Are you asking for an EMTALA citation at registration?

CMS allows you to ask for two ID elements, such as name and address or name and D.O.B. but it does not allow you to require two forms of ID — or any ID –or to go through paperwork — or for the clerk to debate chief complaint.

“Well isn’t important that we get the exact details?” No, it is NOT important for a clerk to get a detailed history of the chief complaint. This fellow says he is passing blood and having difficulty voiding. The clerk does not have the role of taking a history or deciding if the patient needs to see the triage nurse. She was relatively pleasant, but does not seem to understand her appropriate role. Name, d.o.b., nature of complaint and on to the Triage nurse.

“But don’t we need consent to treat?” No, not prior to Triage. I have seen EMTALA citations for requiring financial consents on the typical consent form. CMS allowed the treatment consent following Triage, but not the financial consent, so in the case of a hospital I worked with on their plan of correct, the two consents had to be separated to get POC approval.

And by the way — the hospital which turned this guy away because he was recording his visit has a 100% probability of being cited for an EMTALA violation. There is nothing in EMTALA that says you must provide triage and MSE “unless the patient is recording his visit.”

Now that we know that Hospital 1 appears to have improperly turned this patient away and refused emergency care under EMTALA, would your clerk know that you have an obligation to report the other hospital for a possible EMTALA violation or face a violation for failure to report?

And what was the side discussion? Was the clerk talking to a nurse or two another patient also being signed in? If it was the latter, we probably have a HIPAA issue as well.