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Based on observation, interview and review of policies and procedures, it was determined the hospital failed to fully develop and enforce its EMTALA policies and procedures to ensure:
* The posting of required EMTALA signage.

Findings included:

1. Refer to findings identified under Tag A2402, CFR 489.20(q) which reflects the hospital's failure to fully develop and enforce its EMTALA policies and procedures to ensure the posting of required EMTALA signage.

Based on observation, interview and review of policies and procedures it was determined the hospital failed to fully develop and implement policies and procedures that ensured the posting of signage that specified patients' EMTALA rights in all areas likely to be noticed and where patients wait for examination and treatment.

Findings include:

1. Review of the undated Santiam Hospital policy and procedure titled "Emergency Medical Screening Exam and Transfer" reflected the following related to EMTALA signage:
"Signage and Documentation Requirements...Signage specifying...The rights of individuals with EMC's and women in labor and...Whether the Hospital participates in the applicable state Medicaid program must be posted in a place or places likely to be noticed in the Dedicated Emergency Department, admitting, and in such other locations where individuals are waiting for examination and treatment."

2. The ED entrance, waiting area, and treatment areas were observed during a tour on 02/13/2018 at 1150 with the CNO and ED Manager. The following observations were made:
* There was one EMTALA sign posted in the hallway to the left of the ED registration window. The sign could be read if a person was facing the window. However, the entire ED waiting area was to the right of, and behind the window where the sign was posted, and was not visible from any of the 16 seats in the waiting area.
* The ED had 1 triage room and seven treatment rooms. There was no EMTALA signage observed posted in the ED triage room, ED treatment room 3, or ED hallway areas. During observation of treatment room 3, the ED Manager stated "There's none in this room." These findings were confirmed with the CNO and ED Manager at the time of the observations.

3. The L&D waiting rooms and patient rooms were observed during a tour of the L&D department on 02/13/2018 at 1205 with the CNO and IC Coordinator. The following observations were made:
* There was no EMTALA signage posted in the L&D waiting room.
* There was no EMTALA signage observed posted anywhere in the L&D department including but not limited to observations of LDP rooms 228, 234, 235, and 237. These findings were confirmed with the CNO and IC Coordinator at the time of the observations.