Grimm Quoted on Concerns Over Increased Immigration Enforcement Impacting Health Care Facilities

Douglas said health care leaders should plan specifically how to respond when federal agents arrive for immigration enforcement: “The officer will show up, and I think the first thing to do is to determine why they’re here and under what authority. There are two primary entrances to a hospital, the front door and the emergency room, and in some hospitals, the reception area or the first point of contact may be a volunteer…These people must be included in your education on their obligations, the facility’s obligations, and the facility’s rights under law. You don’t want to defy a properly issued court order, judicial order, or administrative order, but you also need to be aware of your rights in that regard to protect not only your employees’ privacy to the extent they’re afforded it, but also your patients’ privacy. ”

Douglas noted that the arrival of federal agents can be stressful, particularly for volunteers and others who are not accustomed to dealing with law enforcement or auditors, adding, “The goal is not to obstruct a proper investigation, but to make sure that you’re protecting your personnel and the patients to the greatest extent possible. Do the right thing, but also make sure you don’t inadvertently do the wrong thing… So, having educated personnel at both doors, the front desk, and the emergency room is important.”

He further stated that health care employers should prepare similarly to how they would prepare for any audit, whether by the Joint Commission, state Department of Health, or Centers for Medicare & Medicaid Services.

“I gave a lot of advice to my clients on developing the response team for what happens when you’re hacked. Here’s the plan, here’s the decision tree, here’s the notification tree, here’s what you say, here’s what you do not say,” Douglas said. “The same holds true in this context. Assume it’s going to happen, and then just enact the plan.”

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