CPHRM EVALUATION TEST QUESTIONS AND
ANSWERS SET A+
✔✔Identify the categories of HACs for which Medicare won't reimburse the facility -
✔✔Non-reimbursable HACs:
- unintentional retention of foreign objects
- air embolism
- blood incompatibility
- stage III and IV pressure ulcers
- conditions resulting from falls and other trauma
- evidence of poor glycemic control
- catheter-associated unitary track infections
- surgical site infections following specific procedures (coronary artery bypass, bariatric,
orthopedic surgeries, etc.)
- vascular catheter-associated infections
- deep vein thrombosis/pulmonary embolism associated with orthopedic surgery
- latrogenic pneumothorax with venous catheterization
✔✔Discuss Emergency Medical Treatment & Labor Act (EMTALA) history, purpose and
legislation - ✔✔EMTALA was enacted in 1986 under the Consolidated Omnibus Budget
Reconciliation Act (COBRA), commonly referred are the "antidumping statute."
EMTALA ensures that individuals receive a medical screening and stabilizing treatment
for emergency medical conditions, regardless of their ability to pay or insurance status.
COBRA, on the other hand, allows individuals who lose their job-based health insurance
to temporarily continue their coverage.
EMTALA requirements: any person who comes to the emergency department seeking
evaluation or treatment for a medical condition, regardless of their ability to pay, must
be:
1. provided with a medical screening exam (MSE) to confirm if an emergency medical
condition exist.
2. if so, stabilize the emergency medical condition, and/or
,3. transfer patient to a facility that provides higher level of care if necessary
✔✔Key EMTALA terms - ✔✔Emergency Medical Condition - acute symptoms of
sufficient severity, including severe pain, resulting in placing patent's health in serious
jeopardy (bodily function impairment, body organ disfunction, etc.) - 42 USC
1395dd(e)(1).
Dedicated emergency department - specially equipped and staffed to treat patient with
emergency medical conditions - 42 CFR 489.24.
Comes to the emergency department - when a person presents anywhere within 250
yards of the main building 42 CFR 413.65 and request emergency services or who
would appear to a reasonably prudent person to be in need of medical attention 42 CFR
489.24.
Qualified medical person - designated by hospital bylaws as qualified to perform a
medical screening examination 42 CFR 489.24
✔✔Discuss EMTALA requirements for appropriate patient transfer - ✔✔Appropriate
transfer under EMTALA must meet the following:
➣ patient must be treated at the transferring hospital to stabilized to the extent possible
within its capacity and capabilities.
➣ patient must requires a higher level or care.
➣ the risk of transferring must be outweighed by the medical benefits of transfer, and
risks/benefits be certified by the transferring physician.
➣ receiving hospital must be contacted and agree to accept the transfer.
➣ copies of medical records from transferring facility must be sent with patient to the
receiving facility.
➣ transfer must be completed by qualified personnel and appropriate equipment.
Inappropriate transfer:
In the event that a facility receives a patient without the above requirements, the
receiving facility has an obligation under EMTALA to report a potential violation to the
appropriate regulatory agency.
✔✔Additional EMTALA requirements (besides the screening, stabilization, and transfer)
- ✔✔Notice of rights - EMTALA posters and signs where patients are likely to notice.
Central log - central log of everyone who comes to the facility and requests
assessments and care.
Left without being seeing - record of all patients who leave the facility prior to receiving a
medical screening examination.
, Against medical advice - make reasonable effort to advise patients of medical risks of
leaving without receiving the recommended treatment, and if possible patient should be
asked to sign a form confirming their decision to leave without medical advice.
✔✔Exceptions of EMTALA - ✔✔Patient has the right to refuse the medical screening
examination and the facility is exempt from penalty if it informs the patient of
risks/benefits of screening and treatment.
EMTALA does not apply to an inpatient setting.
EMTALA mandates patient be evaluated regardless of the patient ability to pay or
financial status (financial screening is allowed as long as it doesn't delay medical
screening exam or treatment.
Patient must be transfer as needed for specialized care (patient consent and transfer
certification).
✔✔Discuss the risk management implications of non-compliance with EMTALA and
some methods to mitigate this risk - ✔✔Non-compliance with EMTALA may result in an
investigation by the state licensing authority, CMS, and the OIG, as well as other
regulatory agencies.
The facility's response to an investigation for non-compliance can also result in
significant legal expenses.
Risk management should focus on the establishment of and education of policies and
procedures. Emphasis should be placed on applying the requirements in a uniform,
non-discriminatory manner to all patients.
If a facility focuses on evaluating and treating its emergency patients appropriately and
consistently, the risks of non-compliance with EMTALA regulations will be minimized.
✔✔Discuss the on-call requirements for EMTALA - ✔✔Facility must keep a roster of
physician specialists who are available to provide consultation or care for patients with
emergency medical conditions within their area of expertise.
If 24/7 on-call coverage is not possible, the facility must document their reasonable
efforts to arrange for such coverage, for instance, transfer arrangements with other
facilities and contracted services.
On-call physicians must be advised of their obligations, and any time frames for
response to consultation requests.
Monetary penalties up to $50,000 per violation may be imposed on a physician, as well
as loss of Medicare provider status for failure to respond in a timely manner while on-
call.
As an alternative to on-call requirements, a facility may choose to participate in an
approved regional call coverage program.
✔✔Discuss the process of involuntary psychiatric treatment, including the generally
recognized standards for emergency treatment and civil detention - ✔✔Most states
recognize at least two types of involuntary treatment for a psychiatric crisis:
ANSWERS SET A+
✔✔Identify the categories of HACs for which Medicare won't reimburse the facility -
✔✔Non-reimbursable HACs:
- unintentional retention of foreign objects
- air embolism
- blood incompatibility
- stage III and IV pressure ulcers
- conditions resulting from falls and other trauma
- evidence of poor glycemic control
- catheter-associated unitary track infections
- surgical site infections following specific procedures (coronary artery bypass, bariatric,
orthopedic surgeries, etc.)
- vascular catheter-associated infections
- deep vein thrombosis/pulmonary embolism associated with orthopedic surgery
- latrogenic pneumothorax with venous catheterization
✔✔Discuss Emergency Medical Treatment & Labor Act (EMTALA) history, purpose and
legislation - ✔✔EMTALA was enacted in 1986 under the Consolidated Omnibus Budget
Reconciliation Act (COBRA), commonly referred are the "antidumping statute."
EMTALA ensures that individuals receive a medical screening and stabilizing treatment
for emergency medical conditions, regardless of their ability to pay or insurance status.
COBRA, on the other hand, allows individuals who lose their job-based health insurance
to temporarily continue their coverage.
EMTALA requirements: any person who comes to the emergency department seeking
evaluation or treatment for a medical condition, regardless of their ability to pay, must
be:
1. provided with a medical screening exam (MSE) to confirm if an emergency medical
condition exist.
2. if so, stabilize the emergency medical condition, and/or
,3. transfer patient to a facility that provides higher level of care if necessary
✔✔Key EMTALA terms - ✔✔Emergency Medical Condition - acute symptoms of
sufficient severity, including severe pain, resulting in placing patent's health in serious
jeopardy (bodily function impairment, body organ disfunction, etc.) - 42 USC
1395dd(e)(1).
Dedicated emergency department - specially equipped and staffed to treat patient with
emergency medical conditions - 42 CFR 489.24.
Comes to the emergency department - when a person presents anywhere within 250
yards of the main building 42 CFR 413.65 and request emergency services or who
would appear to a reasonably prudent person to be in need of medical attention 42 CFR
489.24.
Qualified medical person - designated by hospital bylaws as qualified to perform a
medical screening examination 42 CFR 489.24
✔✔Discuss EMTALA requirements for appropriate patient transfer - ✔✔Appropriate
transfer under EMTALA must meet the following:
➣ patient must be treated at the transferring hospital to stabilized to the extent possible
within its capacity and capabilities.
➣ patient must requires a higher level or care.
➣ the risk of transferring must be outweighed by the medical benefits of transfer, and
risks/benefits be certified by the transferring physician.
➣ receiving hospital must be contacted and agree to accept the transfer.
➣ copies of medical records from transferring facility must be sent with patient to the
receiving facility.
➣ transfer must be completed by qualified personnel and appropriate equipment.
Inappropriate transfer:
In the event that a facility receives a patient without the above requirements, the
receiving facility has an obligation under EMTALA to report a potential violation to the
appropriate regulatory agency.
✔✔Additional EMTALA requirements (besides the screening, stabilization, and transfer)
- ✔✔Notice of rights - EMTALA posters and signs where patients are likely to notice.
Central log - central log of everyone who comes to the facility and requests
assessments and care.
Left without being seeing - record of all patients who leave the facility prior to receiving a
medical screening examination.
, Against medical advice - make reasonable effort to advise patients of medical risks of
leaving without receiving the recommended treatment, and if possible patient should be
asked to sign a form confirming their decision to leave without medical advice.
✔✔Exceptions of EMTALA - ✔✔Patient has the right to refuse the medical screening
examination and the facility is exempt from penalty if it informs the patient of
risks/benefits of screening and treatment.
EMTALA does not apply to an inpatient setting.
EMTALA mandates patient be evaluated regardless of the patient ability to pay or
financial status (financial screening is allowed as long as it doesn't delay medical
screening exam or treatment.
Patient must be transfer as needed for specialized care (patient consent and transfer
certification).
✔✔Discuss the risk management implications of non-compliance with EMTALA and
some methods to mitigate this risk - ✔✔Non-compliance with EMTALA may result in an
investigation by the state licensing authority, CMS, and the OIG, as well as other
regulatory agencies.
The facility's response to an investigation for non-compliance can also result in
significant legal expenses.
Risk management should focus on the establishment of and education of policies and
procedures. Emphasis should be placed on applying the requirements in a uniform,
non-discriminatory manner to all patients.
If a facility focuses on evaluating and treating its emergency patients appropriately and
consistently, the risks of non-compliance with EMTALA regulations will be minimized.
✔✔Discuss the on-call requirements for EMTALA - ✔✔Facility must keep a roster of
physician specialists who are available to provide consultation or care for patients with
emergency medical conditions within their area of expertise.
If 24/7 on-call coverage is not possible, the facility must document their reasonable
efforts to arrange for such coverage, for instance, transfer arrangements with other
facilities and contracted services.
On-call physicians must be advised of their obligations, and any time frames for
response to consultation requests.
Monetary penalties up to $50,000 per violation may be imposed on a physician, as well
as loss of Medicare provider status for failure to respond in a timely manner while on-
call.
As an alternative to on-call requirements, a facility may choose to participate in an
approved regional call coverage program.
✔✔Discuss the process of involuntary psychiatric treatment, including the generally
recognized standards for emergency treatment and civil detention - ✔✔Most states
recognize at least two types of involuntary treatment for a psychiatric crisis: