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Based on record review, video surveillance review, policy review and staff interview, it was determined, the hospital failed to adopt and enforce a policy to ensure compliance with the EMTALA requirements at 42 CFR 489.20 and 489.24 as evidenced the following:

Failure to provide a medical screening exam to a patient, who presented to the Emergency Department (ED) seeking medical care. The failure affected 1 of 21 sampled patients (Patient #21) as detailed in citation
A-2406.

Cross Refer to A-2406.

Based on record review, video surveillance review, policy review and interview, it was determined, the hospital failed to ensure the central log included all individuals who presented to the Emergency Department (ED) seeking treatment. This failure affected 1 of 21 sample patients (Patient #21).

The findings included:

Review of the facility policy titled "EMTALA Central Log" last reviewed on 05/2025 documents, "This policy reflects guidance under the Emergency Medical Treatment and Labor Act (EMTALA) and associated state laws only. It does not reflect any requirements of the Joint Commission or other regulatory entities.
Policy: The hospital will maintain a Central Log containing information on each individual who requests emergency services or care or whose appearance or behavior would cause a prudent layperson observer to believe the individual need examination or treatment, whether he or she left before a medical screening examination could be performed, whether he or she refused treatment, whether he or she was refused treatment, or whether he or she was transferred admitted or treated, stabilized and transferred or discharged.
The central log includes the patient logs from the traditional ED and either by direct or indirect reference, patient logs from any other areas of the hospital that may be considered dedicated emergency department's or where an individual may present for emergency services or receive a medical screening exam, such as labor and delivery.
Procedure:
All hospitals must maintain the Central Log in an electronic format. An electronic template that includes all federal requirements for EMTALA is available on Medictech for each market or division to customize.
The Central Log, including all additional logs incorporated into the Central Log by reference, shall be maintained in the same manner and with the same central core information. The logs must contain at a minimum, the name of the individual and whether the individual refused treatment, was refused treatment, was transferred, was admitted and treated, was stabilized and transferred, was discharged or expired.
A log entry for all individuals who have come to the hospital; seeking medical attention or who appear to need medical attention must be made by the appropriate individual. Further.
The Central Log of individuals who have come to the hospital seeking medical attention or who appear to need medical attention will be available within a reasonable amount of time for surveyor review and must be retained for a minimum of five years from the disposition of the individual."

Review of the surveillance video conducted on 06/05/25 at approximately 12 noon revealed the following:
On 05/01/25 at 4:10 PM, a Police Officer and Patient #21 are observed entering the emergency department through the main entrance.
At 4:11 PM, the officer interacts with the hospital Sheriff Police Officer and is directed to the triage desk.
At 4:11:49 PM, the officer and Patient #21 interacted with the triage nurse, later identified as Staff B.
At 4:13 PM, the officer and Patient #21 interacted with another staff that came over to the triage desk. The staff was later identified as Staff A (a translator).
At 4:15 PM, the officer and patient walked to the waiting room. The Officer asked the patient to sit in the lobby and got on the phone.
At 4:17 PM, the officer got off the phone, and the patient and officer were seen leaving the emergency department.

The video surveillance confirmed Patient #21 was not registered in the emergency department.

A phone interview with Staff A, Registered Nurse, was conducted on 06/04/25 at 12:50 PM. Staff A recalled the event and stated that she was called in to assist with translation, as Patient #21 spoke Spanish. Staff A explained the police told her the patient was under arrest and she was pregnant, looks like 35 weeks or so, the officer was supposed to take her to jail, but he wanted medical clearance. The staff recalls explaining that most likely due to her condition, she would need to be transferred to another hospital and then the officer took her. Staff A denied getting the patient's name to complete a registration and does not recall any further details.

A phone interview with Staff B, Registered Nurse, was conducted on 06/04/25 at 12:55 PM. Staff B recalled she was working at the triage desk on 05/01/25 and stated she does not recall the patient or the event, she is on vacation and there was a bad reception. Staff B was unable to explain why the patient was not registered and not seen by the provider. Staff B stated pregnant patients over twenty weeks most likely would be transferred to their sister facility for obstetric services and was unable to provide any further details regarding the interaction with Patient #21.

Review of the facility Emergency Department Central Logs dated 05/01/25 revealed the facility failed to maintain a record of every patient presenting to the emergency department. There was no record of Patient #21.

Based on policy review, record review, surveillance video review and interview, it was determined, the hospital failed to substantiate the provision of emergency services for 1 of 21 sampled patients (Patient #21) as evidenced by failure to perform a Medical Screening Exam (MSE) to determine if a medical condition exist and if so to provide care and treatment to relieve or eliminate the condition.

The findings included:

Review of the facility policy titled "EMTALA Medical Screening Examination and Stabilization" dated 05/2025 documents:
"Purpose: To establish guidelines for providing appropriate medical screening examinations ("MSE") and any necessary stabilizing treatment or an appropriate transfer for the individual as required by EMTALA, 42 U.S.C. S 1395dd, and all Federal regulations and interpretive guidelines promulgated thereunder, as well as section 395.1041, Florida Statutes, and all related administrative rules.
Policy: An EMTALA obligation is triggered when:
1. an individual or a representative acting on the individual's behalf, including EMS or a transferring hospital, requests emergency services and care; or
2. a prudent layperson observer observing an individual who comes to the dedicated emergency department ("DED") would conclude from the individual's appearance or behavior that the individual needs an examination or treatment of a medical condition.
Such obligation is further extended to those individuals presenting elsewhere on hospital property requesting examination or treatment for an emergency medical condition ("EMC"). Further, if a prudent layperson observer would believe that the individual is experiencing an EMC, then an appropriate MSE, within the capabilities of the hospital's DED (including ancillary services routinely available and the availability of on-call physicians), shall be performed. The MSE must be completed by an individual (i) qualified to perform such an examination to determine whether an EMC exists, or (ii) with respect to a pregnant woman having contractions, whether the woman is in labor and whether the treatment requested is explicitly for an EMC. If an EMC is determined to exist, the individual will be provided necessary treatment to relieve or eliminate the EMC, within the capacity and capability of the facility, or an appropriate transfer as defined by and required by EMTALA. Emergency treatment shall be applied in a non-discriminatory manner (e.g., no different level of care because of age, gender, disability, race, color, ancestry, citizenship, religion, pregnancy, sexual orientation, gender identity or expression, national origin, medical condition, marital status, veteran status, payment source or ability, or any other basis prohibited.
Procedure:
1. When an MSE is Required
A hospital must provide an appropriate MSE within the capability of the hospital's emergency department, including ancillary services routinely available to the DED, to determine whether or not an EMC exists: (i) to any individual, including a pregnant woman having contractions, who requests such an examination; (ii) an individual who has such a request made on his or her behalf; or (iii) an individual whom a prudent layperson observer would conclude from the individual's appearance or behavior needs an MSE. An MSE shall be provided to determine whether or not the individual is experiencing an EMC or a pregnant woman is in labor. An MSE is required when:
a. A request is made by the individual or on the individual's behalf for examination or treatment for a medical condition, including where:
i. The individual requests medication to resolve or provide stabilizing treatment for a medical condition.

b. The individual arrives on the hospital property other than a OED and makes a request or another makes a request on the individual's behalf for examination or treatment for an EMC.
f. If a law enforcement official requests hospital emergency personnel to provide medical clearance for incarceration, the Hospital has an EMTALA obligation to provide an MSE to determine if an EMC exists.

3. Extent of the MSE
a. Determine if an EMC exists. The hospital must perform an MSE to determine if an EMC exists. It is not appropriate to merely "log in" or triage an individual with a medical condition and not provide an MSE. Triage is not equivalent to an MSE. Triage entails the clinical assessment of the individual's presenting signs and symptoms at the time of arrival at the hospital in order to prioritize when the individual will be screened by a physician or other QMP.
b. Definition of MSE. An MSE is the process required to reach, with reasonable clinical confidence, the point at which it can be determined whether the individual has an EMC or not. It is not an isolated event. The MSE must be appropriate to the individual's presenting signs and symptoms and the capability and capacity of the hospital.
c. An on-going process. The individual shall be continuously monitored according to the individual's needs until it is determined whether or not the individual has an EMC, and if he or she does, until the EMC is relieved or eliminated or the individual is appropriately admitted or transferred. The medical record shall reflect the amount and extent of monitoring that was provided prior to the completion of the MSE and until discharge or transfer.

ii. Pregnant Women: The medical records should show evidence that the screening examination includes, at a minimum, on-going evaluation of fetal heart tones, regularity and duration of uterine contractions, fetal position and station, cervical dilation, and status of membranes (i.e., ruptured, leaking and intact), to document whether or not the woman is in labor. A woman experiencing contractions is in true labor unless a physician, certified nurse-midwife or other QMP acting within his or her scope of practice as defined by the hospital's medical staff bylaws.

Review of the surveillance video conducted on 06/05/25 at approximately 12 noon revealed the following:
On 05/01/25 at 4:10 PM, a Police Officer and Patient #21 are observed entering the emergency department through the main entrance.
At 4:11 PM, the officer interacts with the hospital Sheriff Police Officer and is directed to the triage desk.
At 4:11:49 PM, the officer and Patient #21 interacted with the triage nurse, later identified as Staff B.
At 4:13 PM, the officer and Patient #21 interacted with another staff that came over to the triage desk. The staff was later identified as Staff A (translator).
At 4:15 PM, the officer and patient walked to the waiting room. The Officer asked the patient to sit in the lobby and got on the phone.
At 4:17 PM, the officer got off the phone, and the patient and officer were seen leaving the emergency department.

The video surveillance confirmed Patient #21 did not receive a medical screening examination.

A phone interview with Staff A, Registered Nurse, was conducted on 06/04/25 at 12:50 PM. Staff A recalled the event and stated that she was called in to assist with translation, as Patient #21 spoke Spanish. Staff A explained the police told her the patient was under arrest and she was pregnant, looks like 35 weeks or so, the officer was supposed to take her to jail, but he wanted medical clearance. The staff recalls explaining that most likely due to her condition, she would need to be transferred to another hospital and then the officer took her. Staff A denied getting the patient's name to complete a registration and does not recall any further details.

A phone interview with Staff B, Registered Nurse, was conducted on 06/04/25 at 12:55 PM. Staff B recalled she was working at the triage desk on 05/01/25 and stated she does not recall the patient or the event, she is on vacation and there was a bad reception. Staff B was unable to explain why the patient was not registered and not seen by the provider. Staff B stated pregnant patients over twenty weeks most likely would be transferred to their sister facility for obstetric services and was unable to provide any further details regarding the interaction with Patient #21.

Interview with the Police Department Representative conducted on 06/06/25 at 11:46 AM revealed the sergeant, supervisor on duty on 05/01/25, replied to the surveyor's request for information and explained the hospital told the officer that was escorting Patient #21, that because the patient was 9 month pregnant, they could not monitor her or the baby and that it would be most beneficial to go to Hospital A for obstetric services.

Review of the facility Emergency Department records dated 05/01/25 revealed the facility failed to provide a Medical Screening Exam (MSE) to Patient #21.