Case 36-521 Unit 6

300 Words2 Pages
I’ve got some feedback on Barron’s draft:

36-521.02.B – This subsection says we can hold the patient while the screening agency (SA) reviews the application, which is good. However, we want to hold the patient while we make the application to the SA, too. We’d be fine with a timeframe for the hospital to make the application.

36-521.02.D – We have two comments here. 1) As drafted, the subsection says that if a Certificate of Hold is issued by the SA then a hospital can hold a patient for 9 hours, once medically cleared, while waiting for transport to the SA. We believe there is a loophole in the drafting -- the patient could leave AMA during the medical portion of their stay at the hospital. If the SA has issued a Certificate of Hold, hospitals should be able to hold the patient during the time it takes to medically clear the patient. 2) To Jennifer’s question about 9 hours, we believe that a hospital should be able to hold the patient for as long as it takes to transfer the patient to the SA. If the SA has issued a Certificate of Hold why do we have to release them after 9 hours if the SA cannot secure transport? We are imposing a timeframe on hospitals that we cannot control. If the SA believes the patient needs a Certificate of Hold, why impose limits on the hospital?
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If the SA is going to be the clinical gatekeeper, then the SA needs to take clinical accountability for the patient. If the SA does not believe the patient needs screening, then the SA needs to assume care for the patient and document the discharge in the
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