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1701 NORTH GEORGE MASON DRIVE

ARLINGTON, VA 22205

COMPLIANCE WITH 489.24

Tag No.: A2400

Based on interviews and record reviews, it was determined the hospital staff failed to provide an appropriate medical screening exam for 1 of 23 sampled patients (Patient #1) and, therefore, failed to comply with Section 489.24- Special Responsibilities of Medicare Hospitals in Emergency Cases.
The findings include:
On the morning of 10/17/14, Hospital #1 received notification from Emergency Medical Services (EMS) that Patient #1 was being transported to the hospital. Information the hospital received indicated Patient #1 may have been exposed to Ebola, and had symptoms that may indicate an Ebola infection.
On 10/27/14 at 12:50 p.m. Hospital #1's Chief Medical Officer (CMO), Staff #1, and the Chief Nursing Officer (CNO), Staff #12, were interviewed about the events on 10/17/14. Staff #1 stated Hospital #1's emergency department staff and quarantine areas were ready to accept potential Ebola patients. With changing guidelines for the care of Ebola patients and staff safety, the hospital decided to create an ante room in their ICU unit, so staff would be able to don (put on) and doff (take off) personal protective equipment (PPE) in the ante room. In addition, staff would be able to enter the ante room without going into a hallway after providing care to a patient with Ebola. The construction on the ante room began the evening/night of 10/16/14 and was not yet completed the morning of 10/17/14. Therefore, though the emergency department (ED) was prepared to care for an Ebola patient, the hospital was not ready to admit such a patient.
When the EMS notification of Patient #1 ' s transport was received, Staff #1 (Chief Medical Officer) called and spoke with the Director of the Emergency Department (Staff #3 - a physician) at Hospital #2, to see if the second hospital could handle the patient. Since Patient #1 had vomiting and diarrhea, it was anticipated the patient would be admitted to a hospital. Staff #3 agreed to accept the patient at Hospital #2. After Hospital #2 had agreed to accept the patient, Staff #1 went to Hospital #1's emergency department, to have the ED staff notify EMS that Patient #1 was to be sent to Hospital #2. When Staff #1 arrived in the ED, he/she found the ambulance with Patient #1 had already arrived.
EMS #2 (an EMS physician) arrived at Hospital #1 prior to the patient arriving at the hospital. Staff #1 and EMS #2 had a discussion about sending Patient #1 to Hospital #2. This conversation lasted approximately 35-40 minutes, during which time the patient remained in the ambulance, care was provided by EMS staff.
The surveyor asked Staff #12 about Hospital #1 ' s preparedness for potential Ebola patients. This interview occurred on 10/27/14 at 1:15 p.m. Staff #12 stated the hospital ' s ED staff and ICU staff were trained and ready for a potential Ebola patient to be treated in Hospital #1's ED. When Patient #1 arrived at the ED, the staff was planning to provide care for the patient, had Personal Protective Equipment (PPE) on and was waiting in the designated ED room. Staff #12 stated an ante room was set up in the ED.
Hospital #1 ' s emergency department was prepared, and waiting to provide care for Patient #1. A medical screening exam was not performed at the hospital prior to the patient being sent to Hospital #2.
Please refer to A2400 for more detailed information.

MEDICAL SCREENING EXAM

Tag No.: A2406

Based on interviews, record reviews and document review, it was determined the facility staff failed to perform a medical screening exam for 1 of 23 patients in the survey sample (Patient #1), who presented to the hospital ' s emergency department.
Patient #1 arrived at the hospital on 10/17/14, via ambulance. The patient was subsequently transferred to a second hospital, without receiving a medical screening exam (MSE) while on the property of Hospital #1.
The findings include:
Patient #1was found to be ill (vomiting) on the morning of 10/17/14. EMS (Emergency Medical Services) responded to the event. During the response, Patient #1 allegedly indicated he/she had recently visited Western Africa.
On 10/27/14 at 12:50 p.m. Hospital #1's Chief Medical Officer (CMO), Staff #1, and the Chief Nursing Officer (CNO), Staff #12, were interviewed about the events on 10/17/14. Staff #1 stated Hospital #1's emergency department (ED) staff and quarantine areas were ready to accept potential Ebola patients. Over time, guidelines to the care of potential Ebola patients and staff safety changed. Staff #1stated the hospital decided to create an ante room in the intensive care unit (ICU) that was designated as the area where inpatient Ebola patients would be provided care. The ICU area had three (3) rooms; the middle room was to be used as the ante room. The ante room would allow staff more room to don (put on) and doff (take off) their personal protective equipment (PPE). Construction began the evening/night of 10/16/14 to make doors in the ante room, so staff could enter the ante room without going into the hallway. The construction was not yet finished on the morning of 10/17/14.
Staff #1 stated that on the morning of 10/17/14, the Administration was notified that a patient potentially infected with the Ebola virus (EBV) was coming via ambulance to the hospital, arriving in five minutes. Realizing the construction in the ICU was not yet completed, Staff #1 called and spoke with the Director of the Emergency Department at Hospital #2, to see if the second hospital could handle the patient. Since Patient #1 had vomiting and diarrhea, it was anticipated the patient would be admitted to a hospital. Staff #3 agreed to accept the patient at Hospital #2. After Hospital #2 had agreed to accept the patient, Staff #1 went to Hospital #1's emergency department, to have the ED staff notify EMS that Patient #1 was to be sent to Hospital #2. When Staff #1 arrived in the ED, he/she found the ambulance with Patient #1 had already arrived.
EMS #2 (an EMS physician) arrived at Hospital #1 prior to the patient arriving at the hospital. Staff #1 told EMS #2 of Hospital #2's agreement to accept Patient #1. Staff #1 and EMS #2 discussion of the transfer of Patient #1 lasted approximately 35-40 minutes. During the time of the conversation, the patient remained in the ambulance and care was provided by the EMS staff. The hospital staff did not provide an MSE while the patient was on the hospital property.
The surveyor asked Staff #12 about Hospital #1 ' s preparedness for potential Ebola patients. This interview occurred on 10/27/14 at 1:15 p.m. Staff #12 stated the hospital ' s ED staff and ICU staff were trained and ready for a potential Ebola patient to be treated in Hospital #1's ED. When Patient #1 arrived at the ED, the staff was planning to provide care for the patient, had Personal Protective Equipment (PPE) on and was waiting in the designated ED room. Staff #12 stated an ante room was set up in the ED, but the hospital was not ready if the patient needed to be admitted to the hospital, because the construction in the ICU was not yet completed. Staff #12 acknowledged it was Hospital #1's intention to be ready for any patient that may have a diagnosis of Ebola.
Staff #12 acknowledged the EMS ambulance personnel were not informed of each update the hospital made to prepare for potential Ebola patients, or that the hospital was not ready to accept inpatient Ebola patients, on the morning of 10/17/14. He/she also said there was a discussion about potentially keeping the patient in the ED until the construction was finished, but then they found out Hospital #2 had a ready containment unit. Staff #12 said the ED personnel were not aware of the construction project, or they could have told EMS when EMS called to notify the ED of the coming ambulance.
Staff #10, with Staff #7 in attendance, was interviewed on 10/27/14 at 2:30 p.m. Staff #10 and #7 were nursing managers in the ED (of Hospital #1). Staff #10 stated he/she was on duty when the call came in to the ED for the potential Ebola infected patient - with symptoms of vomiting and diarrhea. He/she stated the staff had completed training for Ebola patients, including the donning and doffing of PPE. After the EMS call was received, the team donned PPE and entered the room where they anticipated treating the patient. Additional staff was called to come in to work, to cover for the staff that would be working with the potential Ebola patient. Staff #10 also stated the staff in the PPE remained in the room to prevent other patients from seeing them in PPE and potentially becoming frightened. He/she stated the staff heard the ambulance arrive; administrative staff was outside talking with EMS staff. The ED staff was then informed the patient had been diverted to another hospital.
When the EMS call was received in the ED, Staff #11 (a physician) went to the ED to ensure the staff was ready to receive the patient. The physician stated the EMS staff informed the hospital staff that Patient #1 was stable and could stay in the ambulance to be completely contained during the discussion between Staff #1 and EMS #2. Staff #11 stated they then learned there were multiple persons who may have been exposed to Patient #1. They began to plan for a large number of people to be quarantined or hospitalized. Disaster planning then went into ' full swing ' . The physician also explained that in the prior month, the hospital had triaged three to four patients that had one or more criteria for Ebola (none were subsequently diagnosed with Ebola). Staff #11 stated he/she (or his/her physician partner) would be available whenever there may be a questionable EBV exposure.
On 10/29/14 at 12:10 p.m. the surveyor interviewed Staff #5, an ED physician. The physician stated Patient #1 arrived at Hospital #1 ' s ED and left without leaving the ambulance. They had been informed by EMS that the patient had symptoms of vomiting, diarrhea, and a history of travel to West Africa. He/she stated The ED Director at Hospital #2 made the final decision to accept Patient #1. The physician stated that most patients were stabilized prior to transport to another facility.
The surveyor interviewed Staff #15, an administrative staff member at Hospital #1. Though not present at the time of the event on 10/17/14, he/she had met with Staff #1 to review the events of that day. Staff #15 stated the hospital alliance between 14 hospitals in the region had been developed to address disaster preparedness situations. As part of the alliance, when patient needs were determined, members of the alliance addressed the right place to house the patient, and where treatment could best be handled. When Hospital #2 accepted Patient #1, Hospital #1 began preparing for the possible influx of persons who may have been exposed to Patient #1.
During the EMTALA survey, a policy and procedure revised last on 3/2013 titled " Transfer of Patients to other Facilities " , documented patient transfers must comply with the EMTALA federal regulations. This document described that the hospital would:
? Provide an appropriate Medical Screening Exam to any individual who came to the Emergency Department;
? Provide necessary stabilizing treatment to any individual with an emergency complaint or in labor;
? Provide a transfer to the a hospital when the hospital did not have the capability or capacity to provide the treatment necessary to stabilize or admit the individual.
The surveyor toured the ED and ICU of Hospital #1 on 10/27/14 at 2:00 p.m. Staff explained the Ebola protocols in each area of the tour. It was observed that doors were present between ICU room #1 and #2 and between ICU #2 and #3. The construction was complete.