HospitalInspections.org

Based on medical record reviews, ambulance run sheets, emails, facility policies and interviews for one of thirty patients who presented to Hospital #2 for care (Patient #1), the Hospital failed to report a possible EMTALA (Emergency Medical Treatment and Labor Act) violation to the State Agency within the required 72 hour timeframe. The finding includes:

Patient #1 was admitted to the Hospital #2's ED (emergency department) on 2/14/18 at 8:52 AM via EMS transport. Review of the ambulance run sheet dated 2/14/18 identified that Patient #1 first arrived at ED #1 via EMS at 8:19 AM, the ED MD tried to divert EMS however, the EMS transport was already backing into ED #1's bay. EMS personnel asked ED #1's MD to evaluate the Patient due to acute EKG changes indicative of a left bundle branch block (myocardial infarction). Further review of the ambulance run sheet identified that after the ED MD looked at the Patient's EKG at 8:19 AM, the MD instructed transfer to Hospital #2 as any delay would only delay patient care.
Patient #1's medical record from Hospital #2 identified that the patient was evaluated at Hospital #2's ED on 2/14/18 with a heart rate of 131, blood pressure 150/90, respiratory rate of 24 and oxygen saturation of 94% on bi-pap. Patient #1 was diagnosed with an acute myocardial infarction, required intubation with mechanical ventilation and was subsequently admitted to the hospital. Patient #1's discharge summary dated 2/23/18 noted final diagnoses of acute pulmonary edema, hypertensive crisis, new paroxysmal atrial fibrillation and coronary artery disease status post stent placements. Review of facility documentation by the MD #1 (Medical Director of Emergency Medical Services) identified that on 2/23/18, MD #1 reviewed Patient #1's ambulance run sheet and sent an email to Attorney #1 at Hospital #2 regarding the transport. On 3/8/18, (13 days after Hospital #2 was notified), Hospital #2 reported the redirection of Patient #1 to Hospital #2 as a possible EMTALA violation to the State of Connecticut Department of Public Health (DPH).

Interview with Attorney #1 who was unavailable for interview at the time of the investigation conducted on 3/14/18 and 3/16/18. Interview with the Director of Regulatory Affairs on 3/16/18 at 11:24 AM indicated that after receiving Patient #1's ambulance run sheet on Friday 2/23/18 or Monday (2/26/18), Hospital #2 believed this to be a potential EMTALA and tried to validate what had occurred. Interview with the VP of Legal Services on 3/16/18 at 11:28 AM noted that Hospital #2 engaged expert council regarding the possibility of an EMTALA violation and after confirmation and validation the facts were understood by 3/5/18 and the possible violation was then reported to the State of Connecticut DPH on 3/8/18. Hospital #2's EMTALA policy identified that each hospital shall monitor compliance with the EMTALA and any apparent violations shall be reported, in part to the Centers for Medicare & Medicaid Services or State Agency, however, the policy lacked the timeframe for reporting.