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Based on interview, document review, and policy review, the hospital failed to maintain compliance with 42 CFR 489.24 with respect to the Emergency Medical Treatment and Labor Act (EMTALA) for 1 of 20 patients (P1) reviewed.

Findings include:

The hospital failed to ensure a comprehensive medical screening examination (MSE) was completed for P1, based on standards of practice, to ensure a potentially life-threatening emergency medical condition (EMC) did not exist or worsen. See A-2406.

The hospital failed to ensure a certification of transfer form was completed by a qualified physician, and provided to the receiving hospital, to certify the expected transfer benefits outweighed the risks for P1. See A-2409.

Based on interview and document review, the hospital failed to ensure a comprehensive medical screening examination (MSE) was completed for 1 of 20 patients (P1) reviewed when the patient presented to the emergency department (ED) unconscious (a life-threatening pathology) with a suspected drug overdose and required intubation (insertion of a tube into airway to assist with breathing) for decreased respiratory effort. P1 was not provided an appropriate medical screening examination, based on standards of practice, to ensure a potentially life-threatening emergency medical condition (EMC) did not exist or worsen.

Findings include:

P1's medical record identified on 3/19/25 at approximately 10:40 a.m., P1, suspected to be 26 years old, was dropped off in the emergency department parking lot, unresponsive with a suspected drug overdose, by an unknown female who was unable to provide any details related to P1. P1 was immediately brought to the resuscitation room where he was intubated at 10:52 a.m., after an adult code blue was called. P1 was provided two doses of Narcan (over the counter medication that rapidly reverses the effects of opioid type medications) without effect, along with intravenous (IV) fluids. Additionally, the following point-of-care testing labs (blood work drawn and tested at the bedside) were completed: glucose (elevated), calcium (within normal limits - WNL), sodium (WNL), potassium (low), venous blood gases (elevated). At 10:56 a.m., approximately 16 minutes after arrival, P1 was transferred via ambulance, with advanced cardiovascular life support (ACLS), to another hospital in critical condition.

P1's ED Report, dated 3/19/25 and completed by medical doctor (MD)-A, identified P1's case details were unclear due to the circumstances surrounding P1's ED presentation, and other then the person who brought him to the ED indicating she administered "2 separate doses of Narcan at home prior to arrival with no relief of symptoms," MD-A had no additional information related to P1 other than a suspected overdose. In response, P1 was brought to the resuscitation room and intubated due to "some spontaneous" "very shallow" breathing effort and the need for airway protection, where P1 demonstrated "good color change on CO2 detector and clear breath sounds bilaterally on auscultation of the chest after intubation;" however, the note indicated, P1's case "was moving rapidly and transfer was required in a rapid manner, post intubation x-ray was unable to be completed to confirm ET (endotracheal) tube placement. At the time it was not felt that any further work-up could be completed prior to transfer including potential for head imaging." Despite this, the report identified "It [did] not sound as if there was any history of trauma but again this could not be elicited further as acquaintance did not provide any further information."

P1's medical record lacked evidence of some degree of imaging, which included a chest x-ray to confirm ET tube placement or a head CT to look for emergent causes of P1's condition. Additionally, P1's record lacked an ECG (electrocardiogram - testing to detect heart problems), or a full set of labs beyond point-of-care testing.

When interviewed on 4/2/25 at 10:41 a.m., the compliance manager (CM)-A stated the facility lacked concerns with P1's case and thus no follow-up was conducted.

During an interview on 4/2/25 at 12:34 p.m., MD-A was able to identify the need for an MSE before the patient was transferred to another hospital for continued care to determine appropriate treatment and transfer needs. He explained P1's care and treatment moved very quickly, and in such situations, like P1's, when they need to be moved, they need to be moved quickly, especially when he thought something else might be going on with P1. MD-A explained that typically the ambulance was not at the hospital, as they were when P1 arrived, and thus it was not typically such a rush for transfer. MD-A identified P1 was unstable; however, was as stable as could be. MD-A stated they maybe could have done a chest x-ray to ensure tube placement; however, "things moved too quick to get it done," and maybe if EMS had not already been there, and he was required to wait for transport, this would have been completed but "globally [he] may have done the same process." MD-A identified facility management had yet to talk to him about any potential concerns related to P1's care.

When interviewed on 4/2/25 at 1:11 p.m., MD-B, who identified himself as the system medical director, stated he expected an unresponsive patient to promptly be evaluated with a focus on "ABCs (airway, breathing circulation)" and to attend to life-threatening issues first and foremost. After that, trauma care was provided if deemed necessary. MD-B explained once a patient was intubated, he expected a chest x-ray to be completed to ensure placement; however, with P1, "EMS was chomping at the bit to go," and he felt staff did enough to demonstrate P1's airway was secured and "likely to be in a proper position." MD-B identified he had reviewed P1's medical record; however, no concerns were identified.

An Emergency Medical Treatment and Active Labor Act (EMTALA) policy, version date 8/10/23, identified a MSE was an exam reasonably calculated to identify critical medical conditions uniformly provided to all patients who present with substantially similar signs, symptoms, and/or complaints; performed by qualified medical personnel. If the MSE revealed that the patient had an EMC, stabilizing treatment must be provided if Children's has the capacity and capability to do so. The policy did not identify any specific MSE components were expected, other than "an exam."

A Plan for Provision of Patient Care, revised 10/24/23, identified Children's existed so serve children; however, a Patient Care and Patient Support Services section indicated "any patient, regardless of race, color, ...or age will be assessed at Children's." Patient needs were assessed to determine appropriate care, treatment, and services which were dependent on collecting data, analyzing information to understand the patients' needs for care, treatment, and services and to identify the need for additional data, along with making care, treatment, and service decisions based on the analysis of information collected.

A Code Blue Emergency policy, version date 12/20/24, identified all individuals, which included adults, who presented to the ED, were required to have an MSE completed.

Based on interview and document review, the facility failed to ensure a certification of transfer form was completed by a qualified physician, and provided to the receiving hospital, to certify the expected transfer benefits outweighed the risks for 1 of 4 (P1) patients reviewed for hospital-to-hospital transfers.

Findings include:

P1's medical record identified on 3/19/25 at approximately 10:40 a.m., P1, suspected to be 26 years old, was dropped off in the emergency department parking lot, unresponsive with a suspected drug overdose, by an unknown female who was unable to provide any details related to P1. P1 was immediately brought to the resuscitation room where he was intubated at 10:52 a.m., after an adult code blue was called. P1 was provided two doses of Narcan (over the counter medication that rapidly reverses the effects of opioid type medications) without effect. P1's medical doctor (MD)-A dictated progress note identified, P1's case "was moving rapidly and transfer was required in a rapid manner ..." At 10:56 a.m., P1 was transferred via ambulance, with advanced cardiovascular life support (ACLS), to another hospital in critical condition.

P1's medical record lacked evidence a certification of transfer was completed and sent to the receiving hospital.

P1's receiving hospital medical record, obtained on 4/1/25, lacked evidence a certification of transfer was received from Children's Hospital.

When interviewed on 4/2/25 at 10:41 a.m., the compliance manager (CM)-A stated the facility lacked concerns with P1's case and thus no follow-up was conducted.

During an interview on 4/2/25 at 12:34 p.m., MD-A stated when a patient was transferred to another hospital, he was expected to complete a transfer form, which was then expected to be sent to the receiving hospital with the rest of the required paperwork. Despite this expectation, MD-A stated he did not complete one for P1 as "[P1] was already gone [transferred]. What was done was done." MD-A explained P1's care and treatment moved very quickly, and in such situations, like P1's, when they need to be moved, they need to be moved quickly. MD-A explained that typically the ambulance was not at the hospital, as they were when P1 arrived, and thus it was not typically such a rush for transfer, and he was able to be more cognizant of the requirements to complete the transfer form before the transfer. MD-A identified facility management had yet to talk to him about any potential transfer concerns related to P1.

When interviewed on 4/2/25 at 1:11 p.m., MD-B, who identified himself as the system medical director, stated he expected providers to transfer patients appropriately. This included contacting the receiving hospital and obtaining a provider acceptance of care. Once this was completed, a transfer form was then to be completed which would identify the acceptance details, and the appropriate level of transport required. MD-B identified he had reviewed P1's medical record; however, no concerns were identified. MD-B was unaware the transfer form was not completed.

During a telephone call on 4/3/25 at 2:27 p.m., the receiving hospital's release of information staff (ROI)-A reviewed P1's medical record related to his 3/19/25 admission. ROI-A verified the hospital received paperwork from Children's on 3/19/25; however, she was unable to locate a certification of transfer.

On 4/4/25 at 12:07 p.m., QM-A reviewed P1's medical record and verified the record lacked a certification of transfer.

An Emergency Medical Treatment and Active Labor Act (EMTALA) policy, version date 8/10/23, directed Children's may not transfer an unstable patient unless a physician certified the medical benefits expected from the transfer, and from the provision of appropriate medical treatment at another medical facility, outweigh the increased risks to the patient, and a copy of the completed certification (Children's Transfer Form) must be provided to the receiving facility.