You may have some EMTALA signs, but you still may get cited for IMPROPER DISPLAY.

When it comes to ED EMTALA signs, many EDs discover they are usually a “Gotcha”.

Do you think I am kidding, then check out actual language from an EMTALA citation:

Location 1 (satellite ED):

1. Observation of the ambulance entrance revealed no signage posted.
2. Observation of trauma room revealed one sign. The sign was obstructed by a cardiac monitor, making visualization difficult.
3. Observation of ED entrance revealed one sign. The sign was obstructed by a bassinet, making visualization difficult.
4. Observation of main entrance waiting room revealed one sign posted in an area that is not visible from where patients are seated.
5. Observation of Triage room revealed no signage posted.
6. Observation of ED isolation room revealed no signage posted.

Other citations include issues such as:

• No signs in OB unit waiting unit
• No signs in waiting area for psych intake department.
• No signs in waiting room or exam rooms in OB unit.
• No signs in urgent care area.
• “Co-pay due at time of service” signage conflicts with EMTALA sign.
• “Average cost of services sign” conflicts with EMTALA sign.
• Sign in cluttered wall that rendered it not “conspicuous.”
• Sign not readable from 20 feet away.
• State mandated warning to Medicaid recipients conflicts with EMTALA sign and law.
• Not visible from every patient seating position in the waiting area.
• Signs not present in the “xxxxxxxx” language
• Spanish version not the same size as English version.

It is hard enough to have a site visit for EMTALA, but you don’t want to start the survey out with a violation staring the investigator in the face the minute they walk into your ED area. Very often things go downhill from there.

Paying attention to the “little” things like the EMTALA signs usually means you are paying attention to the bigger things as well.

See PP 195-202 EMTALA Field Guide – Third Edition.

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