Do the EMTALA transfer requirements apply to transfers from off-campus hospital-based outpatient departments?
Transporting a patient from an off-campus hospital-based department to the main hospital will not be considered a transfer under EMTALA, therefore, the strict transfer requirements will not apply. HCFA considers an off-campus hospital-based facility to be a part of the hospital, and because intra-hospital transportation of a patient is not considered to be a transfer under EMTALA, transporting an individual from the hospital-based entity to the main hospital will not be considered a transfer. However, should the hospital-based facility need to transfer the individual to another unrelated hospital, the “appropriate transfer” requirements must be followed. Q: Can a hospital-based clinic simply dial 911 or the local EMS emergency number for individuals presenting to the clinic with emergency medical conditions? A: Based on the EMTALA transfer guidelines, it is not appropriate for the hospital-based facility to simply dial 911 and rely on EMS to assume responsibility of the patient. The ho