Tips for developing EMTALA compliance program
Awareness of EMTALA responsibilities often requires medical staff bylaws action which, in itself, is a process that requires recognition of the rules, recognition of patterns of violation, and established disciplinary action. Following are some areas that must be addressed:
· Assure that the ability of the patient to pay is never an issue in assessing the patient's condition and level of treatment.
· Provide on-call performance "report cards" to each department.
· Maintain logs of on-call staff response times.
· Document request times for on-call physician assistance and log in the arrival time to the ED for all consultants.
· Evaluate consultant performance on established, objective criteria.
· Educate medical staff to recognize that EMTALA rules apply to entire hospital, not just the ED.
· Assign the authority to develop and maintain call schedules.
· Address vacation, holiday, and sick leave coverage for on-call physicians.
· Address concerns for physicians with on-call schedules at multiple facilities.
· Address issues surrounding office appointments during on-call schedule to provide assurance that scheduled appointment will not interfere with ED call.
· Insist that medical staff bylaws require specialists to write their own admission orders and attend to their patients accordingly.
· Develop and maintain a medical staff quality assurance program relating to EMTALA issues.
· Assure all medical staff understand EMTALA requirements through inservice programs.
· Maintain and report results of repeated failure of on-call physicians to attend to ED patients.
· Monitor lack of hospital oversight of problem specialists.
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