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Based on observation and interview, the hospital failed to ensure signs were posted conspicuously in places likely to be noticed by all individuals entering the emergency department (ED) specifying the rights of individuals under section 1867 of the Emergency Medical Treatment and Active Labor Act (EMTALA) with respect to examination and treatment for emergency medical conditions and women in labor, and to post conspicuously information indicating whether or not the hospital participated in the Medicaid program under a State plan approved under Title XIX. The hospital did not have EMTALA signage posted outside the ambulance entryway to the ED, inside the ambulance entryway, within the main ED, at the three ED entry ways from Radiology or the entry way from the outpatient area.

Findings:

On 06/06 at 10:20 a.m. a tour of the emergency department failed to reveal appropriate EMTALA signage in the following entryways to the emergency department:
- Ambulance entrance
- Three radiology department entry ways
- Within the main ED
- Outpatient entry way through Peds ED area.

In an interview on 06/06/2022 at 10:30 a.m. S2EDDir and S4RN verified the aforementioned emergency department entry ways did not have the appropriate EMTALA signage and the aforementioned entry ways had the potential to be utilized by emergency department patients.

Based on record review and interview the hospital failed to send the receiving facility all medical records (or copies thereof) that were available at the time of transfer related to the emergency condition which the individual has presented with to the ED. This was evidenced by the hospital failing to send copies of all radiographic films for 1 (#2) of 15 (#1-10, 16-20) patients at the time of transfer.

Findings:

A review of the hospital policy title Emergency Department Transfer of patients to Another Hospital or Physicians, Date of last review: July 2014 revealed in part:
F. An appropriate transfer is one which:
2. Ochsner provides the receiving facility with copies of all medical records of the exam and treatment and test results (including but not limited to x-ray, lab, and EKG) which were provided to the patient at Ochsner in connection with the emergency. This is the responsibility of the staff nurse in charge of the patient. This information will accompany the patient.

H. Administrative Duties;
3. All appropriate medical information will accompany the transferring patient. The charge nurse will be responsible for assembling the appropriate information. At a minimum, this will contain:
e. Pertinent x-ray films and report.

A review of Patient #2's MR revealed Patient arrived to the ED on 05/18/2022 at 11:31 p.m. as level 1 trauma after rollover motor vehicle crash. Further review of Patient #2's MR revealed the following radiology test were performed: X-Ray Pelvis Routine AP, Chest 1 view; CT head without contrast, CT chest, abdomen, pelvis with contrast; CT Cervical Spine without contrast; CT Maxiofacial without contrast.

On 05/19/2022 at 1:00 a.m. ED Physician completed the Physician Certification for transfer.
On 05/19/2022 at 1:51 a.m. ED Notes Air Evac at Bedside.
At 2:15 a.m. Care handoff. Provider that received the report: Given to other (Comment) Provider that received/ accepted the report: Flight RN.
Review of Patient #2's medical records failed to reveal documentation as to what medical records and diagnostic studies were sent during the transfer of Patient #2.

A review of Patient #2's MR from Hospital B revealed:
Patient #2 was received as a transfer with C1, fracture, numerous facial fractures, skull base fracture, skull fractures, traumatic subarachnoid, subdural hematoma and pneumocephalus.
Hospital B ED ordered and repeated the CT head without contrast and CT Cervical Spine without contrast due to the transferring hospital not sending a disc with all the radiology films for Patient #2. Hospital B also ordered and completed a CT Sinus without contrast, CT Angiogram neck, and CT Angiogram head while Patient #2 was in the ED.

In an interview on 06/06/2022 at 10:45 a.m. S2EDDir stated the ED nurse is responsible for ensuring all ED records are sent with transferred patients. Radiology is notified if a patient is being transferred and Radiology would transfer all images to a disc for transfer, CT and MRI. She stated she was not sure of basic films.

In an interview on 06/07/2022 at 9:25 S3DirPI stated Patient #2 was transferred because she needed Oculoplastic. She also stated that sometimes the extent of injuries may warrant transfer due to complexity of the case. S3DirPI also stated that the normal process is for staff to document in the medical record as to what records, radiology and laboratory reports were sent with transferred patients. She confirmed the staff did not document what was sent with Patient #2.

In an interview on 06/07/2022 at 09:40 a.m. S6RegDirRad stated the Radiology Department does not document if any films or disc are sent with a transferred patient. She further stated she would not have a way of looking back to determine if anything was sent with Patient #2.
She stated there was a time when the main CD burner was down during the month of May. However, there was a backup system to the main process for burning a disc and a back up to the back up.

In an interview on 06/07/2022 at 11:15 a.m. S6RegDirRad stated she had an email from S9TrDir, asking what happened with a transferred trauma patient on May 19, 2022 and not staff providing a disc to be transferred with the patient.
S6RegDirRad provided the email and a review of the email revealed it was Patient #2 who was transferred and the hospital failed to send a disc with the radiology films. S6RegDirRad verified Patient #2 did not have any radiology films sent with the patient at the time of transfer.

In an interview on 06/07/2022 at 3:15 p.m. S8HSRN stated he remembers Patient #2 being transferred to Hospital B. He further stated he remembers not being able to transfer the radiology images to a disc to send with the patient. He stated Hospital B did call him and he told them they were having technical difficulties with burning a disc. S8HSRN said he told Hospital B, a disc would be sent as soon as possible. S8HSRN was not aware if a disc was ever sent to Hospital B.

In a telephone interview on 06/08/2022 at 7:10 a.m. S7RN stated she remembers caring for Patient #2, calling report and sending a copy of the medical record with the patient. She admits the hospital was not able to make a disc of the radiology films and the patient was transferred only with the Radiologist Reports. She remembers they were not able to create a disc all night. Lastly S7RN stated that she was told the machine used to burn the disc was broken.

In an interview on 06/08/2022 at 10:00 a.m. S10SrDiReg stated normally insurance only pays for the first test performed and the hospital who repeated the test will likely have to absorb the cost.