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Based on document review and interview, it was determined that the Hospital failed to ensure compliance with 42 CFR 489.24.

Findings include:

1. The Hospital failed to post signage related to Emergency Medical Treatment and Active Labor Act (EMTALA). See deficiency at A-2402.

2. The Hospital failed to ensure that each patient seeking medical treatment was included on the emergency room log. See deficiency at A - 2405.

3. The Hospital failed to ensure that each patient was not unduly discouraged from remaining for further treatment. See deficiency at A-2408.

Based on document review, observation, and interview, it was determined that for 1 of 1 Emergency Departments, the Hospital failed to post signage related to Emergency Medical Treatment and Active Labor Act (EMTALA).

Findings include:

1. On 7/20/2020, the policy titled, "Emergency Medical Treatment and Active Labor Act (EMTALA)" dated 10/31/2014, was reviewed. The policy included, "Signage shall be posted in appropriate and conspicuous locations in CCH Hospital Emergency Departments and other areas where patients are waiting for examination and treatment. The signage shall specify the rights of individuals under EMTALA and the CCH participates in the Medicaid program. The signs shall be posted in English, Polish and Spanish."

2. A tour of the Emergency Department was conducted on 7/20/2020 at 9:15 AM, with the Emergency Department Nurse Manager/House Supervisor (E #1). There was no EMTALA signage posted throughout the Emergency Department.

3. An interview was conducted on 7/20/2020 at approximately 9:35 AM with the Emergency Department Nurse Manager/House Supervisor (E #1). E #1 stated that the EMTALA signage was removed in April 2020, during renovations in the ED, and was not replaced. E #1 stated that the EMTALA signage should be posted.

Based on document review and interview, it was determined that for 1 of 20 (Pt #1) records reviewed for patients who presented to the Hopspital's Emergency Department (ED) seeking medical assistance, the Hospital failed to ensure that the patient was documented on the ED's Central Log.

Findings include:

1. The Hospital's policy titled, "Emergency Medical Treatment and Active Labor Act (dated 10/31/2014), was reviewed on 7/20/2020 and required, "...K. Documentation of all individuals presenting to a CCH Hospital Emergency Department for emergency medical treatment is maintained (i.e., a Central Log) and includes the name of each individual and whether she/he: (1) refused treatment; (2) was denied treatment; (3) was treated, admitted, stabilized, and or transferred; or (4) discharged..."

2. The Hospital's Patient/Customer Complaints and Grievance Log included a grievance regarding Pt #1 (date opened 1/30/2020). Pt #1's grievance included, "...Incident date: 1/15/2020. Location: ED Waiting area. Feedback details: The patient presented to the Emergency Department at [Hospital A] on 1/15/2020 at around 6:15 PM complaining about anxiety and asthma. Informed staff that she was not able to breathe ..According to the grievance, the patient proceeded to the waiting area and called 311 to request an ambulance to transfer her to [Hospital Hospital B]..."

3. The [Local Fire Department] Ambulance Run Sheet, dated 1/15/2020 at 18:31 (6:31 PM), was reviewed on 7/20/2020 and included, " ...Arrived on the scene to find a female collapsed on the sidewalk in front of the [Hospital A] having a severe asthma attack. Pt states that she went into the [Hospital A] to get help and couldn't breathe...Pt states at no time did anyone call nurse. Pt was now [in full] panic as she explained and ran out of the hospital [Hospital A] and called 911 before collapsing on the ground exhausted and short of breath still. This is the point when we arrived...Contacted [Hospital B] ER telemetry about what happened ...Care transferred to ER staff [at Hospital B] ..."

4. The Emergency Department Central Log (dated 1/15/2020), was reviewed on 7/20/2020 and did not include any record of Pt #1.

5. On 7/20/2020 at 11:55 AM, an interview was conducted with the System Manager of Patient Access (E #3). E #3 stated that Pt #1 was not on the ED Central Log (1/15/2020). E #3 stated that Pt #1 should have been included on the Log.

Based on document review and interview, it was determined that for 1 of 20 (Pt. #1) patients reviewed for Emergency Department registration, the Hospital failed to ensure that the registration process did not unduly discourage the patient from remaining for further evaluation.

Findings Include:

1. On 7/20/2020, the policy titled, "Emergency Medical Treatment and Active Labor Act" dated 10/31/2014 was reviewed. The policy included, "Procedure/Process C. Reasonable registration processes may be followed (e.g., obtaining demographic information, insurance information and consent to treatment) prior to medical screening and stabilizing treatment, but must not delay screening or stabilizing treatment, or unduly discourage patients from remaining for further evaluation."

2. On 7/20/2020, the policy titled, "Emergency Department Registration" dated 12/15/2011 was reviewed. The policy included, "ED [Emergency Department] Quick Registration: Patient is quickly registered in the ED Registration conversation using the five key data elements to include, Patient First Name, Last Name, Date of Birth, Sex and Reason for Visit...Upon arrival to the Emergency Department the patient will be checked in at the Primary desk or designated area for a Quick Registration. However, if the patient requires immediate medical attention they will be escorted to the Trauma unit or place in an appropriate area to complete the Quick Registration and Triage Screening process. ED Full Registration: Upon completion of the Medical Screening Exam, perform [ed] by a Physician or certified trained professional, the Patient Access Representative may request financial information from the patient and/or patient's representative."

3. On 7/20/2020 at 12:44 PM, the Director of Regulatory Affairs and Accreditation (E #5) presented the [Local Fire Department] ambulance run sheet dated 1/15/2020 at 18:31 (6:31 PM) for Pt. #1. The ambulance run sheet included, "Complaints: Asthma Attack...arrived on the scene to find a female [Pt. #1] collapsed on the sidewalk in front of [Hospital A] having a severe asthma attack...Pt. [Pt. #1] states that she went into [Hospital A] to get help as she couldn't breathe. Pt. states the registration clerk asked for her ID [identification] repeatedly. Pt. states that she was frantic as she could not breathe and begged her to get someone to help and bring oxygen...The registration clerk said I cannot do anything for you until you are registered and I need your ID to do that."

4. On 7/21/2020, Pt. #1's clincial record from Hospital B was reviewed. The record included, "[Pt. #1] is a...female with a PMH [past medical history] of asthma...who presents with SOB [shortness of breath] X 2 days. She initially went to [Hospital A] but was unable to provide ID [identification] d/t [due to] her respiratory distress and was unable to obtain treatment and so called EMS [Emergency Medical Services] who brought her to [Hospital B]...Admit to ...ICU [Intensive Care Unit] for acute persistent asthma exacerbation."

5. On 7/20/2020 at 1:00 PM, an interview was conducted with a Patient Access Clerk ( E #6). E #6 stated that Pt. #1 came to the Emergency Department [Hospital A] on the evening of 1/15/2020. E #6 stated that she told Pt. #1 to come directly to the registration desk when Pt. #1 entered the Emergency Department. E #6 stated that Pt. #1 became angry and stated "Can't you see I have shortness of breath" when E #6 asked Pt. #1 for insurance information and her ID card. E #6 stated that Pt. #1 became increasingly angry and argumentative as she searched through her purse for her ID. E #6 stated that Pt. #1 then made a call to 911 for transportation to another hospital, and walked out. Subsequently, Pt. #1 was not registered or treated at Hospital A, but was transported by ambulance to Hospital B. E #6 stated that the ED instituted a new process, so that the patient is immediately assessed by the front desk triage nurse upon entering the ED.