines of communication and collaboration between human resources staff, line-level management, and legal counsel must be maintained.</p><p>•  Managers should actively engage employees and set clear rules and expectations regarding employee conduct, including specifics on applicable standards of conduct.</p><p> These best practices, however, are not being followed in some agencies. Some federal managers are not adequately addressing misconduct because they are unfamiliar with the disciplinary process, have insufficient training, or do not receive proper support from their human resources offices, the report found.</p><p>In its report, the GAO recommended that OPM better leverage these best practices to help agencies address misconduct and improve its guidance on training supervisors to address misconduct. OPM concurred with the recommendations.   </p><p> </p>

Employee Management

 

 

https://sm.asisonline.org/Pages/Federal-Misconduct.aspx2018-11-01T04:00:00ZFederal Misconduct
https://sm.asisonline.org/Pages/Career-in-Security-Pathways.aspx2018-11-01T04:00:00ZCareer Pathways in Security
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https://sm.asisonline.org/Pages/An-Investment-in-Employees.aspx2018-10-01T04:00:00ZAn Investment in Employees
https://sm.asisonline.org/Pages/Integrating-Robots-in-the-Workplace.aspx2018-09-26T04:00:00ZIntegrating Robots in the Workplace
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https://sm.asisonline.org/Pages/Lessons-in-Violence-Prevention.aspx2018-09-01T04:00:00ZLessons in Violence Prevention
https://sm.asisonline.org/Pages/Harassment-in-the-Academies.aspx2018-09-01T04:00:00ZHarassment in the Academies
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https://sm.asisonline.org/Pages/Checking-In-and-Coaching-Up.aspx2018-07-01T04:00:00ZPerformance Conversations: Checking In & Coaching Up
https://sm.asisonline.org/Pages/Bully-Bosses-Can-Inflict-More-Damage-with-Negative-References.aspx2018-05-17T04:00:00ZBully Bosses Can Inflict More Damage with Negative References
https://sm.asisonline.org/Pages/How-to-Lead-a-Diverse-Security-Workforce.aspx2018-05-01T04:00:00ZHow to Lead a Diverse Security Workforce
https://sm.asisonline.org/Pages/Stopping-Distracted-Driving.aspx2018-04-01T04:00:00ZBehind the Wheel: Stopping Distracted Driving
https://sm.asisonline.org/Pages/Identify-the-Gaps.aspx2018-04-01T04:00:00ZIdentify the Gaps
https://sm.asisonline.org/Pages/Four-Trends-That-Will-Shape-Recruiting-in-2018.aspx2018-03-22T04:00:00ZFour Trends That Will Shape Recruiting in 2018
https://sm.asisonline.org/Pages/Coachable-Employees.aspx2018-03-01T05:00:00ZCoachable Employees
https://sm.asisonline.org/Pages/Fair-and-Neutral.aspx2018-03-01T05:00:00ZFair & Neutral

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https://sm.asisonline.org/Pages/A-Brief-History-of-Bullying.aspxA Brief History of Bullying<p>​Bullies have always been a part of any group development, from the earliest civilizations, and in religions, militaries, schools, neighborhood cliques, teams, families, and companies. </p><p>The workplace bullying phenomenon, as we know it today, first entered the public consciousness on the heels of the workplace sexual harassment issue in the early 1980s. During that decade, Swedish psychologist Heinz Leymann was among the first to conceptualize and analyze the act of workplace bullying. In the early 1990s, British journalist Andrea Adams popularized the term “workplace bullying” through a series of BBC radio documentaries. </p><p>In the United States, bullying first became a major issue in the public sector, with some schools and government agencies taking an avid interest in safeguarding against it. Later, this interest spilled over into private sector workplaces. During the early to mid-1990s, more American researchers began studying the problem of psychologically abusive behaviors at work and the harm they create. Another driver of interest in the private sector was the growing concern about the costs of workplace bullying to a company’s bottom line.  </p><p>Today, workplace bullying incidents are four times more common in all U.S. organizations than sexual harassment episodes, and the related costs to businesses are also four times higher. In behavioral studies, bullying is now often closely linked to suicide and violence. The seriousness of the problem warrants that employers implement a sensible duty of care program in response.</p>GP0|#cd529cb2-129a-4422-a2d3-73680b0014d8;L0|#0cd529cb2-129a-4422-a2d3-73680b0014d8|Physical Security;GTSet|#8accba12-4830-47cd-9299-2b34a4344465
https://sm.asisonline.org/Pages/Lessons-in-Violence-Prevention.aspxLessons in Violence Prevention<p>​It has happened at an outdoor concert in Las Vegas. A work meeting in San Bernardino, California. A nightclub in Orlando. A high school in Parkland, Florida. A church in Sutherland Springs, Texas. An elementary school in Newtown, Connecticut. A movie theater in Aurora, Colorado. An Army base in Fort Hood, Texas. A college campus in Blacksburg, Virginia. And a newsroom in Annapolis, Maryland.</p><p>We can't forget Umpqua Community College in Roseburg, Oregon; the Emanuel African Baptist Church in Charleston, South Carolina; the U.S. Navy Yard in Washington, D.C.; an adult school classroom in Binghamton, New York; a restaurant in Killeen, Texas; a McDonald's in San Ysidro, California; post offices in Dana Point, California; Edmond, Oklahoma; Escondido, California; and Royal Oak, Michigan; a law office in San Francisco; and a beauty salon in Seal Beach, California.</p><p>The first modern-day mass shooting in the United States occurred in 1966 when Charles Whitman killed 16 people and wounded 30 with a rifle from the clock tower on the University of Texas (UT) Austin campus. His murder spree remains one of the top 10 deadliest active shooter attacks in the United States. And active shooter incidents are on the rise—a new FBI report found that 2017 saw the most incidents and most people killed in any one year since 2000.</p><p>Active assailant events have killed too many people to still refer to such workplace violence, school campus violence, or mass shootings in public places as rare. But while horrific incidents in the last several years make the news and keep police, politicians, parents, business owners, and employees awake at night, recall that this has been going on since Whitman fired that first shot from the UT clock tower so long ago. What has happened then will certainly happen again, despite the best efforts of law enforcement responders and security professionals around the country and internationally. These cases deeply scar the cities, schools, campuses, and communities where they happened, forever. The anniversary dates get further and further out as the years and even the decades pass, but no one associated with these events ever forgets. </p><p>How safety and security officials plan for and respond to these incidents, though, has continuously evolved over the decades, and will continue to do so as new research, best practices, and lessons learned are adopted.</p><p>Ticking bombs. Defusing Violence in the Workplace—which the author co-wrote in 1994 with then-San Diego Police psychologist Dr. Michael Mantell—was one of the first business books on active shooters. The book set out a 21-step profile of a potential workplace shooter based on many of the cases that happened up to 1994—usually at U.S. Post Office facilities. The postmaster general at that time even wrote the foreword for our book, showing how attached experts were to the idea that workplace violence was mostly committed by white males in their 30s to 50s, with a military history and access to guns. </p><p>However, it soon became clear how wrong these profiles were. The April 1999 Columbine High School shooting changed collective thinking away from the focus on profiles toward the current emphasis on preattack behaviors and information leakage to third parties about the attackers' preferred targets and plans.</p><h4> Evolving Perceptions</h4><p>For threat assessment experts and security management professionals, the shootings that took 13 lives at Columbine High School were the equivalent to the 9/11 attacks—they completely changed the thinking about how to respond to these types of events. Much like the United States' post-9/11 terrorism fight around the world, engaging an active shooter on sight became the new normal post-Columbine.</p><p>Law enforcement had to change its tactical response to what were now being called active shooters, because at Columbine there were multiple perpetrators who were not there to take hostages and make demands, but to kill others and then themselves. Security experts will never forget hearing recordings of shots fired and the anguished cries inside those buildings as the officers on scene followed their usual protocol: set up a perimeter and wait for the SWAT team to arrive. </p><p>Columbine taught security practitioners about preattack behaviors, the leakage of information by the perpetrators, and the need for arriving police officers to respond quickly, form into tactical teams, and use whatever firearms they had to enter the building and stop the attackers. This model has become standard police procedure for active shooters and mass attackers at schools and businesses in the United States.</p><p><strong>Research and models. </strong>Two U.S. Secret Service (USSS) reports—Protective Intelligence and Threat Assessment Investigations from 2000 and the 2004 Safe School Initiative, authored by USSS Supervisory Special Agent Bryan Vossekuil and psychologists Dr. Robert Fein and Dr. Marisa Reddy—have contributed immensely to the understanding of planned attacks against protected targets, workplace violence, and school violence prevention. These two comprehensive reports should be studied by every security practitioner who faces the potential for violence at their facilities. </p><p>Protective Intelligence and Threat Assessment Investigations was also known as the Exceptional Case Study Project (ECSP) because it focused on data from assassinations of political figures as far back as Abraham Lincoln in 1865, as well as research into school and workplace violence attacks and interviews of surviving political assassins and school and workplace attackers in prison. </p><p>The ECSP laid out the concept that some people make threats and some people pose threats. There should be more focus on people who pose threats and less on those who just make verbal or written threats, because the presence of such threats is not the best indicator of a pending attack. The ECSP also discussed the idea that people who engage in lethal violence often engage in third-party leakage—they warn other people such as coworkers, family members, or students of their plans, but not the targets they intend to harm. The student that wants to shoot his teacher rarely directly threatens that teacher, because it would lead to consequences such as being arrested or suspended, thereby interrupting the opportunity to attack.  </p><p>In the early years of threat assessment and management, there was a tendency to overreact to direct verbal or posted threats and underreact to third-party threats. While all threats need to be investigated, the new emphasis is on listening more closely for these leakage events, and training employees and students to have the courage to report them to the safety and security stakeholders for the business or school.</p><p>The Safe School Initiative, also coauthored by Dr. Randy Borum from the University of South Florida and Bill Modzeleski from the U.S. Department of Education, offered the conclusion that there is no known or useful profile of a school shooter. This research also showed that most perpetrators are on a path from ideas to actions, meaning they follow a distinct process that starts with a grievance, followed by a violent ideation that may last for weeks, months, or even years. They begin to make a plan, acquire or practice with a weapon, stalk their targets, make a series of dry runs, and then attack.</p><p>Two recent reports by the FBI's Behavioral Analysis Unit expand on this concept, detailing preattack behaviors of active shooters based on a study of incidents from 2000 to 2013. The active shooters examined in the study could not be identified prior to attacking based on demographics alone, but concrete patterns emerged in their preattack behaviors. A majority of attackers acquired their firearms legally, and more than three-quarters of attackers spent a week or more preparing. The average attacker had experienced multiple stressors in the year before they lashed out, but only 25 percent had ever been diagnosed with a mental illness. And in the majority of attacks, at least one of the victims was specifically targeted—the most common grievance reported was adverse interpersonal or employment action taken against the shooter. </p><p>A key to identification and resolution of threat cases is early identification of such attack-related behaviors. Perpetrators of targeted acts of violence engage in covert and overt behaviors prior to their attacks: they consider, plan, prepare, and share—and not with their target, but usually with third parties. One challenge security faces is educating scared, concerned, or anxious employees or students on how to disclose what they have heard and to whom, so security stakeholders can assess the information in context, formulate a deterrence plan, and take proactive steps.​</p><h4>Defining Threat Assessments</h4><p>In the post-Columbine world, we began to define a series of investigative processes as a threat assessment—a way to interpret data gathered from a wide variety of sources such as direct observation, records reviews, witness reports, past behaviors, and potential current targets, to form an opinion about the seriousness of a situation. </p><p>Conducting threat assessments became both a science and an intuitive art, and moved away from the limits of profiles, demographic characteristics, or historical statistics. Threat assessment activities underwent a shift from predicting violence—which is not possible—to identifying the behaviors of potential attackers, their targets, and the means and methods for harming those targets as a "window in time." The concept of threat assessments began to take on a new professionalism, moving beyond the realm of just mental health clinicians or law enforcement and into areas crossing over into the fields of security, human resources, prosecution, corrections, educational facilities, and research.   </p><p>Efforts in preventing mass shootings, stopping active shooters, and workplace and school violence prevention continue today, especially in light of recent attacks. We stand on the shoulders of researchers and threat assessment practitioners who were doing this work long before Columbine. Their work supports today's active assailant best practices and is based on extensive research.</p><p>Early researchers—including Dr. Fred Calhoun's work on threats against federal judges and Steve Weston's research on threat assessment—teach the theory that Howlers howl and Hunters hunt, meaning that there is more to worry about from the potential perpetrator who works in stealth than the person who "howls" and wants to be seen as intentionally provocative, disruptive, or sinister. The Hunter wants to be successful and not be stopped by security or the police, so this attacker does not warn. In the past, a lot of investigative energy, security assets, and resources were put towards threats made by Howlers who would say, "I've put a bomb near the loading dock!" or "I'm gonna come there and shoot up the whole school!"</p><p>Security and human resource-related associations are taking the lead in providing research, analysis of incidents, training, and the creation of national standards related to workplace violence and school violence prevention. Such organizations include ASIS International, the Association of Threat Assessment Professionals, and the Society for Human Resource Management. Other groups with input into the prevention of workplace and school violence include the International Association of Chiefs of Police, the National Sheriffs Association, and the National Association of School Resource Officers.​</p><h4>Threat Assessment Teams</h4><p> The biggest shift in the movement towards making the threat assessment process more professional and structured was the emergence of Threat Assessment Teams (TATs). These groups are also called threat management teams, crisis response teams, or critical incident response teams, and they now populate private-sector businesses, school districts, college and university campuses, and public-sector entities ranging from utilities to cities and counties.</p><p>TATs don't need to be formally appointed, but they must be staffed by the organization's safety and security stakeholders. This often includes representatives from executive management, human resources, security, legal counsel, facilities, IT, communications, safety, and risk management. The team can also benefit from support by local law enforcement commanders, mental health clinicians or Employee Assistance Program (EAP) providers, or labor relations or union representatives.</p><p>The function of the TAT is to discuss its coordinated, measured—but urgent— responses to potential crisis situations, including threats or violence towards the organization or its employees, employee-to-employee bullying, high-risk employee discipline or terminations, domestic violence crossovers with employees, threats to the organization's facilities, cyberthreats, and vexatious litigants.</p><p>The value of TATs—which are often run by human resources or security representatives, because of their familiarity with employee-related issues—is to take the best advice from the group and not get manipulated into "seeing the ocean through one drinking straw." In other words, the police may have strong feelings about making an arrest; the threatening employee's manager may want to terminate; and the facilities representative may want to lock the building down. These are all potential solutions and should be put up for group discussion before a final decision is made.</p><h4>Run. Hide. Fight. </h4><p>The Run. Hide. Fight. video created in 2012 by the U.S. Department of Homeland Security (DHS) and the City of Houston is short and to the point. If you are ever confronted by an active shooter, run out of the building, taking as many people as safely as you can with you; hide out in the best room you can barricade; and be ready to fight back if the shooter breaches your room. This active shooter protocol is designed to get employees out of the way of the attacker and the responding police by leaving the facility or locking the room down. In most cases, attackers have a short window of time to carry out their plan—usually five to 10 minutes—before police arrive.</p><p>All of the videos and training programs that have emerged as a response to workplace or campus shooters have the same goals: don't wait for the police to rescue you, get out of their way while they confront the attacker, and be prepared to fight back or provide first aid to save your life and help save the lives of your coworkers, customers, or students.</p><h4>​Domestic Violence in the Workplace </h4><p><strong></strong>One exception to Calhoun and Weston's Howlers vs. Hunters model is called the Intimacy Effect. In cases where there has been previous sexual intimacy between the suspect and the victim, the chances for fatal violence go up dramatically. These perpetrators are Howlers who become Hunters because they are obsessed with hurting or killing their former partner. </p><p>Murder is still the leading cause of death for women in the workplace, and has been for decades, according to the U.S. Occupational Safety and Health Administration. Most women who are killed on the job are shot during robberies at retail facilities or attacked by their former partners while working. As a workplace issue—one that many managers, supervisors, and human resources professionals are still reluctant to address—domestic violence crossover from home to work continues to take the lives of many female employees, especially in states where there are no laws preventing employees from being fired for revealing their victim status to their employer. </p><p>In California, legislation was passed in 2013 that gives domestic violence victim-employees protected class status—like age, race, or gender—and dictates that employers not only cannot fire an employee who brings a domestic violence issue to their attention but must also help create a workplace safety plan to provide protection and support. Fewer than 10 states in the United States offer similar supportive legislation, which is something domestic violence advocacy groups are trying to change.</p><h4>Continued Evolution </h4><p><strong></strong>Progress is being made to thwart potential workplace, school, and mass attackers, but there is still a long way to go to stop future perpetrators. These attackers learn from the methods and mistakes of their predecessors—but so do threat assessment experts and security practitioners. Threat assessment experts need to continue to develop new strategies for schools and businesses.</p><p>Scheduling yearly Run. Hide. Fight. drills that focus on the value of the first two steps is becoming more common, as is training employees and students to listen for—and properly report—preattack leakage threats from potential perpetrators. More organizations and school districts are establishing TATs to address crises, and there has been a bigger emphasis on getting funding for more well-trained school resource officers. </p><p>When it comes to addressing a potential active shooter who is moving on the path from ideas to action, proactive interventional responses by mental health clinicians and law enforcement officers alike is becoming an established best practice. Open dialogue about teaching all parents who own guns to practice safe storage in their homes is more common as well. And if a mass shooting is successfully carried out, there has been a greater emphasis on encouraging national media to not cover the attackers by name and face.</p><p>While facility security has evolved from the model of relying on gates, guards, and guns, it is still important to install appropriate security devices and update procedures periodically.</p><p>How security practitioners handle the threat of mass attackers on campuses and active shooters in workplaces, churches, and malls has changed over the past 25 years. There are many committed people who have made it their life's work to help stop these attacks, and the fight for peace at businesses and schools will continue.  ​</p><p>​ <em>Dr. Steve Albrecht, CPP, is a 22-year member of ASIS. As a keynote speaker, author, and trainer, he specializes in violence prevention. He has written 18 books on business, security, and criminal justice subjects. he can be reached at DrSteve@DrSteveAlbrecht.com.</em></p><h4>Resources Mentioned in this Article</h4><p></p><p>Dr. John Monahan, from the University of Virginia Law School is regarded as the "the leading thinker on the issue of violence risk assessment." </p><p>Hollywood security expert and threat assessment pioneer Gavin de Becker is best known for his groundbreaking work in protective intelligence gathering and his best-selling 1997 book, <em>The Gift of Fear.</em></p><p>Dr. Reid Meloy and Dr. Kris Mohandie are known for their research and speaking work on stalking perpetrators, "predatory versus affective violence," and their widely-used violence risk assessment models, methods, and practices.</p><p>The FBI's Behavioral Analysis Unit has often provided critical research, including two highly-detailed recent reports edited by Supervisory Special Agent Andre Simons: "<a href="https://www.fbi.gov/file-repository/active-shooter-study-2000-2013-1.pdf" target="_blank">A Study of Active Shooter Incidents in the US Between 2000 and 2013</a>" and "<a href="https://www.fbi.gov/file-repository/pre-attack-behaviors-of-active-shooters-in-us-2000-2013.pdf/view" target="_blank">A Study of the Pre-Attack Behaviors of Active Shooter Incidents in the US Between 2000 and 2013.</a>" Supervisory Special Agent Eugene Rugala edited the FBI's 2004 report, "<a href="https://www.fbi.gov/file-repository/stats-services-publications-workplace-violence-workplace-violence" target="_blank">Workplace Violence: Issues in Response</a>."</p><p>Dr. Ted Calhoun and Steve Weston's threat assessment books, presentations, and research and development of the concept known as "Hunters versus Howlers." Calhoun's seminal 1998 book, written for the US Marshals, <em>Hunters and Howlers: Threats and Violence Against Federal Judicial Officials in the United States, 1789 to 1993</em>, taught us to pay more attention to people who don't just draw attention to themselves by making verba​l or written threats.</p>GP0|#cd529cb2-129a-4422-a2d3-73680b0014d8;L0|#0cd529cb2-129a-4422-a2d3-73680b0014d8|Physical Security;GTSet|#8accba12-4830-47cd-9299-2b34a4344465
https://sm.asisonline.org/Pages/The-Dirty-Secret-of-Drug-Diversion.aspxThe Dirty Secret of Drug Diversion<p>​Controlled substances were going missing at Hennepin County Medical Center (HCMC), and the hospital’s security investigator, William Leon, was determined to get to the bottom of it. So, at 11 p.m. on a Friday, Leon settled in for a night of observation at the Level I trauma center in Minneapolis, Minnesota. He kept a trained eye on one registered nurse who was suspected of stealing hydromorphone, an opioid pain medication, for her personal use.</p><p>HCMC has cameras set up in the medication room to monitor controlled substances, and Leon watched as the nurse began gathering prescribed medication for a patient in the emergency department. The process, called wasting, requires the healthcare worker to take a fresh vial or syringe full of medication and then dispose of the excess, leaving only the correct dosage—all with a witness present. Leon observed the nurse dispense a syringe of hydromorphone from the medicine cabinet, and, while a fellow nurse was signing off on the withdrawal, she placed the syringe in her pocket and pulled out an identical syringe, which Leon later learned contained saline. The nurse held up the saline syringe and wasted the required amount, tricking her fellow nurse, and left the room.</p><p>At this point, Leon knew exactly what was going on, and watched with increasing alarm as the nurse headed to a patient’s room in the orthopedic area of the hospital. “In that area, I knew immediately, this patient could have a broken bone—they were in intense pain and requiring this medication,” Leon says. “I see a lot of doctors standing around and I’m thinking ‘uh oh, this patient is going to get saline.’”</p><p>Leon raced to the room and saw that the doctors had given the patient the saline the nurse had brought up. “The patient was still screaming in pain and the doctor was frantically asking the nurse, ‘Are you sure you got the right dosage? Are you sure it was hydromorphone?’ and she was insisting she had,” Leon says. He called the doctor and the nurse into the hall and explained that the patient had just gotten saline and still needed the proper pain medication because the nurse had diverted the hydromorphone in the medication room. The doctor went to properly treat the patient and Leon called the nurse manager and the local sheriff’s detective in to begin an official investigation into the nurse’s actions.</p><p>Drug diversion in the United States is a nebulous problem that is widespread but rarely discussed, experts say. Whether in manufacturing plants, retail pharmacies, hospitals, or long-term care facilities, healthcare workers are stealing drugs—typically for their own personal use—and putting themselves, patients, and coworkers at risk. </p><p>“I hate to tell you, but if you have controlled substances and dispense narcotics, you’ve got diversion going on,” says Cherie Mitchell, president of drug diversion software company HelioMetrics. “It’s just a question of whether you know it or not.”</p><p>The scope and frequency of drug diversion is almost impossible to grasp, due in large part to how diversion cases are addressed. A facility that identifies a diversion problem might bring in any combination of players, from private investigators and local law enforcement to state accreditation boards or the U.S. Drug Enforcement Agency (DEA). There is no overarching agency or organization that records every instance of drug diversion in the United States.</p><p>Controlled substance management is dictated by a number of laws, including the U.S. Controlled Substances Act of 1971, which classifies substances based on how they are used and the potential for abuse. It also dictates how the substances are dispensed, and a facility may be fined if it does not comply. </p><p>The closest estimates of drug diversion rates come from people or organizations who dig up the numbers themselves. The Associated Press used government-obtained data in its investigations on drug diversion at U.S. Department of Veterans Affairs (VA) medical centers. Reported incidents of diversion at about 1,200 VA facilities jumped from 272 in 2009 to 2,926 in 2015, the data revealed, and the VA inspector general has opened more than 100 criminal investigations since last October. John Burke, president of the International Health Facility Diversion Association, extrapolated data he obtained from facilities in Ohio to estimate the presence of 37,000 diverters in healthcare facilities across the country each year. </p><p>Mitchell points out that any statistic derived from officially collected data still wouldn’t accurately reflect the extent of drug diversion in the United States. “There’s a lot of people investigators really suspected were diverters but had to be chalked up to sloppy practice due to a lack of concrete evidence, so any statistic is talking about known diverters who are fired for diversion,” she tells <i>Security Management</i>. “Even if you did have a statistic, it would be off because how do you incorporate those so-called sloppy practicers, or diverters who thought they were about to get caught so they quit on you and left? No matter what number you come to, it’s probably bigger in reality.”​</p><h4>Addiction and Diversion</h4><p>Although more people are paying attention to drug diversion due to recent high-profile cases and the current opioid epidemic in the United States, experts say they have been dealing with the same problems their entire careers. </p><p>“I can personally tell you that I dealt with the same issues 15 or 20 years ago that the healthcare arena is facing today, specifically in the drug abuse and diversion by their own hospital healthcare employees,” says Charlie Cichon, executive director of the National Association of Drug Diversion Investigators (NADDI) and a member of the ASIS International Pharmaceutical Security Council. “There are different drugs today, of course, than there were 20 years ago.”</p><p>Susan Hayes has been a private detective for healthcare facilities for more than a decade and says the opioid epidemic has magnified the drug diversion problem in recent years. “The opioid addiction in America has lit my practice on fire,” she says.</p><p>It’s no secret that opioid addiction has reached epidemic levels in the United States. In 2010, hydrocodone prescriptions were filled 131.2 million times at retail pharmacies alone, making it the most commonly prescribed medication, according to the Mayo Clinic. However, those are just the numbers that were legally prescribed—about 75 percent of people who take opioids recreationally get them from a friend or family member. According to the U.S. Centers for Disease Control and Prevention (CDC), approximately 52 people in the United States die every day from overdosing on prescription painkillers.</p><p>Healthcare workers are not immune to the draw of opioids. In fact, up to 15 percent of healthcare workers are addicted to drugs or alcohol, compared to 8 percent of the general population, according to the Mayo Clinic. </p><p>“Healthcare providers are in very stressful jobs,” Hayes says. “They all have problems. Nurses have emotional attachments to patients that they see die. Even orderlies have very stressful physical jobs, they’re lifting patients. Pharmacists can make mistakes that mean life or death. You have people that are already in very stressful situations, and now you give them access to drugs…. I think the combination is almost deadly.”</p><p>While a bottle of 30mg oxycodone tablets can sell on the street for up to 12 times its price in the pharmacy, most drug diverters are addicts using the drugs themselves. Because of this, diversion shouldn’t be considered just a security concern but a patient safety concern, Cichon says. He references several high-profile diversion cases in which the diverters used the same syringe full of medicine on both themselves and their patients, spreading bacterial infections and hepatitis. In one especially egregious case, a traveling medical technician with hepatitis C would inject himself with his patients’ fentanyl and refill the same syringe with saline, ultimately spreading the virus to at least 30 people in two states.</p><p>Unfortunately, experts acknowledge that most diverters don’t get caught until they have been diverting for so long they start to get sloppy. “The people who are your real problem are the people who are hiding in the weeds, not doing enough to get caught, and those are the ones you want to find,” Mitchell says. “The people they are finding now are the people that have the needle in their arm or somebody has reported them. You want to try to find them before that.”​</p><h4>Out of the Loop</h4><p>Hayes details the path of drugs through a hospital: a pharmacy technician orders the medication from a wholesaler, who will deliver them to the hospital pharmacy. The drugs are sorted and stocked in the pharmacy, where they will remain until they are brought up to the patient floors and stored in various types of locking medicine cabinets. When a patient needs medication, a nurse goes to the medicine cabinet and dispenses the drug for the patient. </p><p>Another ASIS International Pharmaceutical Council member—Matthew Murphy, president of Pharma Compliance Group and former DEA special agent—describes this as the closed loop of distribution. “Once a drug is outside of the closed loop, when it gets dispensed from a pharmacy or administered by a doctor, it’s no longer in the purview of DEA rules and regulations,” he explains. Drugs are most likely to be diverted during those times when they are in transit or exchanging hands, outside of the closed loop.</p><p><strong>Wholesalers.</strong> When fulfilling a pharmacy’s request for medication, wholesalers have just as much of a responsibility to notice if something is amiss as the pharmacy does. Whether it’s a retail pharmacy or a hospital pharmacy, wholesalers are responsible for cutting them off if they start to request unusually high amounts of opioids. </p><p>In 2013, retail pharmacy chain Walgreens was charged $80 million—the largest fine in the history of the U.S. Controlled Substances Act—after committing record-keeping and dispensing violations that allowed millions of doses of controlled substances to enter the black market. Cardinal Health, Walgreens’ supplier, was charged $34 million for failing to report suspicious sales of painkillers. One pharmacy in Florida went from ordering 95,800 pills in 2009 to 2.2 million pills in 2011, according to the DEA. </p><p>Hayes says the fine against the wholesaler was a wake-up call, and now suppliers use algorithms to identify unusual spikes in orders of opiates. Wholesalers can even stop the flow of medication to pharmacies if they believe diversion is occurring—which can be disastrous to a trauma center, Hayes notes.</p><p><strong>Pharmacies.</strong> To restock the shelves, pharmacy technicians compile lists of what medications they are low on to send to the wholesalers at the end of each day. Hayes notes that many pharmacies do not conduct a retroactive analysis on what is being purchased—which is why wholesalers must pay attention to any unusual changes in orders. She stresses the importance of constantly mixing up the personnel who order and stock medications. </p><p>“If you’re both ordering and putting away drugs, that’s a bad thing because you can order six bottles when you only need five and keep one for yourself,” Hayes notes. </p><p>Similarly, it is important to rotate who delivers the drugs to the patient floors. “John the technician has been taking the drugs up to the floors for the last 20 years,” Hayes says. “Well gee, did you ever notice that John drives a Mercedes and has two boats and a house on Long Island? He makes $40,000 a year, did you ever do any investigation into why?”</p><p><strong>On the floor. </strong>Experts agree that the most egregious diversion occurs during the wasting and dispensing process in scenarios similar to the incident Leon witnessed at HCMC. Mitchell explains that all hospitals have different wasting procedures—some require nurses to waste the medication immediately, before they even leave the medication rooms, while others may have a 20-minute window. Other hospitals may prohibit nurses from carrying medication in their pockets to prevent theft or switching. ​</p><h4>Investigations</h4><p>Any company involved with controlled substances, whether manufacturing, distributing, or dispensing, must be registered with the DEA and must adhere to certain rules and regulations—which aren’t always easy to follow.</p><p>Murphy, who worked for the DEA for 25 years, now helps companies follow mandates he calls “vague and difficult to interpret.” For example, DEA requires anyone carrying controlled substances to report “the theft or significant loss of any controlled substance within one business day of discovery.”</p><p>“This hospital had 13 vials of morphine that ‘went missing’ and someone called me in to find out why,” Hayes says. “They asked me, ‘Are 13 vials substantial or not? Do I really need to fill out the form?’ I counsel them on what’s substantial because the language is very loose.”</p><p>Depending on the frequency or significance of these or similar forms, the DEA may open an investigation, Murphy explains. “DEA will look at these recordkeeping forms and determine if in fact everything has been filled out correctly, that they have been keeping good records,” he says. “If DEA determines that they are lax or have not been adhering to requirements, there could be anything from a fine to a letter of admonition requiring corrective actions.” In more serious cases, DEA could revoke the registration because the activity or behavior was so egregious that it was determined that the facility is not responsible enough, Murphy explains. If a facility loses its DEA registration, it cannot dispense controlled substances.</p><p>However, DEA does not get involved in every suspected case of diversion. “There are only so many DEA diversion investigators, so they have to prioritize what they get involved with,” Murphy says. “It has to be pretty egregious for them to get involved to seek a revocation or fine.”</p><p>That’s where people like Hayes come in. “They want me to come in instead of DEA or law enforcement,” she explains. “I’m a private citizen, I understand law enforcement procedures, and I can help them get at the root of the problem before they call in law enforcement.” </p><p>After an investigation into a diverter is opened, it is unclear what happens to the offender. Hayes says that she typically gathers evidence and gets a confession from diverters, at which point her client calls in law enforcement to arrest them. Leon, who was in charge of diversion in­vest­igations at HCMC for 20 years before becoming a consultant for HelioMetrics, was able to investigate but not interview suspected diverters. He tells <em>Security Management</em> that he would call in a sheriff’s detective to interview the suspect.</p><p>Although most diverters are fired when their actions are discovered, they are not always arrested—it’s often at the discretion of their employer. Depending on the diverter’s role, state accreditation boards—such as those that license nurses and pharmacists—would be notified and could potentially conduct their own investigations. </p><p>Cichon cautions that some hospitals hoping to avoid bad press and DEA scrutiny may look for loopholes. “We found out through the course of investigations that if someone resigns and was not sanctioned it may not be a reportable action,” he says. “If we allow this person to resign rather than take action against him, then we don’t have to report it.”</p><p>Murphy notes that DEA typically has no role in individual cases of diversion. “If the diverter has a license from one of those state agencies, usually it’s required that they be reported, and then it’s up to the board how they proceed with the personal license of the individual,” he says. The DEA doesn’t regulate the personnel—that’s up to the state and the facility. </p><p>Cichon notes that the lack of standards when addressing diversion makes it more likely that offenders could slip through the cracks and move on to continue diverting drugs at another facility. “Unfortunately, there are different laws and statutes in every state that set up some sort of reporting requirements,” he says. “There are medical boards, nursing boards, pharmacy boards, and not every worker even falls under some sort of licensing board for that state.” ​</p><h4>Staying Ahead</h4><p>Due to the stigma of discovering diverters on staff, many hospitals just aren’t preparing themselves to address the problem proactively, Cichon explains.</p><p>“This is something that is probably happening but we’re not finding it,” he says. “The statistics I’ve seen at hospitals that are being proactive and looking at this are finding at least one person a month who is diverting drugs in their facility. If a 300-bed hospital is finding one person a month, and Hospital B has the same amount of staff and beds and is finding nothing…”</p><p>NADDI has been providing training for hospitals to develop antidiversion policies. Cichon notes that many hospitals throughout the country have no plan in place to actively look for diverters. “As big as the issue is, many of them are still just not being that proactive in looking at the possibility that this is happening in their facility.”</p><p>Cichon encourages a team approach to diversion that acknowledges diversion as a real threat. “Not just security personnel should be involved with the diversion aspect,” he says. “Human resources, pharmacy personnel, security, everyone is being brought into this investigation, because the bigger picture is patient safety. The diverting healthcare worker typically isn’t one who’s going to be selling or diverting his or her drugs on the street, but they are abusing the drugs while they are working.”</p><p>Leon worked hard on diversion prevention at HCMC after discovering a surprising pattern: almost all of the diverters he investigated wanted to be caught. “What got me on this path of prevention was observing the nurses as they would admit to what they did,” he explains. “More often than not the nurses would say, ‘I wanted somebody to stop me. I needed help, didn’t know how to ask for it, and I was hoping somebody would stop me.’ That’s pretty powerful when you’re sitting there listening to this on a consistent basis.”</p><p>Leon implemented mandatory annual training for everyone in the hospital—from food service workers to surgeons—to recognize the warning signs of drug diversion. “If a nurse or anesthesiologist or physician is speaking with you and telling you they are having these issues, then you should say something,” Leon explains. “It’s not doing the wrong thing—you’re helping them, and that’s the message we sent out. Look, these individuals are not bad individuals. Something happened in their lives that led them down this path.”</p><p>Leon also had cameras installed throughout the hospital that allowed him to observe diversion but also kept his investigations accurate. “We had a nurse who was highly suspected of diverting,” he says. “With the cameras I was able to show that she wasn’t diverting, just being sloppy. The employees appreciated the cameras because it showed they weren’t diverting medication, they just made a mistake.”</p><p>Over time, HCMC personnel became more comfortable coming forward with concerns about their coworkers. Before the facility started the annual training, Leon caught at least one diverter a month. Before he retired, he says, that number had dropped to one or two a year.</p><p>“The success of our program at HCMC was the fact that we paid more attention to educating rather than investigating,” Leon says. “You have to keep those investigative skills up, but you have to spend equal amount of time on prevention and awareness.”</p><p>Mitchell points to algorithmic software that can identify a potential diverter long before their peers could. Taking data such as medicine cabinet access, shift hours, time to waste, and departmental access allows software to identify anomalies, such as a nurse whose time to waste is often high, or a doctor who accesses patients’ files after they have been discharged. </p><p>“Most people are using the logs from the medicine cabinets trying to do statistical analysis,” Mitchell explains. “You find out 60 days or six months later, or you don’t see that pattern emerge by just using one or two data sets. That doesn’t help. The goal is to identify these people as quickly as possible so they are no longer a risk to themselves or the patients or anyone they work with.”</p><p>Murphy encourages facilities to be in full DEA compliance to mitigate diversion. “If somebody wants to steal or becomes addicted, they are going to find a way to do it, and sooner or later they are going to get caught, but then there’s a problem because the hospital has to work backwards to determine how much was stolen and reconcile all that,” he says. He also notes the importance of following up internally on each diversion case and figuring out what went wrong, and adjusting procedures to address any lapses. </p><p>“Every entity that has a DEA program should have diversion protocols in place because if they don’t they are playing Russian roulette with theft and loss and their DEA registration,” Murphy says.  ​</p>GP0|#cd529cb2-129a-4422-a2d3-73680b0014d8;L0|#0cd529cb2-129a-4422-a2d3-73680b0014d8|Physical Security;GTSet|#8accba12-4830-47cd-9299-2b34a4344465