Federal District Court Finds Hospital-Owned Urgent Care Center Must Comply With EMTALA

A recent federal court case in Rhode Island, Friedrich et al. v South County Hospital Healthcare System, et al., found that a walk-in urgent care center owned by a hospital system was subject to the requirements of the Emergency Medical Treatment and Active Labor Act (EMTALA). In this case, the plaintiff presented to the hospital’s urgent/walk-in care clinic complaining of severe pain and burning in her chest and right arm. She was diagnosed with gastroesophageal reflux disease, given medication and discharged with no follow-up ordered. She died of a heart attack the next day.

The decision focused on whether the urgent care clinic fell within the definition of a “dedicated emergency department” of the hospital, which would have required it to provide the patient with a medical screening examination and appropriate stabilizing treatment under EMTALA.  The court reviewed the definitions established by the Center for Medicare and Medicaid Services, which include a department of the hospital that is “held out to the public by name, posted signs, advertising or other means as a place that provides care for emergency medical conditions on an urgent basis without requiring a previously scheduled appointment.”

Under this definition, the most important criterion is whether the clinic would be perceived by an individual as an appropriate place to go for emergency care. Here, even though the hospital’s website stated that the urgent /walk-in care clinic was for “non-emergency needs,” and that it did not provide “emergency room level care,” the court found that a person driving by needing emergency care would not check the website first and based on the signage would not distinguish “urgent” care from an emergency medical condition.  Since patients would believe that the urgent/walk-in care clinic was an appropriate place to go for emergency care, it was a “dedicated emergency department” under EMTALA.

This case was decided in a preliminary stage of the proceedings, as a denial of a motion for summary judgment on the part of the hospital and did not decide the ultimate question of liability.  However, hospitals should be aware that provider-based urgent care centers that are held out to the public as such will likely meet the definition of a “dedicated emergency department” and will be subject to full EMTALA compliance.   The text of the court’s decision can be found here.