Transfers

1
Transfers

• Nancy M. Ruzicka
• Director of Regulatory Compliance

2
Appropriate Transfer

• Transferring hospital must provide medical
  treatment within its capacity to minimize risks
  to person (and in case of woman in labor to the
  unborn child)
• Receiving hospital must have agreed, has space
  and qualified personnel
• Transferring hospital sends all medical records
  available at time of transfer
• Transfer is performed through qualified personnel
  and transportation

3
Transfer Issues

• Not providing all medical treatment within
  capacity
• Must provide the lab and x-ray testing on site in
  the hospital and not refer to physician office
• Discharge vitals within 15-30 minutes prior to
  transfer
• Can not just refer the patient away after
  providing treatment to minimize risk of transfer

4
Documentation issues

• Incomplete certification form
• Must include patient specific clinical benefits
  vs risks
• Signatures of both QMP and MD/DO must be dated
  and timed
• Lack of name of physician approving transfer
  surgeon on call or Dr Smith
• Lack of person accepting transfer Mary in OB

5
Receiving Facility Agrees

• Second requirement of appropriate transfer
• Must obtain permission from receiving hospital
• Permission must be prior to transfer
• Receiving hospital must have services sending
  hospital does not
• Document who name and title who accepted
• Document specifically what hospital including town

6
Send Medical Records

• Third requirement of appropriate transfer
• Send all available medical records with patient
• If test results become available after patient
  sent, FAX to receiving hospital or telephone
  results
• Document which records sent

7
Qualified Personnel and Equipment

• Fourth requirement of appropriate transfer
• Most problematic
• What is qualified personnel and equipment is
  patient and situation dependent
• Sending hospital determines appropriate mode,
  equipment

8
Transfer of Women in Labor

• Women in labor are ALWAYS unstable per CMS
  definition unless determined to be in false labor
• Of 118 community hospitals in Iowa, 85 hospitals
  still provide OB services (per IHA data)
• If not determined to be in false labor, should go
  via ambulance
• Refusal ambulance transfer, documentation

9
WOMEN IN LABOR

• TRANSFERRED ONLY IF PATIENT REQUESTS OR
• IF PHYSICIAN CERTIFIES THAT THE BENEFITS OF
  TRANSFER OUTWEIGH THE RISKS ( OF DELIVERY ENROUTE
  OR DELIVERING A NEWBORN AT A HOSPITAL WITH ONLY
  EMERGENCY BIRTH CAPABILITIES)

10
Transfer of Psychiatric Patients

• If suicidal or homicidal, recent deficiencies
  indicates these patients are in an EMC and
  unstable
• Many hospitals do not have the capability to
  resolve the psychiatric EMC and must transfer to
  a hospital that does
• Private vehicle transfer poses risk of violation
• In many cases, CMS has cited hospitals for not
  sending patients in either ambulance or secure
  supervised transfer (police/sheriff)

11
WHO ARE QUALIFIED STAFF?

• CASE BY CASE BASIS
• BASED UPON CLINICAL CONDITION OF PATIENT
• EMT STAFF MAY BE NOT ALWAYS BE ADEQUATE

12
Private Vehicle Transfers

• Rarely accepted as appropriate mode of transfer
• If patient is in an EMC or a woman in labor,
  usually cited
• Red Flag to surveyors in review of Central Log

13
Ambulances and EMTALA

• Ambulance operations subject to EMTALA if owned
  and operated by the hospitalnot simply medical
  direction
• If on hospital propertyeven non-hospital owned
  ambulances-EMTALA applies
• Not considered on the property unless physically
  there
• Only ability to divert is if the hospital is on
  diversion because it does not have staff or
  facilities to accept ADDITIONAL emergency
  patients
• If on property, even if hospital did not
  officially accept, then all EMTALA requirements
  applyMSE, Central log, stabilization and
  treatment, and appropriate transfer if needed

14
Ambulances and EMTALA

• EMTALA obligations not triggered by use of
  hospitals helicopter pad by local ambulance or
  other hospitals. Considered transist as long as
  sending hospital conducted the MSE prior to
  sending
• EMTALA would be triggered if patient deteriorates
  and staff request assistance in further
  stabilization or treatment