HospitalInspections.org

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Based on observation, interview, record review and review of hospital policies and procedures and medical staff bylaws, the hospital failed to develop and implement policies and procedures for evaluation and treatment of patients presenting for emergency care in accordance with the Emergency Medical Treatment and Labor Act (EMTALA).

Failure to ensure patients receive a comprehensive medical screening examination by a qualified medical professional and stabilizing treatment prior to transfer or discharge risks poor health care outcomes, injury, and death.

Findings included:

1. The hospital failed to identify in medical staff bylaws the providers qualified to perform medical screening examinations.

Cross reference: C-2406

2. The hospital failed to stabilize and transfer a psychiatric patient to a psychiatric facility when inpatient care was required.

Cross reference: C-2409

3. The hospital failed to ensure transfer documentation was completed prior to transferring patients to another acute care facility.

Cross reference: C-2409

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Based on interview, review of hospital policies and procedures, review of medical staff bylaws and rules and regulations, the hospital failed to identify and approve the medical personnel who were qualified to perform Medical Screening Examinations.

Failure to identify and approve the medical personnel who were qualified to perform Medical Screening Examinations risks examinations performed by unqualified staff and failure to identify emergency medical conditions.

Findings included:

1. Review of the hospital policy titled, "Medical Screening Exam," revised date 12/23/20, showed that all medical screening examinations will be done by a provider in the emergency department.

2. Review of hospital medical staff "Bylaws and Rules and Regulations," dated May 2003, failed to show evidence that the Governing Body had identified which classifications of personnel had been approved, and qualifications required to provide MSEs to patients seeking one. The Rules and Regulations showed that a registered nurse, mid-level, or physician will see each person who comes or is brought to the hospital for emergency medical care, to assess the person's condition to determine the nature, acuity, and severity of the person's immediate medical need.

3. Review of the hospital medical staff bylaws showed that Allied Health Professionals are defined as physician assistants, nurse practitioners and certified registered nurse anesthetists. Those professionals were credentialled according to the same guidelines established for the medical staff. Those allied health professionals were to provide services to patients according to the clinical privileges granted to them according to their job descriptions, contracts, and clinical privilege request forms and that had been approved by the medical staff and the governing board.

4. Review of the Allied Health Professional Clinical Privilege Request Form showed that Medical Screening Examinations were not included on the form.

5. On 04/28/22 at 12:40 PM, during an interview with the investigator the Chief Executive Officer (Staff #5) stated that the medical staff bylaws outline clinical privileges. Each provider has a privileging request form that is signed by the Executive Committee and then the governing board. The Chief Nursing Officer (Staff #1) verified that the bylaws did not identify which medical personnel were qualified and approved to perform MSEs and that MSE was not included on the allied health professional clinical privilege request form.

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ITEM #1 - Safe patient transfer

Based on review of hospital policies and procedures, medical record review and interviews, the hospital failed to transfer a patient from the Emergency Department to an inpatient psychiatric facility during a mental health crisis for 1 of 3 psychiatric patients that required admission to a psychiatric facility.

Failure to provide for a safe transfer from one hospital to another hospital places patients at risk of harm and adverse outcomes due to lack of care continuity.

Findings included:

1. Medical record review showed that a 62 year-old patient was brought into the Emergency Department (ED) by law enforcement (Patient #4). The patient received a medical screening examination and was seen by the designated crisis responder (DCR). The medical record showed that the DCR obtained a bed in a psychiatric facility but that the bed would not be ready until approximately 5 AM. The provider note showed that the patient was medically stable. The diagnosis was acute psychosis. The record showed that at midnight the patient was discharged to jail with the police instead of transferred to the psychiatric facility at 5 AM.

2. On 04/28/22 at 4:45 PM, during an interview with the investigator, a registered nurse (RN) (Staff #4) working in the Emergency Department stated that psychiatric patients have someone with them while they are in the Emergency Department, and the nurses go into the patient room with the physician. Staff #4 stated that patients who are going to a psychiatric facility stay in the ED until the bed is available. DCR coordinates bed placement for psychiatric patients.

3. On 04/28/22 at 2:35 PM, during an interview with the investigator, the Director of Nursing (Staff #2) verified that medical records showed that a psychiatric bed had been obtained by DCR, but that the patient was discharged to jail until the bed was available (Patient #4).


ITEM #2 - Transfer documentation

Based on interview, review of medical records and documents, and policy and procedure review, the hospital failed to document all the elements of an appropriate transfer for 4 of 7 medical records of patients who had transferred to another hospital for additional care.

Failure to send completed transfer documents and copies of all medical records pertaining to the patient's emergency care to the receiving facility when patients are transferred from one hospital to another risks medical errors and adverse patient outcomes due to lack of care continuity.

Findings included:

1. Review of the hospital policy titled, "Transfers/Interfacility," revised date 02/24/22, showed that completion of the transfer form(s) to include information sent prior to the transport was required, and would include risks and benefits of transfers as well as patient or family consent. The receiving facility would receive copies of the necessary healthcare information.

2. Review of the hospital's transfer form titled EDTC ED Transfer Communication Form showed that records sent with the patient checklist included face sheet, copies of test and/or procedures, ER patient summary, and Copy of EDTC.

3. Medical record review showed incomplete EDTC checklists for 3 of 7 patients transferred to other facilities (Patient # 7, Patient # 11, Patient # 17). Medical record review for 1 of 7 patients transferred to another facility did not have an EDTC form in the medical record (Patient # 14).

4. On 04/28/22 at 2:35 PM, during an interview with the investigator, the Director of Nurses (Staff #2) stated that hospital policy was not followed for 1 medical record that was missing the transfer form and 3 medical records that were missing completed checklists documenting information sent to receiving hospitals.

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