Critical Path Network
Rules have off-campus’ EMTALA application
Hidden in the hundreds of pages of regulations for the outpatient prospective payment system (OPPS) are important definition and language changes that create new hospital EMTALA obligations, says Stephen A. Frew, a Rockford, IL, health care lawyer who advises hospitals on the 1986 law.
Those obligations are based on off-campus, satellite, and remote site operations, he says. "HCFA [Health Care Financing Administration] has been warning hospitals about EMTALA applying to urgent care and other services located apart from the main hospital, but for the first time, these regulations create specific guidelines and require specific actions," he notes.
Under the new regulations, a hospital’s campus is defined as the main hospital building, a zone of 250 yards around the hospital (including parking lots, driveways, and hospital buildings), and HCFA-approved "provider-based services" (off-site locations, satellites, and remote hospital sites) that participate in the new OPPS, Frew adds.
Included, he says, are these EMTALA rules:
1. Covered sites must have policies and procedures for medical screening exams, including stabilization and either a response from the main hospital or a transfer to the main hospital, as appropriate.
2. Covered sites that do not have physicians must go through a formal process to designate a qualified medical person at the site.
3. Hospital policies must include response plans to areas within the 250-yard zone of the hospital.
4. Remote sites that might transport to a closer facility than the home hospital must have transfer agreements in place covering these circumstances.
"While not all hospitals have remote or satellite facilities to worry about, all hospitals do have to be concerned with the 250-yard exterior zone and formulate policies to deal with it," Frew says.
Additional information on the requirements and a link to the full text of the HCFA publication area available at Frew’s Web site at www.medlaw.com.
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