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Based on observation, interview, and document review, the critical access hospital (CAH) failed to ensure signage pertaining to the Emergency Medical Treatment and Active Labor Act (EMTALA) was posted in all areas likely to be noticed by patients entering the Emergency Department and those patients waiting for treatment. This had the potential to affect all patients presenting to the ED seeking care and treatment via the main hospital/ED and ambulance patient entrances.

Findings include:

On 6/4/24, at 9:40 a.m., a tour of the emergency department (ED) was conducted with the vice president of patient care (VPPC) and the ED director (EDD). During the tour, VPPC identified the main combined ED/hospital entrance. This area lacked EMTALA signage. An EMTALA sign was identified on a wall directly across from the emergency check-in station (registration) desk; however, this sign was not within visualization once seated in four of the eight waiting room chairs due to the sign being blocked by a half wall that separated the waiting area from the ED entrance doorway. In addition, the sign was not within visualization for patients seated on any of the six overflow chairs. EDD identified a Family Consult room, located directly off the main waiting area, was also utilized for waiting room overflow. This room lacked EMTALA signage. The tour ended at the ambulance bay ED entrance where the only EMTALA sign visualized was written in Spanish and located on the wall just inside of the ED ambulance bay doors. This area lacked an EMTALA sign written in English. VPPC acknowledged the visualization concerns within the waiting room proper, and overflow areas, and both VPPC and EDD acknowledged the lack of an English written EMTALA sign by the ambulance bay ED entrance. They stated an English EMTALA sign once was present; however, neither were able to explain why it was no longer present. EDD stated the most likely explanation was when they added a Spanish bill of rights and privacy practice sign to that location that potentially caused the EMTALA sign to not be rehung.

A Model Policies and Procedures for the Examination, Treatment and Transfer of Individuals in Need of Emergency Medical Services policy, dated 5/2/16, directed the hospital was to post signs conspicuously (standing out/clearly visible) in its on-campus and in all areas in which individuals routinely presented and waited for examination and treatment for their medical conditions, such as "Hospital entrances, admitting areas, waiting rooms or treatment room." In addition, all signs must be posted in all the major languages common to the population of the hospital's service area.