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Based on medical record reviews, interviews and document reviews, the facility failed to provide a Medical Screening Examination (MSE) for Patient #2, as evidenced during the medical record review of twenty (20) Emergency Department patients. At the time of this survey, the facility was in complaince, but was previously out of compliance, with the EMTALA requirements at 42 CFR §489 (Rev. 02-21-20)) regarding Responsibilities of Medicare Participating Hospitals in Emergency Cases.

The findings:

The facility's policy entitled, "IHS EMTALA - Compliance with the Emergency Medical Treatment and Active Labor Act Policy," effective January 14, 2025, reads in part:
"I. Policy
Any individual who comes to an Inova Dedicated Emergency Department requesting, or for whom a request is made, examination or treatment for a medical condition, shall be given an appropriate medical screening. Likewise, any individual who is on Inova Hospital Property other than in a Dedicated Emergency Department, and who requests, or for whom a request is made, examination or treatment for an emergency medical condition, shall be given an appropriate medical screening.
... II Purpose
... (i) a medical screening must be done to determine if an emergency medical condition exists for anyone who comes to an Emergency Department seeking an evaluation or treatment ....
III. Applies to
All hospitals, hospital property areas, including any building owned by the hospital that are within 250 yards of the hospital, and provider-based facilities, and off-campus dedicated Emergency Departments.
... V. Expected Outcomes
...2. If... an ambulance brings an individual to the Hospital Property or off-campus Dedicated Emergency Department, regardless of any diversionary status, a Medical Screening Examination and any required treatment for stabilizing the individual must be provided."

The facility's policy entitled, "EMTALA - Compliance with the Emergency Medical Treatment and Active Labor Act, Addendum Title: Medical Screening Procedure, Addendum Letter: A," with a date of November, 2024, reads in part:
"A. Medical Screening Examination
a. Medical Screening Exam Required
i. An appropriate Medical Screening Examination, within the capability and capacity of the facility, shall be provided to any individual who (i) comes to an Inova Dedicated Emergency Department requesting, or for who a request is made for, examination or treatment for a medical condition ....
ii. If an individual comes to an Inova Dedicated Emergency Department and shows signs or symptoms that a prudent layperson would believe indicate the possibility of a medical condition, a Medical Screening Examination is required.
... v. A Medical Screening Examination and stabilizing treatment, as appropriate, are also required for ... (ii) individuals who are in nonhospital-owned ambulances ...on hospital property for purposes of examination or treatment for a medical condition."

Patient #2 was taken to Oakville ED, a free-standing facility of Inova Alexandria Hospital (IAH), at approximately 2:00 A.M. on November 27, 2024, by an Emergency Medical Services (EMS) unit owned by Alexandria City. Once the unit arrived, a clinical team member [Staff Member #7] recommended to the EMS unit that Patient #2 should be transferred to the ED at IAH for further evaluation and possible admission. Patient #2 was never off boarded from the unit into the Oakville ED, was never registered as a patient at the facility and did not receive a Medical Screening Exam (MSE) while there. Patient #2 was transported to the IAH November 27 at 2:16 A.M. where the Patient did receive a MSE and was ultimately admitted. There was no mention in Patient #2's medical record that the Patient had been transported to Oakville ED initially.

The trip log from the City of Alexandria Fire Department reveals that EMS unit transported Patient #2 to the Oakville ED on November 27, 2024, with a chief complaint of "trouble breathing," noting Patient #2's level of distress as "mild." A note on the report states, "PT [patient] transport to INOVA Oakville. Staff met EMS in the ambulance Bay and stated that [Patient #2] should have been transported to INOVA Alexandria due to oxygen administration. EMS then transported PT to INOVA Alexandria ED."

During an interview on January 21, 2025, at 10:32 A.M., Staff Member #5 indicated that any patient that presents to an ED must receive a MSE upon presentation to the ED per EMTALA regulations and per the facility's policies. During an interview on January 22, 2025, at 9:10 A.M., Staff Member #6 indicated agreement that any patient that presents to an ED must receive a MSE.

On January 21, 2025, and January 22, 2025, the surveyor reviewed all changes implemented as a result of the reported incident. According to EMP3, EMP5 and EMP8, one hundred percent (100%) of the ED RNs at the location were reeducated on the facility's policy concerning EMTALA prior to this survey. A training session, including a question and answer session, was also held for all ED nurses at the affected site. Nurses were also required to take additional Health Streams training on EMTALA that is typically only required annually. All content was reviewed, participant lists were provided and reviewed and interviews with nursing staff confirmed participation in the additional training modules.