Problem
Topic: Evaluation Methods for Quality Initiative for EMTALA Complaint
Scenario:
Hospital A's chief financial officer (CFO) is concerned that there are two ongoing EMTALA investigations by the State Department of Health against Hospital A for two inappropriate patient transfers in the last two weeks. As part of its ongoing investigation, the State Department of Health noted that there was a failure to conduct a basic medical screening examination/stabilization for each patient in the emergency department of Hospital A. Sanctions against Hospital A are pending.
Complaints were originally filed by Hospital B (the receiving hospital) against Hospital A for the inappropriate transfer of two patients to Hospital B. This situation is more commonly known as "patient dumping." Both patients were over 60, lacked insurance, and had a history of heart failure. The two inappropriate transfers were by the same emergency physician.
Hospital A's leadership has identified a quality improvement plan with four initiatives related to EMTALA that they want to implement.
After looking at the evaluation methods and based on who would be legally liable for any violations of EMTALA and the potential sanctions for violations, would you recommend the hospital make any further changes to their EMTALA adherence processes?