On March 2, 2022 the Pennsylvania Department of Health ("DOH") issued guidance on what they term "Innovative Hospital Models." These include Micro-Hospitals, Outpatient Emergency Departments, and Tele-Emergency Departments. While some of these models have been approved on a very limited and selective basis, for most of Pennsylvania, there is now a clear understanding what a hospital must do to operate under each of the models.
Micro-Hospitals: The DOH defines a micro-hospital as a hospital with a minimum of 10 beds and a minimum of 10 ED treatment rooms. Some of the salient factors are as follows:
- There is no limit on the location of a micro-hospital
- A micro-hospital can be stand-alone, or on a campus of a hospital
- A physician must be on site 24/7
- EMS can transport patients to the ED
- There is no exception needed (generally) to implement
Outpatient Emergency Departments ("OED"): The DOH will permit a campus of a hospital (without inpatient beds) to offer 24/7 ED services in rural locations. Important aspects include the following:
- The OED must be an outpatient department of a hospital - no freestanding EDs are permitted in PA
- The OED must be located in a rural area defined by the 2010 decennial census
- There must be a minimum of 10 ED treatment rooms
- There must be a physician on site 24/7
- EMS can transport patients to the OED
- Implementation does not require an exception (just follow 28 Pa. Code Chapter 51.3, in all cases above)
Tele-Emergency Departments ("tele-ED"): This model is for use in a rural area only and provides flexibility for rural hospitals. Its features include:
- The hospital must be located in a rural area defined by the 2010 decennial census
- There must be inpatient beds, but there is no minimum number of ED treatment rooms
- The tele-ED is staffed with advanced practice providers ("APPs") with ED privileges
- A physician must be immediately available through telemedicine 24/7
- EMS can transport patients to the tele-ED (but the tele-ED cannot take Medical Command, i.e., does not satisfy the requirements of a Medical Command Facility)
- Implementation does require an exception
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.