Some consultants have been informing urgent care administrators that since they are a hospital-owned urgent care center, they are now classified a type B emergency department. Simply being a hospital-owned facility, however, does not necessarily mean that your urgent care center meets the specific criteria outlined by the Centers for Medicare & Medicaid Services (CMS) for type B emergency departments.
To qualify as a type B emergency department, the urgent care center must meet at least one of the following criteria:
- Licensing: The clinic is licensed by the state in which it is located under applicable state law as an emergency room or emergency department.
Comment: Only if your urgent care center is licensed as an emergency department would your urgent care center qualify under this criterion.
- Self Designation: The clinic is held out to the public by name, posted signs, advertising, or other means as a place that provides care for emergency medical conditions on an urgent basis without requiring a previously scheduled appointment.
Comment: Very few urgent care centers describe the clinic as treating “emergency conditions.” Indeed, the opposite is more common, as almost all urgent care centers publicly communicate that their clinics are not appropriate for evaluating or treating true emergency conditions. Most urgent care clinics, instead, tell the public to call 911 or to go to a hospital emergency department, if the problem is a true emergency.
- Patient Visits: During the calendar year immediately preceding the calendar year in which a determination under this section is being made based on a representative sample of patient visits that occurred, at least one-third of all outpatient visits to the urgent care center are for the treatment of emergency medical conditions on an urgent basis without requiring a previously scheduled appointment.
Comment: Almost no urgent care centers experience an incidence of patient visits for true emergency conditions of one-third or greater. Indeed, one might suspect that many hospital emergency departments do not see over one-third of their patients for true emergency conditions.
Thus, after applying the specific criteria for a type B emergency department, very few urgent care centers are appropriately classified as type B emergency departments.
Some confusion may arise from application of the third criterion. There are three parts to this criterion, however, and in order to qualify as a type B emergency department your urgent care center must meet the definition in all three parts (not just one or two parts). Are over 1/3 of the visits to your urgent care center:
- on an urgent basis
- without appointment
- and for treating emergency medical conditions?
Urgent care centers will generally answer “yes” to the first two components (1) “urgent basis?” and 2) “without appointment?”. But almost all true urgent care centers will answer the last question with a definitive “no,” Hence, these urgent care clinics do not qualify as type B emergency departments.
The criteria for qualifying as a type B emergency department are essentially identical to the criteria that determine whether or not a facility is covered under EMTALA. Thus, if an urgent care center does not qualify as a type B emergency department, then that urgent care center will not be required to follow the EMTALA guidelines.
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