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Page 8

lifeline APRIL 2017

GENDER DISPARITIES IN STROKE CARE

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4 PRESIDENT’S MESSAGE

6 ADVOCACY UPDATE

8 GUEST ARTICLE

12 ORIGINAL RESEARCH

20 ANNOUNCEMENTS

21 UPCOMING MEETINGS & DEADLINES

22 CAREER OPPORTUNITIES

4

California ACEP Board of Directors & Lifeline Editors Roster2016-17 Board of DirectorsLawrence Stock, MD, FACEP, PresidentAimee Moulin, MD, FACEP, President-ElectChi Perlroth, MD, FACEP, Vice PresidentVikant Gulati, MD, Treasurer Vivian Reyes, MD, FACEP, SecretaryMarc Futernick, MD, FACEP, Immediate Past President John O. Anis, MD, FACEPJohn Coburn, MDCarrieann Drenten, MDKevin Jones, DOJohn Ludlow, MD, MBASujal Mandavia, MD, FACEP (At-Large)Valerie Norton, MD, FACEPMaria Raven, MD, MPH, FACEP Nicolas Sawyer, MDJames C. Tse, DO, CAL/EMRA PresidentLori Winston, MD, FACEPVacancy

Advocacy FellowshipAimee Moulin, MD, FACEP, Director

Lifeline Medical EditorRichard Obler, MD, FACEP, Medical Editor

Lifeline Staff EditorsElena Lopez-Gusman, Executive DirectorRyan P. Adame, MPA, CAE, Deputy Executive DirectorKelsey McQuaid, MPA, Government Affairs AssociateTyler Jimenez, Program Associate Lucia Romo, Education Coordinator

APRIL 2017 Index of AdvertisersADVANCED Page 11

Board of Directors Election Page 10

CEP America Page 19

Emergency Groups’ Office Page 11

Emergency Medical Management Associates Page 5

Emergency Medicine Specialists of Orange County Page 22

Emergency Physician Associates of San Jose Page 22

Emergency Physician Management (Parkview) Page 22

Emergency Physician Management (Southern California Hospital) Page 22

Fountain Valley Regional Hospital Page 22

Independent Emergency Physicians Consortium Page 11

Intercommunity Emergency Medical Group Page 22

International Trauma Life Support Page 23

Lance Orr, MD Page 22

Legislative Leadership Conference Page 18, 24

Philip J. Fagan, MD (Los Angeles) Page 22

Philip J. Fagan, MD (Southern California) Page 22

Pinnacle Emergency Physicians Page 22

8GENDER

DISPARITIES IN STROKE

CAREBRIEFING THE CAPITOL COMMUNITY

ON COMMUNITY PARAMEDICINE

2 | LIFELINE a forum for emergency physicians in california

TABLE OF CONTENTS |

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Central Coast Emergency Physicians

Emergent Medical Associates

Emergency Medicine Specialists of Orange County

Front Line Emergency Care Specialists

Loma Linda Emergency Physicians

Napa Valley Emergency Medical Group

Newport Emergency Medical Group, Inc at Hoag Hospital

Pacific Emergency Providers, APC

Tri-City Emergency Medical Group

University of California, Irvine Medical Center Emergency Physicians

Sumit Aarora

Sophia Ahmed

Sergio Alvarez MD

Krystal M Baciak MD

Benjamin Barmaan

Stacey K Barnett

Roland Bastian MD

Cortlyn W Brown MD

Patrick Brown

Tiffany L Cheng MD

Theodore Doherty

Carly E Dougher

William Downes

Montessa L Edwards MD

Nadia Faiq

Zachary Flaming

Morgan L Garner

Alexander Garrett

Michael A Gisondi MD

Alexandra N Grossman MD

Alfredo Guerrero

Marissa Haberlach

Shirin E Kasturia MD

David Kenneally

Michel G Khoury

Katherine E Kroll MD

Brandon Kuang

Christina Liou

Michael Madatovian

Jessica Mason MD

Peter N McCorkell MD

Robert Milanes MD

John A Muraski

Kristi Ontiveros MD

Devan Pandya

John Roberts MD

Chris Roden DO

Smitha Sarma

Luiz Souza-Filho MD

Zetha Sovyanhadi

Joshua Sugino

Benjamin R Supat

Justin Dwight Tsai MD

Zhou Zhang MD

Jessica B Zhang MD

WELCOME new members!

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APRIL 2017 | 3

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PRESIDENT’S MESSAGE |

By Larry Stock,MD, FACEP

LLC is democracy in action. You do not need to be a policy expert to have an impact. Your stories are powerful and authentic. They express your real world emergency medicine (EM) experience that California lawmakers need to hear.

I am writing this message on February 28, 2017 the afternoon before President Trump addresses a joint session of Congress and the day after he met with the nation’s governors. According to the New York Times, the President commented to the governors regarding health care policy-making: “I have to tell you, it’s an unbelievably complex subject. Nobody knew that health care could be so complicated.” 1

The President has stated repeatedly that he believes Obamacare has been a complete disaster for the American people. Many of those critical of the Affordable Care Act (ACA) have expressed that the ACA offered expanded coverage for the poor and those with pre-existing conditions at the expense of those citizens who had been happy with

their health care coverage prior to the ACA. Republican leaders have revealed a sketch of what they would like to see happen. President Trump and the Congressional Republicans state they intend to repeal (part or all of ) the ACA and replace it nearly simultaneously with a plan to ensure all Americans have access to health care coverage. They intend to repeal the individual mandate to obtain health insurance or face tax penalties. They also intend to repeal the employer mandate for larger companies to provide health insurance to their workers or face penalties. They intend to remove income-based subsidies, for those who purchase insurance through the health insurance exchanges, and replace them with age based tax credits, assuming older Americans need more help than younger Americans.

The Medicaid expansion that occurred in 30 states helped cover the working poor. Under the Trump/Republican plan, federal Medicaid dollars would flow to the states as block grants or as a per capita distribution. This would challenge each state to take responsibility

Dear Colleagues,

Please join me at California ACEP’s 2017 Legislative Leadership Conference (LLC) to be held on Tuesday, May 2nd in Sacramento. The 28th Annual LLC is your opportunity to talk to your legislators face-to-face and advocate for your specialty and your patients.

Please go to this link to sign up: http://californiaacep.org/event/2017-llc/

IT’S COMPLICATED:REPEAL, REPLACE, REPAIR

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for eligibility and benefits, with fewer federal resources than under the ACA. One perspective is that the Washington would reduce government regulations and mandates, allowing states to innovate and more efficiently tailor their programs to their residents’ needs. Another perspective is that Washington is transferring responsibility for the care of low income people on to the states, limiting Federal expense and accountability.

The proposed plan would keep popular elements of the ACA including requirements for health plans not to charge premiums to older policy holders more than three times younger policy holders, to cover everyone and not charge more regardless of pre-existing conditions, and allow dependents up to age 26 to stay insured on their parents’ policy. This plan would favor expanding the use of health savings accounts (HSA) coupled with high deductible insurance plans. These “catastrophic” health plans are more consistent with the traditional concept of “insurance”.

The health care coverage and economic uncertainty raised by these proposed changes has resulted in reactions by individuals, insurance companies, and state elected officials. Individuals, with and without pre-existing conditions, are thinking about how they and their family will afford to stay adequately insured in the future. Some insurance companies are threatening to pull out of the health exchange and individual health insurance markets and there is concern about further health insurance rate increases. State governors and legislators are wrestling with budget planning while attempting to maintain health coverage for the poor within their states.

Our members have thoughts about the ACA that run the full range of informed opinion. One aspect we can agree on is that the ACA reduced the number of low income Americans without health care coverage. 20 million more Americans have health care coverage thanks to the ACA. California’s low income and uninsured residents may have benefitted more than any other state. Our uninsured rate dropped from 17% to 8.5%, resulting in 5 million more Californians having some kind of health care coverage. 3.7 million residents gained coverage through Medicaid and 1.4 million more residents have health insurance through Covered California. For those of us serving low income areas, many of our patients went from being uninsured to having some sort of coverage, helping to ensure greater access to care.2 After providing uncompensated, EMTALA mandated safety net care for years, emergency medicine physicians have experienced an actual move towards compensation for emergency care that previously would have been unfunded.

Currently, one third of Californians are on Medicaid. $20 Billion in ACA funds currently flow from the Federal government to California, $15 Billion for the Medicaid expansion and $5 Billion for health exchange subsidies.3 There is little doubt that what happens in Washington DC regarding the ACA, and particularly Medicaid, will have a major impact on Sacramento and on the structure of health care coverage enrollment. Regardless of where you are on the political spectrum, this is a time where your voice and expertise is needed to help determine the future of health care in California. Access to high quality and high value emergency care for all Californians will remain a fundamental California ACEP priority. Please come to Sacramento to the Legislative

• Excellent Opportunities for Emergency Physicians

• Very Competitive Compensation

• Hospitals include Arcadia Methodist & Glendale Memorial (Top heart programs).

• Available practice settings in the Greater Los Angeles area.

Contact Debbie Corn for more information(909) 634-3172 or email CV to [email protected]

Southern CaliforniaJOB OPPORTUNITIES

REFERENCE:1. New York Times, Trump Concedes Health Law Overhaul Is ‘Unbelievably

Complex’, ROBERT PEAR and KATE KELLY, FEB. 27, 2017.

2. California Health Care Foundation, Facts and Figures on the ACA in Cali-fornia: What We’ve Gained and What We Stand to Lose, November, 2016.

3. California Budget & Policy Center, With Trump’s Victory, Millions of Cali-fornians Are at Risk of Losing Access to Affordable Health Care Coverage, Scott Graves, November 15, 2016.

Leadership Conference on May 2nd to help determine our collective future. n

Thanks,

LarryP.S.On Friday 3/24/17 at 3pm EST Speaker of the House Paul Ryan called President Trump and informed him that they did not have the votes in the House of Representatives to pass the American Health Care Act. President Trump told Ryan to withdraw the bill, only 18 days after it was introduced. The AHCA was too stingy for the moderate and too generous for the conservative House Republicans. For now the ACA, with its essential health benefits, including Emergency Services, will remain the law. California’s health coverage expansion will stay intact, for now.

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BRIEFING THE CAPITOL COMMUNITYON

ADVOCACY UPDATE |

California ACEP’s goal for the briefing was

to create greater awareness of the State’s

community paramedicine projects and the

current data and research on the topic. We

also used this as an opportunity to clarify our

position on community paramedicine and

alternate destinations.

As with any change in medical interventions and care delivery, there needs to be extensive scientific research to ensure patient safety. We vigorously test and research use of different interventions and medications in the field prior to changing our standard of care; instituting the practice of alternate destinations should be no different. There have been a number

of community paramedicine programs launched across the country, but few, if any, have published their data in a peer reviewed journal, making it impossible to determine which programs are the safest and most effective and which factors and protocols are necessary to replicate that safety in other programs.

Different community paramedicine programs being piloted in California present different levels of risk and merit different levels of evidence of their safely and effectiveness. Home visits to an individual enrolled in hospice or a patient who has recently been discharged from the hospital with a clear diagnoses and is not otherwise receiving home care carries a lower risk. These programs are very promising and should be tested further to validate their safety and protocols for application across the state. On the other hand, diverting an individual with an undifferentiated condition away from the ED after that individual called

On March 24th, California ACEP hosted a lunchtime policy briefing for Capitol staffers on the topic of community paramedicine and alternate destinations. Board members Maria Raven, MD, MPH, MSc, FACEP and Aimee Moulin, MD, FACEP provided legislative staffers and other interested stakeholders with an overview of California’s emergency care system and the current research on community paramedicine.

COMMUNITY PARAMEDICINE

COMMUNITY PARAMEDICINE

Author: Elena Lopez-Gusman & Kelsey McQuaid, MPA

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911 carries a high risk. Individuals who call 911 are a more complicated patient population that those who present in-person to the emergency department. Initial data from the Stanislaus County behavioral health diversion program has produced the most thorough data of any alternate destination program, but requires further analysis to test the strength of the data and to evaluate long-term patient outcomes. It is still too soon to tell whether the outcomes achieved in Stanislaus County can be replicated elsewhere and what criteria would need to be required to ensure replicability.

California ACEP fought to require Independent Review Board approval for all community paramedicine pilot programs in California, not just the alternate destination pilots, because we wanted to ensure patient safety and oversight. Unfortunately, the California pilot programs were not set up with the intent to collect statistically valid data upon

which good policy could be created. The number of patients is so limited for some of the pilot programs that we can’t draw valid conclusions. Likewise, there is no control group and patients are not tracked for an extended period of time so it is difficult to assess the true impact of the programs, both on patient safety and cost to the healthcare system.

We should establish scientifically stringent pilot programs that will produce useful, statistically significant data upon which future policy can be built. The Legislature should not authorize alternate destination community paramedicine statewide, without the necessary, peer reviewed data that demonstrates which triage criteria and program components are effective.

We take seriously the oath to do no harm, and want to ensure that patients receive safe, timely emergency care. Emergency physicians are pioneers who have been innovators in

delivering life-saving medical care, but we should not charge ahead without proper evidence. We can advance emergency care, but we must do it in a way that is safe and scientifically validated.

Community paramedicine is not the solution to emergency department crowding; boarding has been long proven to be the cause. However, it is one of a number of ideas to change the delivery of health care. Meaningful solutions for achieving better access to care for patients must also include extended primary care hours, expanded insurance coverage, streamlined transfer for mental health and medical inpatient care, and improved case management in the community.

As with all of our advocacy efforts, we welcome your input and hope that you will join us in our efforts to advance emergency medicine in California. If you have any questions, please contact us at [email protected]. n

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GUEST ARTICLE |

The incidence of stroke is higher as people get older, and is higher in men than women up to age 84. Over the age of 85, however, the incidence of stroke is higher in women than in men, and the lifetime risk of stroke is higher in women overall (probably because women have a longer lifespan than men). In fact, every year 55,000 more women suffer a stroke than men. Women are also more likely to suffer from recurrent strokes. The severity of strokes between men and women is debated, but likely similar.

The gender differences do not stop here; they extend to mortality, functional outcomes, treatment rates, and appropriate and timely diagnosis of stroke. In patients over the age of 85, women have a 15% higher stroke mortality than age-matched men. Several studies showed that functional outcomes at 3-6 months were worse in women and more women required dependent living

situations after hospital discharge. This may be because of their older age or poorer pre-stroke functional status. It may also be related to the higher rate of post-stroke depression or less optimal social situations found among women. Because women have strokes at an older age, they more often live alone and have fewer social supports.

To better understand the gender disparities in the treatment of stroke, we should first look at the differences between how men and women present to the emergency department (ED). Women presenting with strokes are less likely to smoke cigarettes or drink alcohol than men. Women are less likely to have a history of heart disease, but are more likely to have hypertension and atrial fibrillation. Also, there is a higher risk of stroke during pregnancy and in the post-partum period, which is unique to women.

Once women present to the ED with an acute stroke, they are less likely than men to receive IV tPA. This is likely because they tend to be older or because they often live alone and their last-known-well-time is unclear. However, even when adjusted for these factors, studies indicate they receive less aggressive tPA therapy than men, despite studies showing that women respond better to IV tPA than men. Once hospitalized for their first stroke, women are less likely to be treated with antithrombotic drugs and less likely to undergo brain MRI, echocardiography, or carotid investigation.

As far as stroke prevention, women are less likely to have adequate blood pressure control or be on statins, and are less likely to receive anticoagulation when found to have atrial fibrillation. Women suffer more from cardioembolic strokes whereas men are more prone to atherothrombotic strokes.

The data on gender disparities in stroke management is complex and sometimes mixed. The etiology of the disparity is multifactorial. It is likely contributed to by others yet to be elucidated, such as preferences around care plans in women over the age of 85, less frequent use of evidence-based care chosen by the patient or family, or physician-related factors. But, the important thing is to recognize the disparity exists.

Now that studies show improved outcomes and a clear benefit from endovascular therapy

Acute stroke management has been a controversial topic among emergency physicians and neurologists for years. However, four landmark studies in 2015 demonstrated benefit from endovascular therapy in cases of large vessel strokes. Given improved outcomes for patients with large vessel strokes it only makes sense that we would want both men and women to similarly reap these benefits when suffering from a stroke. Yet, studies consistently demonstrate gender disparities in the diagnosis and treatment of stroke.

By Vivian Reyes, MD

GENDER DISPARITIES

IN STROKECARE

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in large vessel strokes, we need to be all the more aware of this gender disparity so women can be appropriately diagnosed, imaged, and treated. The first step as emergency physicians is to recognize this phenomenon, and some even argue we should shoot for positive discrimination toward women in the field of stroke, until this gap dissolves.

After looking at the studies on this topic, what has struck me is that the traditional stroke patient I learned about in medical school was a 70 year old male smoker with hypertension and severe cardiovascular disease; this is no longer the pathognomonic stroke patient. Today, I’m not actually sure there is a “pathognomonic stroke patient.” Instead, as emergency physicians, we need to consider the diagnosis of stroke in all pregnant, post-partum, or any adult patient with neurologic symptoms, regardless of age or gender. Until we shed our deeply ingrained vision of the tobacco-smoking male stroke patient, gender disparities in stroke care will persist.

In an effort to increase awareness and educate ourselves and our patients, there is more information on stroke risk in women at the American Heart Association’s “Go Red for women” website at https://www.goredforwomen.org/about-heart-disease/heart_disease_research-subcategory/new-guidelines-reduce-stroke-risk-women/ and the American Stroke Association website http://www.strokeassociation.org/STROKEORG/AboutStroke/Women-Have-a-Higher-Risk-of-Stroke---Infographic_UCM_460403_SubHomePage.jsp#.

• Goyal M, Demchuk AM, Menon BK, et al. Ran-domized Assessment of Rapid Endovascular Treatment of Ischemic Stroke. N Engl J Med 2015; 372:1019-1030.

• Saver JL, Goyal M, Bonafe A, et al. Stent-Retriever Thrombectomy after Intravenous t-PA vs. t-PA Alone in Stroke. N Engl J Med 2015; 372:2285-2295

• Campbell BCV, Mitchell PJ, Kleinig TJ, et al. En-dovascular Therapy for Ischemic Stroke with Perfusion-Imaging Selection. N Engl J Med 2015; 372:1009-1018.

• Berkhemer OA, Fransen PSS, Beumer D, et al. A Randomized Trial of Intraarterial Treatment for Acute Ischemic Stroke. N Engl J Med 2015; 372:11-20

• Reeves MJ, Fonarow GC, Zhao X, et al. Quality of Care in Women With Ischemic Stroke in the GWTG Program. Stroke. 2009;40:1127-1133.

• Reeves M, Bhatt A, Jajou P, et al. Ischemic Stroke: A Meta-AnalysisSex Differences in the Use of Intravenous rt-PA Thrombolysis Treatment for Acute. Stroke. 2009;40:1743-1749.

• Persky RW, Turtzo LC, McCullough LD. Stroke in Women: Disparities and Outcomes. Curr Cardiol Rep. 2010 January ; 12(1): 6–13.

• Giralt D, Domingues-Montanari S, Mendioroz M, et al. The gender gap in stroke: a meta-analysis. Acta Neurol Scand. 2012 Feb;125(2):83-90.

• Reed SD, Cramer SC, Blough DK, et al. Treatment With Tissue Plasminogen Activator and Inpa-tient Mortality Rates for Patients With Ischemic

Stroke Treated in Community Hospitals. Stroke. 2001;32:1832-1840.

• Bushnell C, McCullough LD, Awad IA, et al. Guide-lines for the Prevention of Stroke in Women A Statement for Healthcare Professionals From the American Heart Association/American Stroke As-sociation. Stroke. 2014;45:000-000.) n

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Nadia Zuabi, BS* Larry D. Weiss, MD, JD† Mark I. Langdorf, MD, MHPE*

*University of California Irvine, Department of Emergency Medicine, Irvine, California †University of Maryland, Department of Emergency Medicine, Baltimore, Maryland

Section Editor: Gregory Moore, MD, JD Submission history: Submitted January 5, 2016; Revision received February 23, 3016; Accepted March 13, 2016 Electronically published May 4, 2016 Full text available through open access at http://escholarship.org/uc/uciem_westjem DOI: 10.5811/westjem.2016.3.29705

INTRODUCTION: The Emergency Medical Treatment and Labor Act (EMTALA) of 1986 was enacted to prevent hospitals from “dumping” or refusing service to patients for financial reasons. The statute prohibits discrimination of emergency department (ED) patients for any reason. The Office of the Inspector General (OIG) of the Department of Health and Human Services enforces the statute. The objective of this study is to determine the scope, cost, frequency and most common allegations leading to monetary settlement against hospitals and physicians for patient dumping.

METHODS: Review of OIG investigation archives in May 2015, including cases settled from 2002-2015 (https://oig.hhs.gov/fraud/enforcement/cmp/patient_dumping.asp).

RESULTS: There were 192 settlements (14 per year average for 4000+ hospitals in the USA). Fines against hospitals and physicians totaled $6,357,000 (averages $33,435 and $25,625 respectively); 184/192 (95.8%, $6,152,000) settlements were against hospitals and eight against physicians ($205,000). Most common settlements were for failing to screen 144/192 (75%) and stabilize 82/192 (42.7%) for emergency medical conditions (EMC). There were 22 (11.5%) cases of inappropriate transfer and 22 (11.5%) more where the hospital failed to transfer. Hospitals failed to accept an appropriate transfer in 25 (13.0%) cases. Patients were turned away from hospitals for insurance/ financial status in 30 (15.6%) cases. There were 13 (6.8%) violations for patients in active labor. In 12 (6.3%) cases, the on-call physician refused to see the patient, and in 28 (14.6%) cases the patient was inappropriately discharged. Although loss of Medicare/Medicaid funding is an additional possible penalty, there were no disclosures of exclusion of hospitals from federal funding. There were 6,035 CMS investigations during this time period, with 2,436 found to have merit as EMTALA violations (40.4%). However, only 192/6,035 (3.2%) actually resulted in OIG settlements. The proportion of CMScertified EMTALA violations that resulted in OIG settlements was 7.9% (192/2,436).

CONCLUSION: Of 192 hospital and physician settlements with the OIG from 2002-15, most were for failing to provide screening (75%) and stabilization (42%) to patients with EMCs. The reason for patient “dumping” was due to insurance or financial status in 15.6% of settlements. The vast majority of penalties were to hospitals (95% of cases and 97% of payments). Forty percent of investigations found EMTALA violations, but only 3% of investigations triggered fines. [West J Emerg Med. 2016;17(3):245–251.]

EMTALAEmergency Medical Treatment and Labor Act

2002-15: Review of Office of Inspector General Patient Dumping Settlements

ORIGINAL RESEARCH |

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INTRODUCTION

The Emergency Medical Treatment and Active Labor Act (EMTALA) of 1986 was enacted to prevent discrimination of patients in hospital emergency departments (ED). During its debates and public hearings, Congress expressed its intent to ban financial discrimination and resultant “dumping” of uninsured patients on public hospitals. However, in its final legislated form, EMTALA bans discrimination of ED patients for any reason. It was enacted as part of the Consolidated Omnibus Budget Reconciliation Act (initially designated COBRA, 1985), 1 and modified as the Omnibus Budget Reconciliation Act (OBRA) of 1989. Increasing instances of refusal of care to patients with emergency medical conditions (EMC) prompted Congress to pass this unfunded mandate that required hospitals to:

1. Provide appropriate medical screening examinations (MSE) to the point of identifying or excluding an EMC

2. Stabilize EMCs according to the hospital’s capabilities

3. Provide timely consultation, treatment and hospitalization for the EMC within the “capacity” of the treating hospital and medical staff

4. Appropriately transfer unstable patients to a higher level of care (HLOC) if benefits outweigh the risks of transfer

5. Report known violations by hospitals and physicians receiving such transfers

In addition, the statute provided civil penalties for violation upon both hospitals and physicians. It is investigated by the Office of the Inspector General (OIG) of the Department of Health and Human Services’ (HHS) Centers for Medicaid and Medicare Services (CMS).2

EMTALA defines an EMC as either (1) a medical condition manifesting itself by acute symptoms of sufficient severity (including severe pain, psychiatric disturbances and/or symptoms of substance abuse) such that the absence of immediate medical attention could reasonably be expected to result in: placing the individual’s health (or, with respect to a pregnant woman, the health of the woman or her unborn child) in serious jeopardy; or serious impairment to bodily functions; or serious dysfunction of any bodily organ or part; or (2) with respect to a pregnant woman who is having contractions, that there is inadequate time to effect a safe transfer to another hospital before delivery, or that the transfer may pose a threat to the health or safety of the woman or the unborn child.3

Potential penalties for both hospitals and physicians are severe, despite the fact that neither is compensated for the cost of providing care to uninsured or underinsured patients. Physicians and hospitals are fined up to $50,000 per incident for failing to comply with EMTALA and are also at risk of exclusion from federally funded Medicare and Medicaid programs for repeated or flagrant violations.1 Furthermore, physicians and hospitals are liable regardless of intent, as determined in Roberts v. Galen, an EMTALA case that reached the U.S. Supreme Court in 1999.4

The regional offices of HHS and CMS are responsible for investigating complaints of alleged EMTALA violations and forwarding confirmed

violations to the OIG for possible imposition of civil monetary fines.2 The regional CMS office usually delegates the initial onsite investigation to a state department of health.

Compliance with the EMTALA statute is difficult and costly, as every patient who has been deemed to have “come to the ED” must have an evaluation to exclude an EMC. Even the U.S. General Accounting Office (GAO) outlined some of these difficulties in a 2001 report. They include overcrowding from increasing ED patients with non-urgent complaints and reduced ED on-call specialist panels due to the inadequate compensation to care for a large number of uninsured patients. Furthermore, this report highlighted ambiguous regulations, including which satellite hospital sites fall under the EMTALA mandate.2

Despite 300 federal court decisions expanding interpretation of the statute with case law, the HHS maintains no ongoing transparent and public reporting system for potential violations. Even the U.S. GAO has criticized the OIG enforcement as inconsistent and weak.5 While the OIG publicly discloses settlements on its website, these have not been compiled or analyzed since 2006.6

This paper provides an update on the activity of EMTALA settlements reported by the OIG, as well as the scope, cost, frequency, regional location, and most common allegations leading to settlements by hospitals and physicians for EMTALA violations. The descriptions of these settlements uniformly include a statement that settlements were made without admission of guilt on the part of hospitals or physicians.

METHODS

We reviewed the OIG EMTALA archives in May 2015, which included EMTALA cases settled from 2002-2015.7 (https://oig.hhs.gov/fraud/enforcement/cmp/patient_dumping. asp accessed May 2015 with most recent report 3/17/15.)

Each settlement includes a one-paragraph synopsis of the case, with varying detail. The website uniformly names the hospital, state, physician name (if applicable), and amount of fine. None mentioned loss of federal funding as a consequence. The description often included the general clinical diagnosis of the patient, mechanism of injury and age, and most importantly, category of alleged violation. Age was not uniformly reported, and at times the description included reference to multiple patients per report without ages.

Narrative descriptions were codified by one of the authors (NZ), and entered into an Excel spreadsheet (version 7.0, Microsoft Corporation, Redmond, WA, 2007). We recorded the following 12 categories of alleged violations:

1. Failure to screen for an EMC

2. Failure to stabilize a patient with an EMC

3. Inappropriate transfer of a patient with an EMC

4. Failure to transfer a patient with an EMC

5. Patient turned away for insurance or financial status

6. Patient in active labor

APRIL 2017 | 13

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7. On-call physician refused to see patient with EMC

8. Patient with EMC inappropriately discharged

9. Hospital did not accept referral for transfer in of patient with EMC

10. No specialist physician available upon patient with EMC arrival

11. ED on ambulance diversion

12. Hospital where patient presented had capacity to care for EMC but refused

Each of the 192 entries in the OIG database was allocated to as many categories (1-12) as appropriate. Therefore, the number of allegations described here exceeds the number of OIG reports by design.

We obtained information regarding total number of EMTALA allegations (denominator) in the U.S. from three sources. The first was a website maintained by the Association of Healthcare Journalists (AHCJ).8 This database covers January 6, 2011, to May 13, 2015, (4.5 years). We used the search term 489.24, which is the CMS code designation for an allegation of EMTALA violation. We designate this as “AHCJ Website.”

Second, we also derived information on the total number of CMS EMTALA investigations from the AHCJ database from this same organization, which requires membership, and which we designate “AHCJ Database.”

Finally, we sought personal communication from the federal administrator designated “EMTALA Technical Lead - Hospital Program Analyst Survey & Certification Group – Division of Acute Care Services Centers for Medicare & Medicaid Services.”

Since this was an analysis of publicly available data, no human subjects’ approval was required.

RESULTS

There were 192 settlement agreements (14 per year average for more than 4,000 hospitals in the U.S.). Fines against both hospitals and physicians totaled $6,357,000 (hospital and physician average $33,435 and $25,625 respectively). There were 184 (95.8%, $6,152,000) settlements involving hospitals and eight (4.2%) against physicians ($205,000). Therefore, 97% of monetary penalties were levied against hospitals.

There were 392 alleged categories (1-12) of EMTALA violations identified in these 192 brief reports from the OIG website (average 2.04 per settlement). The categories of settlements are detailed in Figure 1. The most common settlements were for failing to screen (144/192, 75%) and stabilize (82/192, 42.7%) for EMCs. Other factors are listed in Figure 1.

Although loss of Medicare/Medicaid federal funding is an additional possible penalty for EMTALA violation, there were no reported cases where hospitals were excluded from federal reimbursement. There was no information on EMTALA investigations that were not subject to settlement.

Western Journal of Emergency Medicine 248 Volume XVII, no. 3 : May 2016

Review of Office of Inspector General Patient Dumping Settlements Zuabi et al.

would drop the proportion of investigations that result in OIG fines to 3.2% (192/6,035). Furthermore, the proportion of even CMS findings of liability (n=2,436) that resulted in OIG settlements occurred in only 7.9% (192/2,436) of cases.

There was significant variation in the number of settlements by CMS region (Figure 4), from a high of 68 in Region 4 (Southeast) to a low of 0 in Region 10 (Pacific Northwest), shown in Figure 5.

DISCUSSIONThis paper adds unique data to the emergency medicine

literature, as it provides the first review of recent CMS EMTALA investigations and civil monetary penalties. As the investigation process is complaint-driven, these data reveal that most complaints relate to allegations of improper screening examinations, followed by improper stabilization, and then improper transfers, but only a minority of allegations result in fines.

The EMTALA mandate began in 1986 in response to high-profile cases where patients were denied care, or were transferred from the ED without receiving necessary stabilizing care. Prior to EMTALA, in many communities the under- and uninsured received care in public hospitals (usually academic medical centers), while privately insured patients often received care in privately-owned community hospitals. When patients without insurance presented with medical emergencies or active labor to private hospitals, they were often turned away, some with bad outcomes in transit, or after arrival at public hospitals.

Rather than dealing directly with inequitable funding of providers and hospitals for healthcare, EMTALA placed an unfunded mandate on EDs and on-call specialists to provide screening and stabilizing care to everyone, without regard for insurance or ability to pay.

Consequently, regional surveys of community hospital EDs in California documented the erosion of on-call specialty panels from 2000 to 2006. The EMTALA mandate was an important driver, as specialists refused to take ED call to avoid being subjected to EMTALA mandates to care for the unfunded.10 This further shifted underfunded and unfunded care to university and public hospitals.

This trend accelerated after November 2003 when CMS significantly amended the EMTALA regulations. The new amendments significantly changed the duty of hospitals to provide panels of on-call physicians to their EDs. Prior to that time, the on-call panel had to include all specialties represented in the organized medical staff of the hospital. After November 2003, hospitals only had to provide an on-call panel that reasonably met the needs of its community.11 Very quickly, surgical subspecialists began disappearing from hospital call schedules. The “needs of the community” were then served by transferring patients to academic medical centers and other tertiary care facilities. Therefore, for a variety of reasons, the post-EMTALA provision of emergency care no longer involves

Figure 1. Factors associated with monetary settlement with U. S. Office of Inspector General for allegations of violation of Emergency Medical Treatment and Labor Act (EMTALA), 2002-15 (n= 392 for all categories of violations).

Figure 2. Number of monetary settlements with the U.S. Office of Inspector General for allegations of violation of Emergency Medical Treatment and Labor Act (EMTALA), 2002-15 (n=192).

Figure 3. Emergency Medical Treatment and Labor Act (EMTALA) violations (2011-15) by category, from the Association of Healthcare Journalists Database. These 1,386 categories of alleged violations were contained in 527 separate CMS (Centers for Medicare and Medicaid Services) investigations. ED, emergency department

144

82

30 28 25 22 22 13 12

4 4 3 3 0

20

40

60

80

100

120

140

160

Alle

ged

Viol

atio

ns

Western Journal of Emergency Medicine 248 Volume XVII, no. 3 : May 2016

Review of Office of Inspector General Patient Dumping Settlements Zuabi et al.

would drop the proportion of investigations that result in OIG fines to 3.2% (192/6,035). Furthermore, the proportion of even CMS findings of liability (n=2,436) that resulted in OIG settlements occurred in only 7.9% (192/2,436) of cases.

There was significant variation in the number of settlements by CMS region (Figure 4), from a high of 68 in Region 4 (Southeast) to a low of 0 in Region 10 (Pacific Northwest), shown in Figure 5.

DISCUSSIONThis paper adds unique data to the emergency medicine

literature, as it provides the first review of recent CMS EMTALA investigations and civil monetary penalties. As the investigation process is complaint-driven, these data reveal that most complaints relate to allegations of improper screening examinations, followed by improper stabilization, and then improper transfers, but only a minority of allegations result in fines.

The EMTALA mandate began in 1986 in response to high-profile cases where patients were denied care, or were transferred from the ED without receiving necessary stabilizing care. Prior to EMTALA, in many communities the under- and uninsured received care in public hospitals (usually academic medical centers), while privately insured patients often received care in privately-owned community hospitals. When patients without insurance presented with medical emergencies or active labor to private hospitals, they were often turned away, some with bad outcomes in transit, or after arrival at public hospitals.

Rather than dealing directly with inequitable funding of providers and hospitals for healthcare, EMTALA placed an unfunded mandate on EDs and on-call specialists to provide screening and stabilizing care to everyone, without regard for insurance or ability to pay.

Consequently, regional surveys of community hospital EDs in California documented the erosion of on-call specialty panels from 2000 to 2006. The EMTALA mandate was an important driver, as specialists refused to take ED call to avoid being subjected to EMTALA mandates to care for the unfunded.10 This further shifted underfunded and unfunded care to university and public hospitals.

This trend accelerated after November 2003 when CMS significantly amended the EMTALA regulations. The new amendments significantly changed the duty of hospitals to provide panels of on-call physicians to their EDs. Prior to that time, the on-call panel had to include all specialties represented in the organized medical staff of the hospital. After November 2003, hospitals only had to provide an on-call panel that reasonably met the needs of its community.11 Very quickly, surgical subspecialists began disappearing from hospital call schedules. The “needs of the community” were then served by transferring patients to academic medical centers and other tertiary care facilities. Therefore, for a variety of reasons, the post-EMTALA provision of emergency care no longer involves

Figure 1. Factors associated with monetary settlement with U. S. Office of Inspector General for allegations of violation of Emergency Medical Treatment and Labor Act (EMTALA), 2002-15 (n= 392 for all categories of violations).

Figure 2. Number of monetary settlements with the U.S. Office of Inspector General for allegations of violation of Emergency Medical Treatment and Labor Act (EMTALA), 2002-15 (n=192).

Figure 3. Emergency Medical Treatment and Labor Act (EMTALA) violations (2011-15) by category, from the Association of Healthcare Journalists Database. These 1,386 categories of alleged violations were contained in 527 separate CMS (Centers for Medicare and Medicaid Services) investigations. ED, emergency department

144

82

30 28 25 22 22 13 12

4 4 3 3 0

20

40

60

80

100

120

140

160

Alle

ged

Viol

atio

ns

Western Journal of Emergency Medicine 248 Volume XVII, no. 3 : May 2016

Review of Office of Inspector General Patient Dumping Settlements Zuabi et al.

would drop the proportion of investigations that result in OIG fines to 3.2% (192/6,035). Furthermore, the proportion of even CMS findings of liability (n=2,436) that resulted in OIG settlements occurred in only 7.9% (192/2,436) of cases.

There was significant variation in the number of settlements by CMS region (Figure 4), from a high of 68 in Region 4 (Southeast) to a low of 0 in Region 10 (Pacific Northwest), shown in Figure 5.

DISCUSSIONThis paper adds unique data to the emergency medicine

literature, as it provides the first review of recent CMS EMTALA investigations and civil monetary penalties. As the investigation process is complaint-driven, these data reveal that most complaints relate to allegations of improper screening examinations, followed by improper stabilization, and then improper transfers, but only a minority of allegations result in fines.

The EMTALA mandate began in 1986 in response to high-profile cases where patients were denied care, or were transferred from the ED without receiving necessary stabilizing care. Prior to EMTALA, in many communities the under- and uninsured received care in public hospitals (usually academic medical centers), while privately insured patients often received care in privately-owned community hospitals. When patients without insurance presented with medical emergencies or active labor to private hospitals, they were often turned away, some with bad outcomes in transit, or after arrival at public hospitals.

Rather than dealing directly with inequitable funding of providers and hospitals for healthcare, EMTALA placed an unfunded mandate on EDs and on-call specialists to provide screening and stabilizing care to everyone, without regard for insurance or ability to pay.

Consequently, regional surveys of community hospital EDs in California documented the erosion of on-call specialty panels from 2000 to 2006. The EMTALA mandate was an important driver, as specialists refused to take ED call to avoid being subjected to EMTALA mandates to care for the unfunded.10 This further shifted underfunded and unfunded care to university and public hospitals.

This trend accelerated after November 2003 when CMS significantly amended the EMTALA regulations. The new amendments significantly changed the duty of hospitals to provide panels of on-call physicians to their EDs. Prior to that time, the on-call panel had to include all specialties represented in the organized medical staff of the hospital. After November 2003, hospitals only had to provide an on-call panel that reasonably met the needs of its community.11 Very quickly, surgical subspecialists began disappearing from hospital call schedules. The “needs of the community” were then served by transferring patients to academic medical centers and other tertiary care facilities. Therefore, for a variety of reasons, the post-EMTALA provision of emergency care no longer involves

Figure 1. Factors associated with monetary settlement with U. S. Office of Inspector General for allegations of violation of Emergency Medical Treatment and Labor Act (EMTALA), 2002-15 (n= 392 for all categories of violations).

Figure 2. Number of monetary settlements with the U.S. Office of Inspector General for allegations of violation of Emergency Medical Treatment and Labor Act (EMTALA), 2002-15 (n=192).

Figure 3. Emergency Medical Treatment and Labor Act (EMTALA) violations (2011-15) by category, from the Association of Healthcare Journalists Database. These 1,386 categories of alleged violations were contained in 527 separate CMS (Centers for Medicare and Medicaid Services) investigations. ED, emergency department

144

82

30 28 25 22 22 13 12

4 4 3 3 0

20

40

60

80

100

120

140

160

Alle

ged

Viol

atio

ns

Figure 1. Factors associated with monetary settlement with U. S. Office of Inspector General for allegations of violation of Emergency Medical Treatment and Labor Act (EMTALA), 2002-15 (n= 392 for all categories of violations).

Figure 2. Number of monetary settlements with the U.S. Office of Inspector General for allegations of violation of Emergency Medical Treatment and Labor Act (EMTALA), 2002-15 (n=192).

Figure 3. Emergency Medical Treatment and Labor Act (EMTALA) violations (2011-15) by category, from the Association of Healthcare Journalists Database. These 1,386 categories of alleged violations were contained in 527 separate CMS (Centers for Medicare and Medicaid Services) investigations. ED, emergency department

14 | LIFELINE a forum for emergency physicians in california

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Volume XVII, no. 3 : May 2016 249 Western Journal of Emergency Medicine

Zuabi et al. Review of Office of Inspector General Patient Dumping Settlements

many specialists in some communities.However, during this time, the number of settlements

appears to have decreased. After 30 years of implementation, a whole generation of physicians has been exposed to safer evaluation of potential medical emergencies prior to consideration for transfer, and to the prohibition of inquiry regarding method of payment prior to MSE.

To further understand this, it is instructive to examine the CMS’s “EMTALA Physician Review Worksheet,” which gives good insight into the factors involved in an investigation (Appendix). First, there are instructions defining the medical screening examination, which can range from a “brief history and physical examination,” to a “complex process” involving ancillary studies, diagnostic procedures (such as lumbar puncture), advanced imaging, consultation and procedures performed by consultants.

The standard asked of the CMS physician reviewer

Figure 4. Number of monetary settlements with U.S. Office of Inspector General by Centers for Medicare and Medicaid (CMS) region, for Emergency Medical Treatment and Labor Act (EMTALA) violations, 2002-15.

Figure 5. Center for Medicare and Medicaid (CMS) regions relevant to reporting of U.S. Office of Inspector General Emergency Medical Treatment and Labor Act (EMTALA) enforcement.

is one of “reasonable clinical confidence,” sufficient to determine whether or not an EMC…existed.” The form asks the reviewer to identify “inappropriately long delay” prior to the MSE. “In labor” is defined as “having contractions,” without further specifying interval or severity. The reviewer is asked to determine, “with reasonable medical certainty” whether there would be time to transfer the pregnant patient safely. Patient outcome after transfer is noted to not be a determinant of appropriate stabilization, but this could be a “red flag.” However, regarding transfer of a woman in labor, delivery prior to arrival at the receiving hospital is considered a “marker of instability” for transfer.

The obligation for care includes that which is “within the full capabilities” of a hospital’s staff and facilities and includes access to on-call specialists. The form asks the investigator to state the reason the EMC was not stabilized prior to transfer, and notes that the patient can refuse stabilizing treatment. During the transfer, the form asks whether this was done with the best equipment and personnel, whether the benefits outweighed the risks of transfer, whether the physician documented the benefits and risks in the medical record, and if the patient was sent with all medical records.

Designation as a specialty center is not limited to, for example, trauma/burn/neonatal intensive care unit (ICU), but rather asks the investigator to opine on other hospital capabilities. On the receiving end, hospital’s ability to accept a transfer can be limited by “lack of capacity,” but this is not further defined. Disputes arise whether a receiving hospital can refuse a transfer because of lack of inpatient, ICU or operating rooms, in addition to ED beds. This element is vague in all EMTALA guidance from CMS and the statute itself. The investigator worksheet similarly leaves this undefined.

The worksheet instructs the investigator specifically to not render an opinion regarding EMTALA violation. Finally, it requires the listing of the specialty of any potential violator physician, implying this is not limited to the actions of the emergency physician, but includes on-call specialists as well.

There is a small chance that any individual case will lead to an EMTALA investigation and fine. However, this could have devastating consequences for a physician or hospital. A $50,000 fine may have a minimal impact for a hospital, but a significant impact on a physician, as malpractice insurance policies do not cover the cost of civil penalties. Also, when a regional CMS office authorizes an on-site investigation, they can also investigate other previous cases involving the hospital and the physician. If CMS finds repeated or flagrant violations, each violation may result in an additional fine and may result in permanent exclusion of the providers from the Medicare and Medicaid programs.

Even though CMS may fine both hospitals and physicians for EMTALA violations, a patient may only legally sue the hospital for alleged injuries due to an EMTALA violation. Even though physicians do not face tort liability for alleged EMTALA violations, the duties enumerated by EMTALA quickly became

The number of settlements per year varied during the study period (Figure 2), from a high of 30 in 2003 to lows of seven per year in 2009 and 2010 (2015 is a partial year).

We sought to determine the proportion of EMTALA investigations that resulted in fines, requiring a denominator of EMTALA investigations from 2002-15. This was derived from three sources, which yielded different results.

The AHCJ Website (found at www.Hospitalinspections. org) returned 359 records of hospitals investigated from 2011-15. We scrutinized each to assure there was indeed at least one EMTALA-based allegation recorded, including the categories above, and eliminated duplicates. This yielded 338 unique EMTALA allegations in 4.5 years. Earlier data were not compiled from this source.

The AHCJ Database downloaded directly from the subscription to the organization listed 527 instances of “investigation for violation of EMTALA” between January 2011 and January 2015 (4 years), among 14,516 total CMS hospital offenses that led to investigations for all causes (3.6%).

Of the 14,516 offenses listed in the AHCJ Database that were investigated by CMS, 10 specific EMTALA violation categories were listed. These were not the same as the 12 categories of violations identified by the authors of this paper, which were contained in the OIG narrative descriptions. For example, the authors of this paper identified four additional categories of violations not in the AHCJ list: 1) active labor, 2) turned away for financial status, 3) no specialty physician available, and 4) ED on ambulance diversion. Conversely, the AHCJ Database had two categories that the authors did not find in the OIG website: 1) ED log (a required list of all patients who present to any ED in chronological order) and 2) posting of signage regarding EMTALA obligations. The sum of all allegations in the AHCJ Database was 1,386 (multiple allegations in each of 527 investigations), and we report the breakdown of these alleged violations by category in Figure 3.

Therefore, depending on the denominator taken from the AHCJ Database (n=527) or the AHCJ Website (n=338), there were between approximately 75-130 EMTALA investigations per year from 2011-2015. Extrapolating these 4 to 4.5 years of data over the 12-year period of OIG listed EMTALA settlements would amount to approximately 100 per year, or 1,200 investigations. Given 192 monetary settlements, this indicates that, at most, approximately 16% of EMTALA investigations result in fines.

The third source of information (and perhaps most reliable) on the scope of EMTALA allegations and investigations is CMS’ own database, operational since 2004. Between then and 2015, there were 6,316 complaints received (approximately 574 per year), 6,035 investigations done by CMS (549/year), of which 2,436 found EMTALA violations (221/year).9 This source documents more than four times as many investigations per year as the AHCJ website or database contain. Using these data to extrapolate over the 12-year period during which OIG settlements are publicly reported, would drop the proportion of investigations that result in OIG fines to 3.2% (192/6,035). Furthermore, the proportion of even CMS findings of liability (n=2,436) that resulted in OIG settlements occurred in only 7.9% (192/2,436) of cases.

There was significant variation in the number of

settlements by CMS region (Figure 4), from a high of 68 in Region 4 (Southeast) to a low of 0 in Region 10 (Pacific Northwest), shown in Figure 5.

DISCUSSION

This paper adds unique data to the emergency medicine literature, as it provides the first review of recent CMS EMTALA investigations and civil monetary penalties. As the investigation process is complaint-driven, these data reveal that most complaints relate to allegations of improper screening examinations, followed by improper stabilization, and then improper transfers, but only a minority of allegations result in fines.

Volume XVII, no. 3 : May 2016 249 Western Journal of Emergency Medicine

Zuabi et al. Review of Office of Inspector General Patient Dumping Settlements

many specialists in some communities.However, during this time, the number of settlements

appears to have decreased. After 30 years of implementation, a whole generation of physicians has been exposed to safer evaluation of potential medical emergencies prior to consideration for transfer, and to the prohibition of inquiry regarding method of payment prior to MSE.

To further understand this, it is instructive to examine the CMS’s “EMTALA Physician Review Worksheet,” which gives good insight into the factors involved in an investigation (Appendix). First, there are instructions defining the medical screening examination, which can range from a “brief history and physical examination,” to a “complex process” involving ancillary studies, diagnostic procedures (such as lumbar puncture), advanced imaging, consultation and procedures performed by consultants.

The standard asked of the CMS physician reviewer

Figure 4. Number of monetary settlements with U.S. Office of Inspector General by Centers for Medicare and Medicaid (CMS) region, for Emergency Medical Treatment and Labor Act (EMTALA) violations, 2002-15.

Figure 5. Center for Medicare and Medicaid (CMS) regions relevant to reporting of U.S. Office of Inspector General Emergency Medical Treatment and Labor Act (EMTALA) enforcement.

is one of “reasonable clinical confidence,” sufficient to determine whether or not an EMC…existed.” The form asks the reviewer to identify “inappropriately long delay” prior to the MSE. “In labor” is defined as “having contractions,” without further specifying interval or severity. The reviewer is asked to determine, “with reasonable medical certainty” whether there would be time to transfer the pregnant patient safely. Patient outcome after transfer is noted to not be a determinant of appropriate stabilization, but this could be a “red flag.” However, regarding transfer of a woman in labor, delivery prior to arrival at the receiving hospital is considered a “marker of instability” for transfer.

The obligation for care includes that which is “within the full capabilities” of a hospital’s staff and facilities and includes access to on-call specialists. The form asks the investigator to state the reason the EMC was not stabilized prior to transfer, and notes that the patient can refuse stabilizing treatment. During the transfer, the form asks whether this was done with the best equipment and personnel, whether the benefits outweighed the risks of transfer, whether the physician documented the benefits and risks in the medical record, and if the patient was sent with all medical records.

Designation as a specialty center is not limited to, for example, trauma/burn/neonatal intensive care unit (ICU), but rather asks the investigator to opine on other hospital capabilities. On the receiving end, hospital’s ability to accept a transfer can be limited by “lack of capacity,” but this is not further defined. Disputes arise whether a receiving hospital can refuse a transfer because of lack of inpatient, ICU or operating rooms, in addition to ED beds. This element is vague in all EMTALA guidance from CMS and the statute itself. The investigator worksheet similarly leaves this undefined.

The worksheet instructs the investigator specifically to not render an opinion regarding EMTALA violation. Finally, it requires the listing of the specialty of any potential violator physician, implying this is not limited to the actions of the emergency physician, but includes on-call specialists as well.

There is a small chance that any individual case will lead to an EMTALA investigation and fine. However, this could have devastating consequences for a physician or hospital. A $50,000 fine may have a minimal impact for a hospital, but a significant impact on a physician, as malpractice insurance policies do not cover the cost of civil penalties. Also, when a regional CMS office authorizes an on-site investigation, they can also investigate other previous cases involving the hospital and the physician. If CMS finds repeated or flagrant violations, each violation may result in an additional fine and may result in permanent exclusion of the providers from the Medicare and Medicaid programs.

Even though CMS may fine both hospitals and physicians for EMTALA violations, a patient may only legally sue the hospital for alleged injuries due to an EMTALA violation. Even though physicians do not face tort liability for alleged EMTALA violations, the duties enumerated by EMTALA quickly became

Figure 4. Number of monetary settlements with U.S. Office of Inspector General by Centers for Medicare and Medicaid (CMS) region, for Emergency Medical Treatment and Labor Act (EMTALA) violations, 2002-15.

Figure 5. Center for Medicare and Medicaid (CMS) regions relevant to reporting of U.S. Office of Inspector General Emergency Medical Treatment and Labor Act (EMTALA) enforcement.

APRIL 2017 | 15

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The EMTALA mandate began in 1986 in response to high-profile cases where patients were denied care, or were transferred from the ED without receiving necessary stabilizing care. Prior to EMTALA, in many communities the under- and uninsured received care in public hospitals (usually academic medical centers), while privately insured patients often received care in privately-owned community hospitals. When patients without insurance presented with medical emergencies or active labor to private hospitals, they were often turned away, some with bad outcomes in transit, or after arrival at public hospitals.

Rather than dealing directly with inequitable funding of providers and hospitals for healthcare, EMTALA placed an unfunded mandate on EDs and on-call specialists to provide screening and stabilizing care to everyone, without regard for insurance or ability to pay.

Consequently, regional surveys of community hospital EDs in California documented the erosion of on-call specialty panels from 2000 to 2006. The EMTALA mandate was an important driver, as specialists refused to take ED call to avoid being subjected to EMTALA mandates to care for the unfunded.10 This further shifted underfunded and unfunded care to university and public hospitals.

This trend accelerated after November 2003 when CMS significantly amended the EMTALA regulations. The new amendments significantly changed the duty of hospitals to provide panels of on-call physicians to their EDs. Prior to that time, the on-call panel had to include all specialties represented in the organized medical staff of the hospital. After November 2003, hospitals only had to provide an on-call panel that reasonably met the needs of its community.11 Very quickly, surgical subspecialists began disappearing from hospital call schedules. The “needs of the community” were then served by transferring patients to academic medical centers and other tertiary care facilities. Therefore, for a variety of reasons, the post-EMTALA provision of emergency care no longer involves many specialists in some communities.

However, during this time, the number of settlements appears to have decreased. After 30 years of implementation, a whole generation of physicians has been exposed to safer evaluation of potential medical emergencies prior to consideration for transfer, and to the prohibition of inquiry regarding method of payment prior to MSE.

To further understand this, it is instructive to examine the CMS’s “EMTALA Physician Review Worksheet,” which gives good insight into the factors involved in an investigation (Appendix). First, there are instructions defining the medical screening examination, which can range from a “brief history and physical examination,” to a “complex process” involving ancillary studies, diagnostic procedures (such as lumbar puncture), advanced imaging, consultation and procedures performed by consultants.

The standard asked of the CMS physician reviewer is one of “reasonable clinical confidence,” sufficient to determine whether or not an EMC…existed.” The form asks the reviewer to identify “inappropriately long delay” prior to the MSE. “In labor” is defined as “having contractions,” without further specifying interval or severity. The reviewer is asked to determine, “with reasonable medical certainty” whether there would be time to transfer the pregnant patient safely. Patient outcome after transfer is noted to not be a determinant of appropriate stabilization,

but this could be a “red flag.” However, regarding transfer of a woman in labor, delivery prior to arrival at the receiving hospital is considered a “marker of instability” for transfer.

The obligation for care includes that which is “within the full capabilities” of a hospital’s staff and facilities and includes access to on-call specialists. The form asks the investigator to state the reason the EMC was not stabilized prior to transfer, and notes that the patient can refuse stabilizing treatment. During the transfer, the form asks whether this was done with the best equipment and personnel, whether the benefits outweighed the risks of transfer, whether the physician documented the benefits and risks in the medical record, and if the patient was sent with all medical records.

Designation as a specialty center is not limited to, for example, trauma/burn/neonatal intensive care unit (ICU), but rather asks the investigator to opine on other hospital capabilities. On the receiving end, hospital’s ability to accept a transfer can be limited by “lack of capacity,” but this is not further defined. Disputes arise whether a receiving hospital can refuse a transfer because of lack of inpatient, ICU or operating rooms, in addition to ED beds. This element is vague in all EMTALA guidance from CMS and the statute itself. The investigator worksheet similarly leaves this undefined.

The worksheet instructs the investigator specifically to not render an opinion regarding EMTALA violation. Finally, it requires the listing of the specialty of any potential violator physician, implying this is not limited to the actions of the emergency physician, but includes on-call specialists as well.

There is a small chance that any individual case will lead to an EMTALA investigation and fine. However, this could have devastating consequences for a physician or hospital. A $50,000 fine may have a minimal impact for a hospital, but a significant impact on a physician, as malpractice insurance policies do not cover the cost of civil penalties. Also, when a regional CMS office authorizes an on-site investigation, they can also investigate other previous cases involving the hospital and the physician. If CMS finds repeated or flagrant violations, each violation may result in an additional fine and may result in permanent exclusion of the providers from the Medicare and Medicaid programs.

Even though CMS may fine both hospitals and physicians for EMTALA violations, a patient may only legally sue the hospital for alleged injuries due to an EMTALA violation. Even though physicians do not face tort liability for alleged EMTALA violations, the duties enumerated by EMTALA quickly became national standards of practice. Therefore, in medical malpractice litigation, patients may allege negligence due to failure of a physician to adhere to national standards of practice, including screening, stabilization, and transfer of ED patients.

A discussion of alleged EMTALA violations must include the three major obligations of hospitals and physicians, the duties to appropriately screen, stabilize, and transfer patients. Congress failed to provide a definition of appropriate MSE, and this led to more litigation than any other aspect of the statute. Gradually, the federal courts of appeals developed the “comparability test.” A hospital provides an appropriate MSE when it provides an examination comparable to a similar patient.12 This reflects the fact that EMTALA is an antidiscrimination statute.

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Address for Correspondence: Mark I. Langdorf, MD, MHPE, University of California Irvine, 333 City Blvd W, Suite 640, Orange, CA 92868. Email: [email protected].

Conflicts of Interest: By the WestJEM article submission agreement, all authors are required to disclose all affiliations, funding sources and financial or management relationships that could be perceived as potential sources of bias. The authors disclosed none.

Copyright: © 2016 Zuabi et al. This is an open access article distributed in accordance with the terms of the Creative Commons Attribution (CC BY 4.0) License. See: http://creativecommons.org/ licenses/by/4.0/

REFERENCES1. EMTALA. American College of Emergency Physicians Web site. Available

at: http://www.acep.org/News-Media-top-banner/EMTALA/. Accessed Dec 30, 2015.

2. Emergency Care. EMTALA Administration and Enforcement Issues. Unit-ed States General Accounting Office. Available at: http://www. gao.gov/new.items/d01747.pdf Published June 2001. Accessed Dec 30, 2015.

3. 42 U.S.C. §1395dd(E). (See 42 CFR 489.24(b)) Reference: PT31 EMT 5D Work-sheet, CMS/OIG investigative report form. Accessed Jun 26, 2015.

4. Roberts v. Galen of Virginia- The Supreme Court Misses the Boat on EM-TALA. Emtala.com Website. Available at: http://www.emtala.com/ rob-erts.htm. Accessed Dec 30, 2015.

5. Rosenbaum S, Cartwright-Smith L, Hirsh J, et al. Case studies at Denver Health: ‘patient dumping’ in the emergency department despite EMTA-LA, the law that banned it. Health Aff (Millwood). 2012;31:1749-56.

6. www.ehcca.com/presentations/uninscong1/yeh_1.ppt PowerPoint pre-sentation from Charlotte Yeh MD, Regional Administrator, Centers for Medicare and Medicaid Services, given to the National Congress on the Un and Under Insured, December 10, 2007, Washington, D.C.

7. Patient Dumping. Office of Inspector General U.S. Department of Health and Human Services Website. Available at: https://oig.hhs. gov/fraud/en-forcement/cmp/patient_dumping.asp. Accessed May 2015.

8. HospitalInspections.org. Association of Health Care Journalists Website. Available at: http://www.hospitalinspections.org/. Accessed Oct 22, 2015.

9. Personal communication from Mary Ellen Palowitch MHA RN, EMTALA Technical Lead - Hospital Program Analyst Survey & Certification Group – Division of Acute Care Services Centers for Medicare & Medicaid Services, 12/16/15.

10. Rudkin SE, Langdorf MI, Oman JA, et al. The worsening of ED on-call cov-erage in California: 6-year trend. Am J Emerg Med. 2009;27:785-91.

11. 42 C.F.R. §489.24(j)(2)(iii).

12. See, e.g.: Vickers v Nash, 78 F.3d. 139, (4th Cir. 1994)

13. 42 U.S.C. §13955dd(E)

14. See, e.g.: Green v. Touro Infirmary, 992 F.2d 537, (5th Cir. 1993)

15. 42 U.S.C. §1395dd(C)

16. 42 U.S.C.§1395dd(F)

17. Available at: https://www.cms.gov/Medicare/Provider-Enrollmentand- Certification/SurveyCertificationGenInfo/downloads/ SCLetter08-15.pdf, page 42.

If the MSE does not reveal an EMC, then EMTALA obligations are fulfilled. However, the diagnosis of an EMC gives rise to the duty to stabilize.12,13 A patient is stable if it is reasonably likely the patient will not deteriorate en route during a transfer, including patients “transferred” to home (discharged from the ED).14 When providers stabilize the patient’s EMCs the obligations under EMTALA are fulfilled.14,15

The EMTALA transfer obligations only apply to unstable patients. Therefore, if an ED cannot stabilize a patient, then it may transfer the patient if “appropriate.”16 The referring hospital must stabilize the patient to its maximum potential, must secure acceptance from a provider at a receiving hospital, and send appropriate records, personnel and equipment. The referring physician must sign a certification, in actuality an oath, documenting that the medical benefits of transfer outweigh the risks. In addition to these “appropriate” transfer requirements, patients may request or demand transfer after proper disclosure of the risks.

A receiving hospital has a duty to accept all “appropriate” transfers if it has capacity (an available appropriate bed) and the capability (appropriate staff ), and if the receiving hospital serves as a regional referral center or has unique capabilities not available at the referring hospital.16 Hospitals do not have a duty to accept lateral transfers.17

We were not able to find any recent hospital or physician loss of federal funding in our investigation. The last information from 2007 from CMS reported 13 hospitals had been terminated from Medicare for EMTALA violations.6

We had substantial difficulty discovering the true number of EMTALA allegations that may result in penalties. We believe the federal government’s CMS data to be most accurate, suggesting a very low (<8%) incidence of OIG monetary penalties even after CMS determines there has been an EMTALA violation.9

CONCLUSION

Of 192 hospitals and physicians settling with the OIG from 2002-15, most were for failing to provide screening (75%) and stabilization (42%) to patients with EMCs. The reason for patient “dumping” was due to insurance or financial status in 15.6% of settlements, the original intent of the statute. The vast majority of penalties were to hospitals (95% of cases and 97% of fines). Forty percent of investigations found EMTALA violations, but only 3% of investigations triggered fines. n

APRIL 2017 | 17

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legislative leadership conference

may 2 sacramento

2017

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It’s one of the things we do best.

DO YOU PLAY WELL WITH OTHERS?

Learn more about our culture of caring and engaging careers at: go.cep.com/PlayWell OWN YOUR CAREER

At CEP America, we developed a culture that values teamwork, collaboration, and playing well with others, which makes for a truly fun and warm work environment.

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LEGISLATIVE LEADERSHIP CONFERENCE (LLC)

May 2, 2017, Sacramento, California

BOARD OF DIRECTORS ELECTION

May 15-31, 2017 Online

The California Emergency Medicine Advocacy Fund (CEMAF) has transformed California ACEP’s advocacy efforts from primarily legislative to robust efforts in the legislative, regulatory, legal, and through the Emergency Medical Political Action Committee, political arenas. Few, if any, organization of our size

can boast of an advocacy program like California ACEP’s;

a program that has helped block Medi-Cal provider rate

cuts, lock in $500 million for the Maddy EMS Fund over

the next 10 years, and fight for ED overcrowding solutions!

The efforts could not be sustained without the generous

support from the groups listed below, some of whom have

donated as much as $0.25 per chart to ensure that California

ACEP can fight on your behalf. Thank you to our 2015-16 contributors (in alphabetical order):

• Alvarado Emergency Medical Associates• Antelope Valley Emergency Medical Associates• Beach Emergency Medical Associates• Berkeley Emergency Medical Group • Centinela Freeman Emergency Medical Associates• CEP America• Chino Emergency Medical Associates• Coastline Emergency Physicians Medical Group• Culver Emergency Medical Group• Eden Emergency Medical Group • Hollywood Presbyterian Emergency Medical Associates• Mills Peninsula Emergency Medical Group• Montclair Emergency Medical Associates• Napa Valley Emergency Medical Group• Orange County Emergency Medical Associates• Pacific Coast Emergency Medical Associates• Pacific Emergency Providers• Pacifica Emergency Medical Associates• Riverside Emergency Physicians• San Dimas Emergency Medical Associates• Sherman Oaks Emergency Medical Associates• South Coast Emergency Medical Group, Inc.• Tarzana Emergency Medical Associates• TeamHealth• Temecula Valley Emergency Physicians, Inc.• US Acute Care Solutions• Valley Emergency Medical Associates• VEP Healthcare, Inc.• Valley Presbyterian Emergency Medical Associates• West Hills Emergency Medical Associates

CEMAF ANNOUNCEMENTS |

20 | LIFELINE a forum for emergency physicians in california

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For more information on upcoming meetings, please e-mail us at [email protected]; unless otherwise noted, all meetings are held via conference call.

| CALIFORNIA ACEP UPCOMING MEETINGS & DEADLINES

APRIL 2017

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APRIL 2017

18th California Medical Association Lobby DaySacramento, CA

MAY 2017

2nd California ACEP Legislative Leadership Conference (LLC)Sacramento, CA

3rd at 9am Board of Directors MeetingSacramento, CA

9th at 9am Reimbursement Committee Conference Call

11th at 10am Government Affairs Committee Conference Call

15th - 31st Chapter Board ElectionOnline

29th Memorial DayChapter Office Closed

JUNE 2017

8th at 10 am Board of Directors MeetingSacramento, CA

APRIL 2017 | 21

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To advertise with Lifeline and to take advantage of our circulation of over 3,000 readers, including Emergency Physicians, Groups, and Administrators throughout California who are eager to learn about what your business has to offer them, please contact us at [email protected] or give us a call at (916) 325-5455.

BAKERSFIELD, CALIFORNIA: Pinnacle Emergency Physicians (2007-present) with 3 local ED's (10h shifts) seeking FT/PT, BC/BE docs (all trauma goes to the County Hospital)

• Memorial Hospital: 80k/y, STEMI, Stroke & Burn Receiving Center, currently 24/7 Peds, PICU, OB and adult hospitalist services…Peds ED opening 4/2017

• Mercy Downtown: 37k/y, Stroke Receiving Center w/ adult hospitalist services

• Mercy Southwest: 52k/y, Stroke Receiving Center w/ adult hospitalist services

Staffed by 40 FT/PT physicians and 40 FT/PT mid-levels. Income in top 5-10% nationwide. Low cost of living.Contact: Les Burson, DO, Medical Director [email protected] 661-332-1064 or Dr. Kian Azimian, MD, Assistant Medical Director [email protected] 661-616-8930

DOWNTOWN LOS ANGELES: Emergency Physician needed. $350,000 + incentive per year, malpractice paid, half days, half nights. ABEM ABOEM with experience. Present core group average 23 yrs tenure. 36,000 annual visits, paramedic receiving (no peds) STEMI Stroke, physician coverage 36-40 hrs/day, NP & PA coverage 12-20 hrs/dayFAX CV to 213 482 0577 or call 213 482 0588 or [email protected]

LAKE TAHOE, CALIFORNIA: Enjoy the benefits of partnership from day one in our stable, independent, democratic group. We are looking for a full-time BC/BP Emergency Physician to replace a retiring partner. We staff two EDs: a level 3 trauma center with annual volume of 20k and a critical access rural hospital with annual volume of 12k. In the winter months, we also staff clinics at three local ski resorts. Flexible scheduling allows you to take advantage of the abundant year-round outdoor activities beautiful Lake Tahoe and the Sierra Nevada’s have to offer. For more information email to [email protected]

LOS ANGELES – CULVER CITY: Southern California Hospital at Culver CityRare opportunity to join a Westside LA ER group. Group seeks BC/BE emergency physician to work Part-Full Time as an independent contractor. Excellent compensation with malpractice paid. Nine hour shifts with 11 hours of PA double coverage. 90% nights shifts are covered by night doctors. A complete ED refurbishment has been completed with an ER rebuild and expansion in the future. Computerized Charting and PACS! Email CV and references to [email protected]. Phone 951-898-0823.

ORANGE COUNTY—PLACENTIA—PLACENTIA LINDA HOSPITAL: Full or part time BC/BE ABEM independent contractor physician needed to join long standing independent group. 20 bed new beautiful emergency department with 29,000 annual visits. 12 hour shifts with split between mainly swings and nights. Moderate acuity and excellent nursing and ancillary staff backup. Very competitive salary structure with malpractice and tail coverage paid. Placentia Linda Hospital is located in north central Orange County in a very pleasant safe community with great schools. Contact: Peter Anderson, MD | (714) 396-6935 | [email protected]

RIVERSIDE, CA: Parkview Medical Center – Great opportunity to join a 14 year ER group. Group seeks BC/BE Emergency Physician to work Part/Full Time as an independent contractor. Excellent Top Tier Compensation based on productivity with malpractice paid. Ten hour shifts with MD double coverage and 12 Hour PA. Computerized equitable shift scheduling. Efficient Computerized Charting and PACS! A brand new ER expansion will break ground soon tripling the size of the ER!Email CV and references to [email protected] or Phone (951) 898-0823

SAN JOSE, CALIFORNIA: Independent, democratic EP group has a rare opportunity for a FT partnership track position. Located in Downtown San Jose, heart of Silicon Valley, our 23 bed ER sees about 58K. 58 hrs Physician/NP coverage daily. Excellent call panel, Stroke/STEMI center. Shared nights/holidays. Low overhead, top pay. We have been providing care at this hospital for 30 years. Become a partner in only 2 years! Must be BC/BE. Please send CV and letter of interest to David Ghilarducci MD, [email protected]

SOUTHERN CALIFORNIA – ORANGE COUNTY: Full time and part time independent contracting emergency physicians needed for high volume, high acuity practices. Chest Pain Center, Stroke Center, Pediatric Level II trauma center - large independent group with forty years of clinical excellence for two acute care facilities. Expanding group needs BC/BE emergency physicians and pediatric emergency physicians. Excellent compensation, malpractice paid, scribes, midlevel providers, 8 – 9 hour shifts, excellent call panel coverage.Email CV and references to [email protected], fax to 714-543-8914

SOUTHERN CALIFORNIA: LA/OC area single hospi t al democrat ic group 40+ year contract holder with low turnover seeks BC/BE Emergency Physician for FT/PT position. We are a STEMI/Stroke Receiving Center with an 80K/year census. We have 24/7 in-house hospitalist and intensivist coverage along with a NICU and FP residency. The ED has 60 beds including Fast Track with PA/NP coverage, provider in triage, Scribes, and triple physician coverage during peak hours. Competitive compensation with night differential, paid malpractice, and educational support. Email CV to [email protected] or Fax to 562-945-5283

SOUTHERN CALIFORNIA OPPORTUNITIES:

• Tustin, CA - Orange County - 73-bed community hospital, 8-bed ER, paramedic receiving, low volume. 10 x 24hr = $240,000/yr + incentive

• East Los Angeles - 120-bed community hospital urgent care (non paramedic receiving) volume 700/mo. Guarantee $100/hr.

• Norwalk, CA - 60-bed hospital. 500-600 patient/mo. Paramedic receiving. $110/hr.

FAX CV to 213 482 0577 or call 213 482 0588 or email [email protected]

CAREER OPPORTUNITIES |

22 | LIFELINE a forum for emergency physicians in california

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Looking for an ITLS course?

EMREF offers the following California providers list:

Please call 916.325.5455 or E-mail Lucia Romo: [email protected] for more information.EMREF is a proud sponsor of California ITLS courses.

Search for upcoming courses: http://cms.itrauma.org/CourseSearch.aspx

American Medical Response (AMR)Ken Bradford, Operations841 Latour Court, Ste D, Napa, CA 94558-6259Phone: (707) 953-5795Email: [email protected]

EMS AcademyNancy Black, RN, Course Coordinator1170 Foster City Blvd #107, Foster City, CA 94404Phone: (866) 577-9197Fax: (650) 701-1968Email: [email protected]: www.caems-academy.com

Compliance TrainingJason Manning, EMS Course Coordinator3188 Verde Robles Drive, Camino, CA 95709Phone: (916) 429-5895 Fax: (916) 256-4301 Email: [email protected]

CSUS Prehospital Education ProgramDerek Parker, Program Director3000 State University Drive East, Napa Hall, Sacramento, CA 95819-6103Office: (916) 278-4846 Mobile: (916) 316-7388 Email: [email protected]: www.cce.csus.edu

ETS – Emergency Training ServicesMike Thomas, Course Coordinator3050 Paul Sweet Road, Santa Cruz, CA 95065Phone: (831) 476-8813 Toll-Free: (800) 700-8444 Fax: (831) 477-4914 Email: [email protected]: www.emergencytraining.com

Loma Linda University Medical Center tnatsissA evitartsinimdA ,senoJ enyL

Department of Emergency Medicine11234 Anderson St., A108, Loma Linda, CA 92354Phone: (909) 558-4344 x 0 Fax: (909) 558-0102 Email: [email protected]: www.llu.edu

Medic AmbulanceJames Pierson, EMT-P506 Couch Street, Vallejo, CA 94590-2408 Phone: (707) 644-1761 Fax: (707) 644-1784Email: [email protected]: www.medicambulance.net

Napa Valley CollegeGregory Rose, EMS Co-Director2277 Napa Highway, Napa CA 94558Phone: (707) 256-4596Email: [email protected] Web: www.winecountrycpr.com

NCTI – National College of Technical InstructionLena Rohrabaugh, Course Manager333 Sunrise Ave Suite 500, Roseville, CA 95661Phone: (916) 960-6284 x 105 Fax: (916) 960-6296Email: [email protected] Web: www.ncti-online.com

Oakland Fire DepartmentSheehan Gillis, EMT-P, EMS Coordinator 47 Clay Street, Oakland, CA 74607Phone: (510) 238-6957Fax: (510) 238-6959 Email: [email protected]: http://www.oaklandnet.com/fire/

Riggs Ambulance ServiceGreg Petersen, EMT-P, Clinical Care Coordinator100 Riggs Ave, Merced, CA 95340Phone: (209) 725-7010Fax: (209) 725-7044Email: [email protected]: www.riggsambulance.com

Rocklin Fire DepartmentChris Wade, Firefighter/Paramedic

Phone: (916) 625-5311Fax: (209) 725-7044Email: [email protected]: www.rocklin.ca.us

Rural Metro AmbulanceBrian Green, EMT-P1345 Vander Way, San Jose, CA 95112Phone: (408) 645-7345Fax: (408) 275-6744Email: [email protected]: www.rmetro.com

ytefaS cilbuP egelloC roinuJ asoR atnaSTraining CenterBryan Smith, EMT-P, Course Coordinator5743 Skylane Blvd, Windsor, CA 95492Phone: (707) 836-2907 Fax: (707) 836-2948Email: [email protected] Web: www.santarosa.edu

WestMed CollegeBrian Green, EMT-P5300 Stevens Creek Blvd., Suite 200, San Jose, CA 95129-1000Phone: (408) 977-0723 Email: [email protected] Web: www.westmedcollege.com

American Health Education, Inc

7300B Amador Plaza Road, Dublin, CA 94568Phone: (800) 483-3615Email: [email protected]: www.americanhealtheducation.com

Verihealth/Falck Northern California

2190 South McDowell Blvd, Petaluma, CA 94954Phone: (707) 766-2400Email: [email protected] Web: www.verihealth.com

Ken Bradford, Training Coordinator

3401 Crest Drive, Rocklin, CA 95765

Perry Hookey, EMT-P

PHI Air Medical, CaliforniaGraham Pierce, Course Coordinator 801 D Airport Way, Modesto, CA 95354Phone: (209) 550-0884 Fax: (209) 550-0885Email: [email protected] Web: http://www.phiairmedical.com/

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2017legislative leadership conference

May 2 sacramento

2017legislative leadership conference

May 2 sacramento

lifelineCalifornia Chapter, American College of Emergency Physicians

1121 L Street, Suite 407Sacramento, CA 95814

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PAIDCPS

2017legislative leadership conference

May 2 sacramento