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Based on review of hospital EMTALA (Emergency Medical Treatment and Labor Act) policy and other policies, emergency department (ED) Central Log, ED medical records, video surveillance and interview, it was determined Greene County Hospital (GCH) failed to:

1. Adopt and enforce a policy to ensure compliance with EMTALA requirements to maintain a central log on each individual that comes to the ED.

2. Register two patients who presented to the hospital's ED via emergency medical service (EMS) with a chief complaint of motor vehicle accident on the ED Central Log, including Patient Identifier (PI) # 27 and PI # 28.

3. Provide a medical screening exam (MSE) for PI # 27 and PI # 28.

4. Provide an appropriate transfer for PI # 4 who was diverted to GCH for a MSE during EMS transport with a chief complaint of seizure while enroute to another facility.

This had the potential to affect all patients presenting to the ED at GCH.

Cross Refer to A 2406 and A 2409 for findings.

Based on review of the emergency department (ED) Central Log, hospital EMTALA (Emergency Medical Treatment and Labor Act) policy, video surveillance footage, and interview, it was determined the hospital failed to:

1. Adopt and enforce a policy to ensure compliance with EMTALA requirements to maintain a central log on each individual that comes to the ED.

2. Register two patients who came to the hospital's ED seeking assistance, including whether or not the patients refused or were refused treatment, or were admitted and treated, transferred or discharged.

This affected two of two patients with a chief complaint of motor vehicle accident (MVA), including Patient Identifier (PI) # 27, and PI # 28, who presented to the ED for emergent care via emergency medical services (EMS) transport on 6/17/25.

This had the potential to negatively affect all patients who presented to this hospital requesting emergency care.

Findings include:

1. Review of the hospital policy entitled EMTALA revealed the policy failed to include maintaining a central log on each individual that comes to the ED.

The surveyor requested the hospital's policy regarding maintaining a central log for patients presenting to the ED and none was provided.

2. Review of video surveillance still shots provided by the hospital revealed PI # 27 and PI # 28 arrived together at the hospital's ambulance entrance on 6/17/25 at 12:01:21 AM via EMS transport.

Continued review of the video surveillance still shots revealed PI # 27 and PI # 28 at the nurse station for the ED at 12:02:55 AM, then exiting via the ambulance entrance on 6/17/25 at 12:05:AM.

Review of the ED Central Log for 6/17/25 revealed a total of five ED patients were registered on the log. PI # 27 and PI # 28 were not registered on the Central Log at 12:02 AM on 6/17/25.

The hospital failed to register every patient presenting on hospital property seeking emergent care on their Central Log.

An interview was conducted on 6/24/25 at 11:58 AM with Employee Identifier (EI # 1, Chief Nursing Officer and ED Manager, who confirmed PI # 27 and PI # 28 were not registered on the ED central log.

Based on video surveillance footage, hospital policies and interview, it was determined Greene County Hospital failed to provide a medical screening exam (MSE) within the capability of their emergency department (ED) to determine whether or not an emergency medical condition (EMC) existed for two patients that presented via emergency medical services (EMS) transport to the hospital's ED.

This deficient practice affected Patient Identifier (PI) # 27 and PI # 28, and had the potential to affect all patients presenting to the ED needing an MSE.

Findings include:

Hospital Policy: EMTALA (Emergency Medical Treatment and Labor Act)
Policy Number: None
Original Date: 6/1/2021

Purpose:

To establish guidelines for tracking the care provided to each individual seeking care in a dedicated ED for a medical condition or seeking care in areas on hospital property...for an EMC as required of any hospital with an ED by EMTALA...

...Hospitals have three main obligations under EMTALA:

1. Any individual who comes and requests must receive a MSE to determine whether an EMC exists...

Hospital Policy: MSE
Policy Number: None
Revision Date: 07/2021

Policy Statement:

All individuals who present to the ED, on hospital property, or through ambulance transport requesting or appearing to need examination or treatment will receive a MSE performed by qualified personnel to determine the presence of an EMC.

1. Review of video surveillance still shots provided by the hospital revealed PI # 27 and PI # 28 arrived together at the hospital's ambulance entrance on 6/17/25 at 12:01:21 AM via EMS transport.

Continued review of the video surveillance still shots revealed PI # 27 and PI # 28 at the nurse station for the ED at 12:02:55 AM, then exiting via ambulance on 6/17/25 at 12:05:AM.

No evidence was provided by the hospital that PI # 27 and PI # 28 received a MSE before leaving the hospital to determine if an EMC existed.

An interview was conducted on 6/24/25 at 11:58 AM with Employee Identifier (EI # 1, Chief Nursing Officer and ED Manager, who confirmed PI # 27 and PI # 28 arrived via EMS transport with a chief complaint of motor vehicle accident on 6/17/25 and did not receive a MSE.

Based on medical record (MR) review, hospital EMTALA (Emergency Medical Treatment and Labor Act) policy, hospital central log, transfer log, and interview, it was determined Greene County Hospital failed to provide an appropriate transfer for one of nine emergency department (ED) MRs reviewed with a disposition of transfer.

This deficient practice affected Patient Identifier (PI) # 4, and had the potential to affect all patients transferred from this hospital's ED.

Findings include:

Hospital Policy: EMTALA
Policy Number: None
Original Date: 6/1/2021

Purpose:

To establish guidelines for tracking the care provided to each individual seeking care in a dedicated ED for a medical condition or seeking care in areas on hospital property...for an emergency medical condition (EMC) as required of any hospital with an ED by EMTALA...

...Hospitals have three main obligations under EMTALA:

...2. If an emergency medical condition (EMC) exists, treatment must be provided until the EMC is resolved or stabilized. If the hospital does not have the capability to treat the EMC, an "appropriate" transfer of the patient to another hospital must be done in accordance with the EMTALA provisions...

...What are the requirements for transferring patients under EMTALA?

EMTALA does not apply to the transfer of stable patients, however, if the patient is unstable, then the hospital may not transfer the patient unless:

- A physician certifies the medical benefits expected from the transfer outweigh the risks, OR

- A patient makes a transfer request in writing after being informed of the hospital's obligations under EMTALA and the risks of transfer.

- In addition, the transfer of unstable patients must be "appropriate" under the law, such that (1) the transferring hospital must provide ongoing care within its capability until transfer to minimize transfer risks, (2) provide copies of medical records, (3) must confirm that the receiving facility has space and qualified personnel to treat the condition and has agreed to accept the transfer...

1. PI # 4 was brought to the ED via emergency medical services (EMS) transport for a medical screening exam after EMS diverted to Greene County Hospital enroute to another facility (Hospital A) on 6/14/25 at 7:55 PM. PI # 4 had a chief complaint of seizure.

Review of the central log revealed PI # 4 was registered at 7:55 PM on 6/14/25.

Review of the MR revealed PI # 4 received a MSE at 8:19 PM by the physician. The physician documented in his/her History of Present Illness that he/she cleared PI # 4 for continuing to Hospital A.

Continued review of the MR revealed the registered nurse documented the following on 6/14/25 at 7:55 PM:

"MSE done, mode of departure was ambulance." "Patient was never moved from stretcher, personnel continuing their route to hospital."

Further review of the MR revealed there was no documentation the risks and benefits of transfer were explained to PI # 4, that PI # 4 consented to the transfer, nor that Hospital A was contacted and PI # 4 was accepted by a provider for transfer, and that the MR containing the MSE was sent with PI # 4 at time of transfer.

Review of the ED transfer log for 6/14/25 revealed PI # 4 was not listed on the log as a transfer.

An interview was conducted on 6/26/25 at 1:45 PM with Employee Identifier # 1, Chief Nursing Officer and ED Manager, who confirmed there was no documentation a transfer form was completed on PI # 4 which included risks and benefits of transfer, PI # 4's consent to transfer, an accepting provider at Hospital A, nor that the MR was sent with PI # 4 at time of transfer.