Reference no: EM133513839

Case Study: Hospital A's chief financial officer (CFO) is concerned that there are two ongoing EMTALA investigations by the State Department of Health against Hospital A for two inappropriate patient transfers in the last two weeks. As part of its ongoing investigation, the State Department of Health has noted was that there was a failure to conduct a basic medical screening examination/stabilization for each of the patients when in the emergency department of Hospital A. Sanctions against Hospital A are pending.

Complaints were originally filed by Hospital B (the receiving hospital) against Hospital A for inappropriate transfer of two patients to Hospital B. This situation is more commonly known as "patient dumping." Both patients were over age 60, lacked insurance, and had a history of heart failure. The two inappropriate transfers were by the same emergency physician.

Hospital A's leadership has identified a quality improvement plan with four initiatives related to EMTALA that they want to implement.

Questions: Multi-faceted quality improvement strategies to avoid EMTALA complaints, investigations, and sanctions:

Initiative 1: Require education on EMTALA for all current and new employees at the hospital. Commence with immediate education and then require annual EMTALA updates.
Initiative 2: Conduct a peer review of records for provider in the two complaints.
Initiative 3: Review contextual factors, such as whether the hospital was on diversion status, at time of the events.
Initiative 4: Review patient throughput through processes and provider staffing at the time of the incidents. Do you think the evaluation method is implementable in the short term and long term? Is the evaluation method sustainable and effective? Do you think it would need to be adjusted after a period of time?
After looking at the evaluation methods and based on who would be legally liable for any violations of EMTALA and the potential sanctions for violations, would you recommend the hospital make any further changes to their EMTALA adherence processes?