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Based on policy review, record review, and staff interview, the Critical Access Hospital (CAH) failed to enforce policies to ensure compliance with 42 CFR 489.24, special responsibilities of Medicare hospitals in emergency cases, and the related requirements at 42 CFR 489.20 for 4 of 21 emergency department patient records (Patients #1, #2, #3, and #4) reviewed.

Hospitals are required to adopt and enforce a policy to ensure compliance with the requirements of §489.24. Failure of the CAH to enforce their Emergency Medical Treatment and Labor Act policy limited the CAH's ability to ensure appropriate treatment for emergency department patients and continuity of care for patients transferred from the emergency department.

Findings include:

The Critical Access Hospital (CAH) failed to ensure a qualified individual performed an appropriate medical screening examination for a patient who presented to the CAH's emergency department (Refer to C2406) and failed to document the medical records sent to the receiving hospital for three patients transferred from the emergency department (Refer to 2409).

Based on policy review, record review, and staff interview, the Critical Access Hospital (CAH) failed to ensure a qualified individual performed an appropriate medical screening examination for 1 of 21 patient records reviewed (Patient #1) of patients who presented to the CAH's emergency department. Failure to perform a medical screening examination limited the CAH's ability to determine if the patient had an emergency medical condition.

Findings include:

Review of the policy "EMTALA [Emergency Medical Treatment and Labor Act] and Physician On-Call Policies" occurred on 07/13/16. This policy, dated 02/2011, stated,
"I. Policies
A. It is the policy of Mercy Medical Center (the 'Hospital') that if an individual comes to the Emergency Department . . . :
1. The Hospital will provide an appropriate a [sic] medical screening examination within the capability of the Hospital's dedicated emergency department . . . to determine whether or not an emergency medical condition exists. The examination will be conducted by an individual(s) determined qualified by Hospital Bylaws or rules and regulations . . ."

Reviewed on 07/12/16, Patient #1's emergency department medical record from 10/17/15 lacked evidence of performance of a medical screening examination by a qualified individual.

During an interview on 07/13/16 at approximately 8:10 a.m., two administrative staff members (#1 and #2) confirmed Patient #1's emergency department medical record from 10/17/15 lacked documentation of a medical screening examination by the physician.

Based on policy review, record review, and staff interview, the Critical Access Hospital (CAH) failed to document the medical records sent to the receiving hospital for 3 of 12 records reviewed (Patients #2, #3, and #4) of patients transferred from the emergency department. Failure to document the medical records sent to the receiving facilities for transferred patients limited the CAH's ability to ensure continuity of care for transferred patients.

Findings include:

Review of the policy "EMTALA [Emergency Medical Treatment and Labor Act] and Physician On-Call Policies" occurred on 07/13/16. This policy, dated 02/2011, stated,
"III. Procedures
C. An Individual Who Has an Emergency Medical Condition . . .
3. . . . c. The Hospital shall send the receiving facility copies of all pertinent medical records available at the time of transfer, including: (1) history; (2) records related to the individual's emergency medical condition; (3) observations of signs and symptoms; (4) preliminary diagnoses; (5) results of diagnostic studies or telephone reports of the studies; (6) treatment provided; (7) results of any tests; and (8) a copy of the completed applicable sections of the Transfer Summary . . . "

Reviewed on July 12-13, 2016, the following emergency department patient records lacked documentation of the records the CAH sent to the receiving hospital upon transfer:
- Patient #2 on 11/04/15
- Patient #3 on 12/16/15
- Patient #4 on 02/19/16

During an interview the morning of 07/13/16, an administrative staff member (#2) confirmed the medical records for Patients #2, #3, and #4 lacked documentation of the records sent to the receiving hospital upon transfer from the CAH's emergency department.