EMTALA: Court Finds No Evidence That Hospital Had Screening Procedure in Place

​Characterizing the facts of the case as "tragic," the U.S. District Court for the Eastern District of Pennsylvania denied a hospital's motion for summary judgment on an Emergency Medical Treatment and Labor Act (EMTALA) claim that the hospital failed to perform an appropriate medical screening exam for a 47-year-old woman who died in the hospital emergency department (ED) as a result of hemopericardium caused by a ruptured aortic dissection. The court noted that EMTALA does not define "appropriate medical screening" and that federal courts have interpreted the law as requiring hospitals to provide uniform screening to patients with substantially similar clinical complaints. Thus, to sustain an EMTALA claim, the plaintiff must allege that the hospital failed to apply its standard of screening uniformly to all patients in the ED.

The court found that defendant hospital failed to provide the court with its standard screening procedures and instead argued that the emergency physician followed a logical process in making a differential diagnosis to rule in or rule out various medical conditions for the patient, which the hospital contended constitutes screening under EMTALA. The court rejected the hospital's argument, stating that how the emergency physician exercised her medical...