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Based on review of patient records, hospital policies and procedures and staff interviews, the hospital failed to comply with all requirements of 489.24.

Refer to citations and examples at:

A 2411 (489.24(f)) Recipient Hospital Responsibilities - Hospital staff failed to accept transfer requests for 2 stroke patients who required a higher level of care. The hospital was not on diversion status at the time (8/7/16), and the sending hospital had no neurology medical staff available.

Based on record review, review of hospital policies and procedures, and staff interviews at the 2 hospitals identified in the complaint, Providence St. Peter Hospital refused to accept transfers of 2 patients with symptoms of stroke from the requesting hospital which had no neurology medical staff available to provide care (Patients #1 and #2).

Failure to accept patient transfers risked patient health and safety by delaying access to a higher level of care, and was a violation of EMTALA regulations.

Findings:

1. Record Review:
Patient #1: On 8/7/16, a 71 year old patient was seen in the Capital Medical Center (MC)Emergency Department (ED) with symptoms of a stroke. The Capital MC ED physician called Providence St. Peter Hospital to transfer the patient as there was no neurology on-call coverage available at Capital MC. The request was denied as documented in the patient's ED records. The patient signed themselves out of Capital Medical Center "Against Medical Advice" and acquired an ambulance to take them to St. Peter Hospital ED where they were seen and evaluated.

Documentation by medical staff at both hospitals reflected that request for transfer for Patient #1 was declined by Providence St. Peter Hospital staff: From the Capital MC record, the ED physician wrote on 8/7/16: "I initially consulted at St. Peter's Hospital who returned my call at 1735 however they told me that they could not accept the transfer because they were not on call for our facility."

From the Providence St. Peter Hospital record, the ED physician wrote on 8/7/16: "Today (the patient) went to Capital MC where s/he was diagnosed with a hemorrhagic stroke. Apparently they called here to transfer the patient and they were declined from the transfer center here by the stroke team with recommendation to go to University of Washington."

Patient #2: On 8/7/16, a 79 year old patient was seen in the Capital MC ED with symptoms of a stroke. The same Capital Medical Center ED physician (as for Patient #1) called Providence St. Peter Hospital to transfer the patient as there was no neurology on-call coverage available at Capital MC on 8/7/16.

Documentation by the Capital MC ED physician read, "I attempted to call the transfer center at St. Peter's Hospital at 1720 with call returned at 1735. The transfer center got the neurosurgeon for me who noted that this was not a neurosurgical case but rather a neurology case. We then paged the on-call neurologist at St. Peter's Hospital who declined to discuss the case with us as they stated they are not on-call for us despite our request to transfer the patient."

2. Review of Policies and Procedures:
Review of Providence St. Peter Hospital (PSPH) policies and procedures revealed:
The policy, "EMTALA," Number 861-00 PRE-008 directed staff under #3 C "Transfers to PSPH from another EC (Emergency Center/[Department])":
"PSPH is obligated to accept appropriate transfer of individuals being sent from another EC with an (emergency medical condition) if PSPH has the capacity and capability to do so."

Providence St. Peter Hospital staff failed to accept requests for 2 transfers of patients with symptoms of stroke.

The policy, "Telephone Recording," dated as last revised 12/1/15 read: "All facilitated phone calls involving a patient transfer or patient consultation, incoming to or outgoing from the Patient Placement/Transfer Center will be recorded."

Providence St. Peter Hospital staff failed to completely record Transfer Center call(s) for Patients #1 and #2 as directed by hospital policy.

3. Interviews:
The Capital MC ED physician was contacted and interviewed on 11/7/16 to clarify if he requested a consult or a transfer for Patient #1 and Patient #2 with the on-call neurosurgeon and neurologist at Providence St. Peter Hospital on 8/7/16. He stated Capital MC had no neurology coverage on 8/7/16, and he was seeking a higher level of care for both patients, so he requested transfers.

Interview with Capital MC Quality Assurance staff on 11/2/16 and review of the physician on-call schedule for August 2016 verified that there was no neurology coverage available on 8/7/16.

Interview with Providence St. Peter Hospital administrative staff on 11/1 and 11/2/16 indicated there were no beds available on 8/7/16 until 1900/7 p.m., and then 3 patients were admitted. No documentation was provided to verify the interview information. There was no documentation of the transfer request for Patient #2 who may have been discussed during the same call received by the Capital MC ED physician at 1735 on 8/7/16, and the Transfer Center tape was not recorded in full as directed by hospital policy. The tape abruptly ended during the first call with the PSPH neurosurgeon and the Capital MC ED physician. There was no information provided or available regarding the request to transfer Patient #2. No documentation was provided to verify staff interview information.

Providence St. Peter Hospital staff failed to accept transfers for 2 patients who needed a higher level of care for symptoms of stroke. This risked patient health and safety by delaying access to a higher level of care, and was a violation of EMTALA regulations.