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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 has noted was that there was a failure to conduct a basic medical screening examination/stabilization for each of the patients when 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 inappropriate transfer of two patients to Hospital B. This situation is more commonly known as “patient dumping.” Both patients were over age 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.
Multi-faceted quality improvement strategies to avoid EMTALA complaints, investigations, and sanctions:
Initiative 1: Require education on EMTALA for all current and new employees at the hospital. Commence with immediate education and then require annual EMTALA updates.
Initiative 2: Conduct a peer review of records for provider in the two complaints.
Initiative 3: Review contextual factors, such as whether the hospital was on diversion status, at time of the events.
Initiative 4: Review patient throughput through processes and provider staffing at the time of the incidents.
In your initial post, address the following:
Discuss whether you think the recent incidents were EMTALA violations.
Create evaluation methods for two out of the four initiatives of the quality improvement plan related to EMTALA. You should identify and describe any metrics that will be needed in your evaluation methods.
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