> What's a "hospital that has no real ER" mean? COBRA applies to "a
> hospital that has a hospital emergency department."
This is true to an extent. COBRA applies not only to the ED, but to the
entire facility. Thus a medically unstable patient on the floor, in the
OR, or in the parking lot must be stabilized to the full capability of
your hospital. Many people think that COBRA only applies to the ED and
the ED doctors, but this couldn't be further from the truth.
This particular hypothetical scenario is somewhat difficult because of
the unusual nature of this facility that has no ED, but does have a
"high risk NICU" which means they are clearly capable as a facility of
taking care of a pediatric patient in extremis. I've never encountered
such a facility, but would suspect that the answer could only be
provided by HCFA. I would ask the regional HCFA representative to make a
statement as to whether or not this "hypothetical facility" falls under
the regulations of COBRA.
Daniel E. Kates, M.D.
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Thunderbird Samaritan Medical Center
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