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621 TENTH STREET

NIAGARA FALLS, NY 14302

EMERGENCY SERVICES POLICIES

Tag No.: A1104

Based on policy review, document review and medical record review, the medical staff do not adhere to facility policy related to midlevel practitioners involved in the transfer of patients to an higher level of care for 2 of 4 patients (Patient #10 and # 17).
Findings Include:
Review on 11/16/16 of policy A-28 " EMTALA/COBRA " last revised 12/15 indicates physician assistants (PA) are authorized to conduct medical screening examinations under the direction of the ED physician or attending physician. However, the physician completes the transfer form including medical orders for transfer. The policy indicates PA's are under the direct supervision of an emergency room physician. "Nothing in this policy shall give the PA the sole authority to execute a Physician Certificate for Transfer which must be completed by a physician unless no physician is present in the emergency department (ED) at the time of the patient transfer. In that circumstance, the certificate may be completed by a PA, but only after consultation with a physician."
Review of the Keystone Healthcare Management ED physician schedule for November 2016 revealed an attending physician is onsite 07:00 AM to 07:00 PM and 07:00 PM to 07:00 AM every day covering all shifts.
Review on 11/16/16 of the medical record for Patient #10 dated 11/09/16 revealed at 09:04 PM a medical assessment is performed by the PA. At 10:00 PM care is transferred to another PA. Both PA notes are signed off by an ED physician on 11/10/16 at 05:43 AM, however, there is no indication that either PA consulted with the attending physician prior to the transfer at 03:30 AM. The transfer form/order and the physician certification of medical necessity for ambulance transfer both dated 11/10/16 are signed by the PA, not the ED attending physician.
Review on 11/16/16 of the medical record for Patient # 17 dated 11/11/16 revealed a medical assessment is performed by the PA. The PA notes are signed off by an ED physician on 11/12/16 at 07:17 AM (the next shift), however, there is no indication the PA consulted with the attending physician prior to the transfer. The Transfer form/order dated 11/11/16 is signed by the PA, not the ED attending physician.