- Supreme Court Denies Review of 6th Circuit Ruling that Hospitals’ EMTALA Obligations Continue after Admitting Individuals for Inpatient Care
- August 24, 2010 | Author: Jessica M. Eames
- Law Firm: King & Spalding LLP - Atlanta Office
On June 28, 2010, the United States Supreme Court denied certiorari on a recent ruling by the United States Court of Appeals for the Sixth Circuit, holding that the Emergency Treatment and Labor Act (EMTALA) continues to apply after individuals are admitted from an Emergency Department to the hospital as an inpatient.
Moses v. Providence Hospital & Medical Ctrs., involved claims alleging EMTALA violations against a Michigan hospital by the estate of Marie Moses-Irons who was murdered by her husband 10 days following his discharge from the hospital after being admitted for a psychotic episode. Physicians in the emergency department admitted the husband as an inpatient for further testing, after which he was diagnosed with a migraine headache and “atypical psychosis [with] delusional disorder” and discharged six days later.
The Sixth Circuit held that “EMTALA imposes an obligation on a hospital beyond simply admitting a patient with an emergency medical condition to an inpatient care unit.” The Court concluded that “EMTALA requires a hospital to treat a patient with an emergency condition in such a way that, upon the patient’s release, no further deterioration of the condition is likely.” Consequently, “the statute requires more than the admission and further testing of a patient; it requires that actual care, or treatment, be provided as well.”
In reaching this decision, the Court of Appeals rejected the Centers for Medicare & Medicaid Services’ (CMS) 2003 regulation clarifying that a hospital’s EMTALA obligations are satisfied if an individual with an emergency medical condition is admitted to the hospital “as an inpatient in good faith in order to stabilize the emergency medical condition.” According to CMS, “[i]f the hospital admits the individual as an inpatient for further treatment, the hospital’s obligation under [EMTALA] ends.” The Court found CMS’s interpretation of the statute to be “contrary to EMTALA’s plain language,” concluding instead that “treatment” in order to stabilize a medical condition requires more than admitting the individual for further testing.
Before the Moses decision, only two other circuit courts had directly addressed whether EMTALA obligations continue after a hospital admits a patient. Both were decided prior to the 2003 CMS regulation, and both reached the opposite conclusion. In 2002, the Ninth Circuit held in Bryant v. Adventist Health Sys./W, 289 F.3d 1162 (9th Cir. 2002) that “EMTALA’s stabilization requirement ends when an individual is admitted for inpatient care.” After a patient is admitted, according to that court, “state tort law provides a remedy for negligent care.” Similarly, the Fourth Circuit decided in 1996 in Bryan v. Rectors & Visitors of the Univ. of Va., 95 F.3d 349 (4th Cir. 1996) that EMTALA’s “stabilization requirement was intended to regulate the hospital’s care of the patient only in the immediate aftermath of the act of admitting her for emergency treatment and while it considered whether it would undertake longer-term full treatment or instead transfer the patient to a hospital that could and would undertake that treatment.”
The Moses Court reached its decision without citing to these conflicting decisions in the Ninth and Fourth circuits. Judging from its certiorari denial, the Supreme Court appears content to permit the now shallow circuit split to develop further before deciding whether to weigh in.