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Based on Emergency Department (ED) medical record reviews, interviews, transfer documents reviews, Emergency Medical Treatment and Labor Act (EMTALA) policy review, and staff's EMTALA education and competency, the hospital failed to ensure EMTALA laws and hospital EMTALA policy were followed for all patients seeking emergency medical care in their hospital. This failure prevented the hospital from meeting the requirements for compliance with 42 CFR 489.20 and 42 CFR 489.24.

Findings include:

1. The hospital failed to provide an appropriate medical screening exam for one of four obstetric patients (Patient (P)1) out of a total sample of 21 patients reviewed. Cross Reference: A2406 Appropriate Medical Screening Examination.

2. The hospital failed to: 1. have completed accurate transfer documentation for two of four patients (Patient) (P)2 and P15) reviewed for transfer to another acute care hospital, and 2. failed to care for their Emergency Department (ED) patients needing inpatient services when the hospital had the capability and capacity of transferring one of four patients (Patients (P)15) reviewed for transfer their Emergency Department (ED) to another acute care hospital in the Prisma Health system out of a total sample of 21 ED patients. Cross Reference: A2409 Appropriate Transfers.

5. Review of the Corporate Compliance training section, which was reviewed every two years, revealed the training all hospital staff received consisted of five slides, which were related to the money penalties involved with EMTALA violations. Two of the post training questions after the five EMTALA training slides were related to the money penalties related to EMTALA violations.

During an interview on 03/12/25 at 10:30 AM, the Director of Clinical Education, the Associate Chief Nursing Officer (CNO) and the Clinical Care Experience Director-Richland Department of Clinical Care Experience confirmed that the "Corporate Compliance" training was the only training all hospital staff received every two years, with the exception of the additional training and competencies on EMTALA law provided during onboarding for each new ED nursing staff.

Review of the ED staff competencies as follows:

1. Review of ED Director of Operation Emergency Services (DO-ES) personnel file revealed he/she received Corporate Compliance training last completed 07/17/24.

2. Review of ED Patient Support Technician (PST) 1's personnel file revealed ED-PST1 received Corporate Compliance (the five slide EMTALA education) on 05/27/24. No other EMTALA training or competency was found in ED PST1's personnel file.

3. Review of Obstetric (OB) RN1's personnel file revealed OB-RN1 received Corporate Compliance training (the five slide EMTALA education) on 06/14/24. No other EMTALA training or competencies was found in OB-RN1's personnel file.

4. Review of Obstetric (OB) RN2's personnel file revealed, OB-RN2 received Corporate Compliance training (the five slide EMTALA education) on 08/28/24. No other EMTALA training or competencies was found in OB-RN2's personnel file.

5. Review of Obstetric (OB) RN3's personnel file revealed, OB-RN3 received Corporate Compliance training (the five slide EMTALA education) on 06/13/24. No other EMTALA training or competencies was found in OB-RN3's personnel file.

6. Review of Obstetric (OB) RN4's personnel file revealed, OB-RN4 received Corporate Compliance training (the five slide EMTALA education) on 06/01/24. No other EMTALA training or competencies was found in OB-RN4's personnel file.

7. Review of Obstetric (OB) RN6's personnel file revealed, OB-RN6 received Corporate Compliance training (the five slide EMTALA education) on 06/16/24. No other EMTALA training or competencies was found in OB-RN6's personnel file.

8. Review of Obstetric (OB) RN7's personnel file revealed, OB-RN7 received Corporate Compliance training (the five slide EMTALA education) on 08/16/24. No other EMTALA training or competencies was found in OB-RN7's personnel file.

9. Review of Obstetric (OB) RN8's personnel file revealed, OB-RN8 received Corporate Compliance training (the five slide EMTALA education) on 07/16/24. No other EMTALA training or competencies was found in OB-RN8's personnel file.

10. Review of OB Surgical Technician (ST) (OB-ST1) personnel file revealed, OB-ST1 received Corporate Compliance training (the five slide EMTALA education) on 08/25/24. No other EMTALA training or competencies was found in OB-ST1's personnel file.

During an interview on 03/12/25 at 10:30 AM the above lack of EMTALA law training, education, and competencies for ED and OB staff was confirmed by the Director of Clinical Education.

Review of the EMTALA training provided for by the contracted security staff (SS) 1 revealed the training consisted of a sixteen slide EMTALA training that discuss in plain language what EMTALA law consisted of and included application of EMTALA law scenarios and test questions.

During an interview on 03/12/25 at 11:30 AM, the Associate CNO (also present was the Clinical Care Experience Director-Richland Department of Clinical Care Experience) confirmed that he/she understood, that the contracted security had a more in depth EMTALA training for the non-clinical security staff containing 16 slides versus the hospitals' "Corporate compliance" five slide training.

Based on observations, interviews, and policy review, the facility failed to ensure the appropriate Emergency Medical Treatment and Labor Act (EMTALA) signage was displayed in areas where patients would be able to read it and know their EMTALA rights.

Findings include:

Observations on 03/10/25 at 9:26 AM while touring in the Emergency Department (ED) revealed two patient waiting areas, one was identified for the pediatric emergencies and the other side was for adult emergencies. Further observations revealed the pediatric side contained EMTALA signage. The ED was broken into color coded zones with a total of sixty-nine bays. Observations of the ED revealed EMTALA signage (notice of rights) was not displayed in places likely to be seen by patients upon entering the ED.

During an interview on 03/10/25 at 9:26 AM, the Associate Chief Nursing Officer (A-CNO) confirmed that the ED lacked signage

Observations on 03/10/25 at 10:16 AM during a tour revealed no signage was seen in the triage areas or rooms of the Labor and Delivery (L&D) unit where obstetric (OB) patients seeking emergency medical care would be likely to notice the EMTALA signs to see, read and know their rights.

During an interview on 03/10/25 at 10:16 AM, the A-CNO confirmed that there was no EMTALA signage in the L&D unit triage area or rooms where OB patients seeking emergency medical care would come for triage and their Medical Screening Exam to rule in or out an Emergency Medical Condition.

Review of the hospital's policy titled "Emergency Medical Treatment and Labor Act (EMTALA): Prisma Health" last reviewed 10/22/24 revealed, "Signage will be posted conspicuously in the DED [dedicated emergency department], as well as those individuals waiting for examination and treatment in areas located on hospital property other than the DED (e.g., labor and delivery, waiting room, admitting area, entrance, and treatment areas)."

Based on review of the Emergency Department (ED) log including the Obstetric ED cases, interviews, and policy review, the facility failed to register one of a total sample of 21 patients (Patient (P) 1) seeking Emergency care on their ED log. This failure to maintain a log of all obstetric patients seeking emergency medical care placed all obstetric patients at risk.

Findings include:

During a telephone interview on 03/10/25 at 10:23 AM, P1 stated he/she had come to the hospital ED to seek emergency medical care for possible premature labor, with a complaint of nausea vomiting and stomach pain. P1 stated he/she first went to the ED registration, but in the ED only entered his/her social security number to verify P1 was in the system. Because P1 was greater than 16 weeks pregnant, P1 was told he/she would need to be triaged and screened in the Labor and Delivery Unit (L&D). P1 was placed in a wheelchair with his/her toddler and wheeled up to L&D by an ED staff (later identified as Patient Support Technician (PST) 1). During our interview P1 stated that at the registration desk, "I was yelled at by a staff [in L&D] with black hair and green scrubs." P1 went on to state that the L&D staff told him/ her could not be seen in L&D because P1 had a toddler, and the hospital had a new policy since December, no one under the age of 16 was allowed in the hospital. P1 stated, "I was in pain and nauseated and uncertain if I was in premature labor and was so taken back and upset with the unprofessional demeanor of the [L&D] staff yelling at me because I had my toddler, not caring that I could lose my unborn baby. I had no one to call to get my toddler, I just started crying and could not speak. When I tried to walk out the way I came up, the same staff yelled at me that I could not use those elevators because they were staff elevators. The ED staff was there with a wheelchair and offered to take me back down in the wheelchair and the L&D staff stated told the ED technician [PST1] that he/she should not wheel me down, that I should walk."

Review of security video for 02/15/25 the date P1 identified coming into the ED to seek emergency medical care revealed:
At 2:55 PM P1 and his/her toddler were observed past Security Staff (SS) 1.
At 2:57 PM P1 and toddler were at the Unit secretary directed to the registration desk.
At 2:59 PM P1 interacted with ED Registered Nurse (RN) 1. ED-RN1 was observed making a call (later identified as a courtesy call to L&D that P1 was being sent up to their department) at 3:00 PM.
At 3:01 PM P1 was observed in a wheelchair with a Patient Support Technician (PST) 1.
At 3:02 P1 was wheeled out of ED and up to L&D, using the "yellow zone" elevator at 3:03 PM P1 was on the elevator. No video was available for the L&D unit.

During an interview of 03/10/25 at 4:15 PM, ED-RN1 stated "I do not remember his/her name, but I do remember this day, per our protocol I asked [P1] to enter in his/her social security number that brought up [P1's] information to confirm that [P1] was in our hospital's record system." ED-RN1 stated, "I did not continue with registration because [P1] stated he/she was greater than 16 weeks and explained his/her symptoms, per the hospital protocol, I had [P1] go up to L&D for the triage and MSE [Medical Screening Exam]." ED-RN1 stated "I made a courtesy call" to L&D to let them know P1 was coming. ED-RN1 stated registration was fast, the patient just needed to enter their social security number, and it brings up all the demographics for that patient if they are in their system and we verify that. ED-RN1 confirmed P1 was in the hospital's medical record system.

During an interview on 03/10/25 at 3:55 PM, PST1 stated that he/she had taken P1 up to the fourth floor L&D on 02/15/25 through the back staff elevators (identified as the yellow zone elevators) and P1 had a toddler. P1 had complained of abdominal cramping and pain was her chief complaint and was worried she was going to deliver prematurely. The Charge RN (OB-RN1) told him/her to leave P1 at registration, and then he/she went back down to the ED. "I had to return to L&D with another patient when I saw [P1] was trying to leave, and was distraught, crying and saying they would not take care of him/her because he/she had his/her three-year-old with him/her."

During an interview on 03/12/25 at 4:02 PM, the Obstetric Registered Nurse (OB-RN) 1 confirmed he/she was the Nurse in Charge on the L&D Unit on 02/15/25 who engaged P1 to registered P1 for triage. OB-RN1 confirmed P1 was not registered P1 because P1 did not fill out the information on their registration clipboard. OB-RN1 confirmed that they just needed a patient's social security number to pull up all their information. When asked why P1 was not logged into their emergency department log on 02/15/25, OB-RN1 stated "P1 did not fill out the clipboard information."

Review of the Emergency Department log that included obstetrics for 02/15/25 from 00:01 AM to 11:59 PM revealed P1 was not entered into the ED log.

During an interview with on 03/10/25 at 3:00 PM, the Associate Chief Nursing Officer (ACNO) and the Clinical Care Experience Director-Richland Department of Clinical Care Experience confirmed P1 was not on the ED log in the ED or OB.

Review of the hospital's policy titled "Emergency Medical Treatment and Labor Act (EMTALA): Prisma Health" last reviewed 10/22/24 revealed, "Central log is a log that a hospital is required to maintain on each individual who comes to the hospital seeking assistance. The purpose of the central log is to track the care provided to each individual where EMTALA triggered. ... Each department where medical screening occurs will maintain an EMTALA Central Log, which includes the following required elements:
4.3.1 Whether the patient refused treatment,
4.3.2 Whether the Patient was refused treatment,
4.3.3 Whether the patient was transferred, admitted, and treated, stabilized and transferred or discharged."

Based on interviews, medical record review, and policy review, the hospital's emergency department (ED) failed to provide an appropriate medical screening examination (MSE) when it failed to follow their ED policies for triage and assessment for anyone seeking emergency medical care for one of four ED obstetric (OB) patients (Patients (P)1 and for one of 17 ED patients (P13) out of a total sample of 21 patients. The failure to triage and assess each patient seeking emergency medical care on the Labor and Delivery (L&D) unit and ED had the potential to delay care and treatment for all ED and those patients sent to L&D and resulted in delayed emergency care and treatment for P1.

Findings include:

1. During a telephone interview on 03/10/25 at 10:23 AM, P1 stated he/she had come to the hospital ED to seek emergency medical care for possible premature labor, with a complaint of nausea vomiting and stomach pain. P1 stated he/she first went to the ED registration, but in the ED only entered his/her social security number to verify P1 was in the system. Because P1 was greater than 16 weeks pregnant, P1 was told he/she would need to be triaged and screened in the Labor and Delivery Unit (L&D). P1 was placed in a wheelchair with his/her toddler and wheeled up to L&D by an ED staff (later identified as Patient Support Technician (PST) 1). During our interview P1 stated that at the registration desk, "I was yelled at by a staff [in L&D] with black hair and green scrubs." P1 went on to state that the L&D staff told him/ her could not be seen in L&D because P1 had a toddler, and the hospital had a new policy since December, no one under the age of 16 was allowed in the hospital. P1 stated, "I was in pain and nauseated and uncertain if I was in premature labor and was so taken back and upset with the unprofessional demeanor of the [L&D] staff yelling at me because I had my toddler, not caring that I could lose my unborn baby. I had no one to call to get my toddler, I just started crying and could not speak. When I tried to walk out the way I came up, the same staff yelled at me that I could not use those elevators because they were staff elevators. The ED staff was there with a wheelchair and offered to take me back down in the wheelchair and the L&D staff stated told the ED technician [PST1] that he/she should not wheel me down, that I should walk."

Review of security video for 02/15/25 the date P1 identified coming into the ED to seek emergency medical care revealed:
At 2:55 PM P1 and his/her toddler were observed past Security Staff (SS) 1.
At 2:57 PM P1 and toddler were at the Unit secretary directed to the registration desk.
At 2:59 PM P1 interacted with ED Registered Nurse (RN) 1. ED-RN1 was observed making a call (later identified as a courtesy call to L&D that P1 was being sent up to their department) at 3:00 PM.
At 3:01 PM P1 was observed in a wheelchair with a Patient Support Technician (PST) 1.
At 3:02 P1 was wheeled out of ED and up to L&D, using the "yellow zone" elevator at 3:03 PM P1 was on the elevator. No video was available for the L&D unit.

During an interview of 03/10/25 at 4:15 PM, ED-RN1 stated "I do not remember his/her name, but I do remember this day, per our protocol I asked [P1] to enter in his/her social security number that brought up [P1's] information to confirm that [P1] was in our hospital's record system." ED-RN1 stated, "I did not continue with registration because [P1] stated he/she was greater than 16 weeks and explained his/her symptoms, per the hospital protocol, I had [P1] go up to L&D for the triage and MSE [Medical Screening Exam]." ED-RN1 stated "I made a courtesy call" to L&D to let them know P1 was coming. ED-RN1 stated registration was fast, the patient just needed to enter their social security number, and it brings up all the demographics for that patient if they are in their system and we verify that. ED-RN1 confirmed P1 was in the hospital's medical record system. ED-RN1 stated that after hearing the concerns PST 1 stated were expressed by P1 from his/her experience of being refused care in the L&D unit for having a toddler with him/her, ED-RN1 stated he/she went to his/her ED Associate Manager -Nursing, who documented the potential EMTALA concerns and sent them to the Director of Operation Emergency Services.

Review of the email sent from ED Associate Manager -Nursing to Director of Operation Emergency Services on 02/15/25 at 5:17 PM revealed, P1 "did not have a choice and had to bring his/her toddler" P1 "was in tears" the ED-RN (1) who sent P1 to L&D called up to L&D to talk with the L&D RN (OB-RN1) "was rude ... making comments like 'Why isn't she going to Lexington then?" A previous encounter occurred with the L&D staff when a patient 36 weeks pregnant with twins taken to L&D there where "3 [sic] staff members at the desk had an attitude" about signing in the 36-week pregnant with twins patient.

During an interview on 03/10/25 at 4:30 PM, the ED Manager confirmed he/she was not aware of the incident with P1, or the email sent from ED Associate Manager -Nursing to the Director of Emergency Services on 02/15/25.

During an interview on 03/11/25 at 2:09 PM, the Director of Operations for Emergency Services was asked if the internal concerns voiced by PST1, ED-RN1 and sent to him/her by the Director of Operations for Emergency Services were addressed and reviewed under EMTALA law violations. The Director of Operations for Emergency Services stated it was not an EMTALA violation because it happened in the ED. The Director of Operations for Emergency Services confirmed that he/she did not know that EMTALA laws covered L&D or anywhere that a patient presented on the hospital grounds seeking emergency medical care. The Director of Operations for Emergency Services confirmed the concerns brought forward by his/her staff regarding P1 had not been addressed. The Director of Operations for Emergency Services confirmed the only EMTALA training he/she has received was from their online "Corporate Compliance" training.

During the following interviews on 03/11/25 the following OB-RNs confirmed that the only EMTALA training they received online "Corporate Compliance" training that included "EMTALA" that did not include competencies but did include test questions at the end.
OB-RN2 03/11/25 at 11:00 AM
OB-RN3 03/11/25 at 10:47 AM
OB-RN4 03/11/25 at 10:04 AM
OB-RN6 03/11/25 at 10:25 AM

Review of the Corporate Compliance training section that was the only EMTALA training L&D received every two years and what the entire hospital, including ED staff, received every two years after their onboarding was completed included five training slides. Two of the post training questions after the five EMTALA training slides were related to the violations and money penalties involved with EMTALA violations.

During an interview on 03/12/25 at 10:30 AM, the Director of Clinical Education, the Associate Chief Nursing Officer (ACNO) and Clinical Care Experience Director-Richland Department of Clinical Care Experience confirmed that the "Corporate Compliance" training was the only training all hospital staff received every two years, with the exception of the additional training and competencies on EMTALA law provided during onboarding for each new ED nursing staff.

During an interview on 03/12/25 4:02 PM the Obstetric Registered Nurse (OB-RN) 1 confirmed he/she was the Nurse in Charge on the L&D Unit on 02/15/25 who registered P1. OB-RN1 confirmed he/she did not register or triage P1 on 02/15/25. OB-RN1 confirmed P1 was not seen by a qualified medical professional (QMP) to have an MSE performed on P1 to ensure that a medical emergency was ruled in or out. OB-RN1 confirmed that he/she was aware P1 was leaving the unit and told P1 he/she could not leave on the same elevator he/she came up on. OB-RN1 stated he/she did not document P1 had come to the L&D seeking emergency medical care.

During an interview on 03/10/25 at 3:00 PM the Associate Chief Nursing Officer (ACNO) and the Clinical Care Experience Director-Richland Department of Clinical Care Experience confirmed P1 was not on the ED or OD/ED log and that there was not a medical record for P1 on 02/15/25 and no MSE was performed for P1 who came to the ED seeking emergency medical care.

2. Review of the ED record revealed P13, a 13-year-old came to the ED seeking emergency medical care on 10/28/24 at 10:09 PM with a chief complaint of "chest pain." Review of the ED notes failed to include the RN triage or a medical screening exam (MSE) by the QMP to determine if chest pain was cardiac related. The only note found in the medical record was that P13 was not in the ED at 10:28 (19 minutes) from the time P13 came to the ED seeking emergency medical care for chest pain.

During an interview 03/12/25 at 2:00 PM the Medical Record Navigator, the Associate Chief Nursing Officer (ACNO) and the Clinical Care Experience Director-Richland Department of Clinical Care Experience confirmed there was no documentation from the ED RN or QMP in P13's ED medical record. The ACNO confirmed that it is not the ED standard to wait 19 minutes for an RN to triage a patient that complains about chest pain, usually they are "seen right away."

Review of hospital's policy titled Emergency Medical Treatment and Labor Act (EMTALA): Prisma Health" "last reviewed" 10/22/24, revealed "Hospitals with a dedicated emergency department (ED) must provide to any individual including any infant born alive at any stage of development, who comes to the ED an appropriate Medical Screening Examination (MSE) within the capability of the hospital's ED, including ancillary services routinely available to the ED, to determine whether or not an emergency medical condition (EMC) exists ... EMTALA obligations are triggered when there has been a request for medical care by an individual within a dedicated emergency department (DED), when an individual requests emergency medical care on hospital property ..."

Based on interviews medical record reviews, hospital bed capability, transferring data, hospital capability and capacity data, and policy and procedure the hospital failed to 1. have completed and accurate transfer documentation for two of four patients (P) (P2 and P15) transferred to another acute care hospital, and 2. failed to care for their Emergency Department (ED) patients (P) needing inpatient services when the hospital had the capability and capacity by transferring one of four (P15) transfer reviewed from their Emergency Department (ED) to another acute care hospital in the Prisma Health system, a total of 21 ED medical records were reviewed. This failure to provide care in the hospital where the patient was treated in the ED, when it has both capability and capacity places all patients being transferred at risk for delays in care and treatment.

Findings include:

1. a. Review of the ED medical record for P2 revealed P2 arrived at the ED on 02/24/25 at 8:31 AM via emergency medical service (EMS) and presented with "Altered Mental Status Stroke-like symptoms." After stabilizing care was completed, the ED physician's decision was to transfer P2 to another acute care hospital. No signed or documented "Physician Certification" was found in P2's transfer that included verification of a physician-to-physician consultation, a nursing-to-nursing consultation, and/or the risk and benefits if the patient and/or family accepted or refused the transfer. No physician's order to transfer was found and the hospital failed to obtain "consent to transfer" signed by P2 and/or the family member.

b. Review of the ED medical record for P15 revealed P15 arrived at the ED on 02/21/25 at 3:59 PM with no chief complaint noted by emergency medical services (EMS) of "Stroke/TIA stroke" (a medical condition where blood flow to the brain is interrupted, leading to brain damage or death). After care was completed, the ED physician decided to transfer P15 to another acute care hospital. The hospital failed to obtain "consent to transfer" signed by P15, and no physician's order to transfer was found.

During an interview on 03/12/25 at 3:30 PM, the Medical Record Navigator, Clinical Care Experience Director-Richland Department of Clinical Care Experience, and the Associate Chief Nursing Officer (ACNO) confirmed the above information was missing from the patients' records who were transferred to Prisma Baptist Hospital.

2. Review of P15's ED medical record revealed P15 came to the ED on 02/20/25 at 5:30 PM via ambulance with a chief complaint of "Cerebrovascular Accident" (commonly known as a stroke, a medical condition where blood flow to the brain is interrupted, leading to brain damage or death). The physician's note documented on 02/22/2025 5:40 PM for discharge disposition: "Patient was reevaluated. The results and disposition were discussed.
Disposition: Admit: The decision to elevate care was made and plan is for admission to the hospital. Given capacity, transfer to Baptist for admission to the BIMA with neuro to follow."

Review of the census and bed capacity for Patient Care Unit (PCU) at Prisma Richland equivalent to the PCU unit that P15 was sent to at Prisma Baptist hospital revealed Prisma Richland's PCU identified at 10 West was staffed for twenty-eight beds and indicated twenty-seven beds were occupied. The hospital had one bed available.

During an interview on 03/12/25 at 3:42 PM the Associate Chief Nursing Officer (ACNO) and the Clinical Care Experience Director-Richland Department of Clinical Care Experience who provided the census, bed count, and staffed beds information for all the transfers reviewed and confirmed for the 02/20/25 the date P15 was transferred from Prisma Richland to Prisma Baptists the PCU was at 96% capacity but had one bed available and was staffed to accommodate the admission.

Review of a twelve-month February 2024 to February 2025 revealed the following:
February 2024 out of the 144 transfers 43 patients were transferred to Prisma Baptist (29.9%)
March 2024 out of the 164 transfers 68 patients were transferred to Prisma Baptist (41.4%)
April 2024 out of the 126 transfers 44 patients were transferred to Prisma Baptist (34.9%)
May 2024 out of the 152 transfers 61 patients were transferred to Prisma Baptist (40.1%)
June 2024 out of the 140 transfers 66 patients were transferred to Prisma Baptist (41.1%)
July 2024 out of the 166 transfers 75 patients were transferred to Prisma Baptist (45.2%)
August 2024 out of the 180 transfers 84 patients were transferred to Prisma Baptist (46.6%)
September 2024 out of the 171 transfers 73 patients were transferred to Prisma Baptist (42.7%)
October 2024 out of the 133 transfers 60 patients were transferred to Prisma Baptist (45.1%)
November 2024 out of the 136 transfers 75 patients were transferred to Prisma Baptist (55.1%)
December 2024 out of the 119 transfers 44 patients were transferred to Prisma Baptist (37%)
January 2025 out of the 150 transfers 66 patients were transferred to Prisma Baptist (44%)
February 2025 out of the 132 transfers 77 patients were transferred to Prisma Baptist (58.3%)

During an interview on 03/11/25 at 3:00 PM with the ACNO, who provided the transfer documentation, confirmed that the highest number of transfers for each of the 12 months are to Prisma Baptist. The ACNO confirmed that Prisma Richland Hospital has more services and a larger capacity than Baptists.

During an interview on 03/11/25 at 11:32 AM the Interim Division Chief Pulmonary, Critical Care, and Sleep Medicine stated, "when we initiated the internal transfers in August of 2022, there were concerns brought forward, it was new, and there were safety concerns, and criteria. It was an adjustment. Prisma Richland Hospital's Intensive Care Unit (ICU) is consulted and determine if we have capability and capacity, but patient safety is number one." Interim Division Chief Pulmonary, Critical Care, and Sleep Medicine, verified there are times the hospital has capacity but each case is individually reviewed by the critical care team to make that decision, considering patient safety first.

During an interview on 03/11/25 at 12:01 PM the ED Assistant Director stated, "I am not aware of any complaints regarding our transfers. Our process is to consult ICU, to determine if the patient can be treated at a sister facility [within the Prisma Health system]." When asked if there is a bed open at this hospital why don't the patients stay here? The ED Assistant Director stated that because we have ICUs at other hospitals, we rely on "bed board" people to let us know where (within our system) beds are available [to transfer patients to].

Review of the hospital's policy titled "Transferring and Accepting Patients from Another Facility, including a Prisma Health Hospital: Prisma Health" effective date 04/27/22 revealed "In preparation for and prior to transfer, the appropriate communication and documentation must be completed. ... When it has been determined that a patient needs to be transferred to another facility, the physician will: Explain to the patient the risks and benefits of transfer. Obtain the consent to transfer. The "Transfer Consent" section of the form will be completed and placed in the patient's medical record. Complete the EMTALA/Transfer to another facility - Section 1: Physician Certification. Contact the Transfer center to identify a physician at the facility who is on-call to accept the patient. The transferring physician will speak with accepting physician to transfer. The sending physician will be responsible for any orders for anticipated treatment or medications needed during transport. EMTALA/electronic document-Transfer to another facility Section 2: Nurse Certification"

Review of the hospital's policy titled " Emergency Medical Treatment and Labor Act (EMTALA): Prisma Health" effective date 10/22/24, reveled, "Appropriate Transfer occurs when: (i) the transferring hospital provides medical treatment within its capacity that minimizes the risks to the individual's health ... and qualified personnel for the treatment of the individual and has agreed to accept transfer of the individual to provide appropriate medical treatment; ... the transferring hospital sends to the receiving hospital ... the informed written consent for transfer or certification ... Capability means that an organization has the physical space, equipment, supplies, and services including ancillary services available at the hospital. The capabilities of the hospital's staff mean the level of care that the hospital's personnel can provide within the training and scope of their professional licenses. The hospital is responsible for treating the individual within the capabilities of the hospital as a whole, not necessarily in terms of the particular department at which the individual presented. Capacity means the ability of the hospital to accommodate the individual requesting examination or treatment of the transferred individual. Capacity encompasses the number and availability of qualified staff, beds, equipment, and the hospital's past practices-of accommodating additional patients in excess of its occupancy limits, including if the hospital has customarily accommodated patients by, for example, moving patients to other units, calling in additional staff , or borrowing equipment from other facilities."