Corporate Compliance

Physician-owned specialty hospitals not ready for emergencies

Healthcare Auditing Weekly, January 15, 2008

Most physician-owned specialty hospitals are not ready to deal with emergencies, according to a report by the OIG.

All hospitals that participate in Medicare must demonstrate their ability to meet the Conditions of Participation (CoP), a set of health and safety standards.

The CoPs require a hospital have:

  • A physician on duty or on call at all times
  • Twenty-four hour nursing services, furnished or supervised by a registered nurse
  • Written policies and procedures in place for addressing individuals' emergency care needs, regardless of whether the hospital has an emergency department

In addition, a hospital is not in compliance with the CoPs if it relies on 911 as a substitute for its own emergency services.

According to the report:

  • Sixty of the 109 hospitals reviewed had an emergency department, but more than half had only one bed
  • More than two-thirds of the hospitals did not have a physician on site at all times
  • Two-thirds of physician-owned specialty hospitals use 911 as part of their emergency response procedures
  • One-third of hospitals use 911 to obtain medical assistance to stabilize a patient
  • Seven hospitals did not have nurses on duty or physicians on call
  • Almost 25% of specialty hospitals lack basic information in their written policies about managing medical emergencies

The report recommended that CMS:

  • Develop a system to identify and regularly track physician-owned specialty hospitals
  • Ensure that hospitals meet the current Medicare CoPs that require a registered nurse to be on duty 24 hours a day, 7 days a week and a physician to be on call if one is not onsite
  • Ensure that hospitals have the capabilities to provide for the appraisal and initial treatment of emergencies and that they are not relying on 911 as a substitute for their own ability to provide these services
  • Require hospitals to include necessary information in their written policies for managing a medical emergency, such as the use of emergency response equipment and the life-saving protocols to be followed

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