·	NeurosurgeryPAC
·	About the Washington Committee
·	Collective Bargaining
·	EMTALA
·	Fraud and Abuse
·	Graduate Medical Education
·	Make a Difference
·	Medical Liability Reform
·	Medical Research
·	Miscellaneous Legislation
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·	Patient Bill of Rights
·	Protect Patients Now
·	Regulatory Policies of Interest
·	Reimbursement
·	Stroke

EMTALA March 2005: AANS/CNS Submit Comments to EMTALA Technical Advisory Group. Click here for a copy of the comments (PDF 250KB) July 9, 2002: Comments to HHS regarding proposed rule relating to the "Responsibilities of Medicare Participating Hospitals in Emergency Cases" under the Emergency Medical Treatment and Active Labor Act (EMTALA) As a result of extreme pressure by neurosurgery, on June 13th, the Centers for Medicare and Medicaid Services (CMS) issued a memorandum to its state and regional enforcement offices clarifying the EMTALA rules (the State Operation Manual - SOM) related to simultaneous call. The memo states "After lengthy discussions with the medical community, and understanding the impact of this policy, CMS is revising its policy to allow on-call physicians to provide coverage simultaneously at several hospitals to maximize patient access to care. As required in the SOM, hospitals must have policies and procedures to follow when an on-call physician is simultaneously on-call at another hospital and are not available to respond. Hospital policies may include, but are not limited to procedures for back-up on-call physicians, or the implementation of an appropriate EMTALA transfer..." On the same day, CMS also published additional guidance for on-call physicians in the form of a question and answer document. This publication also addresses the issues of 24/7/365 on-call coverage and rules related to scheduling and performing elective surgery while on-call.

• June 13, 2002: Clarification from CMS regarding hospital responsibilities concerning on-call physicians (PDF 23KB)
  
  
• June 13, 2002: Question & Answer Document (PDF 16KB)
  
  
• The Centers for Medicare and Medicaid Services recently pronounced that serving on-call to more than one hospital simultaneously and performing elective surgery while on-call to the emergency department may violate EMTALA. The AANS and CNS are therefore urging all neurosurgeons to write CMS and object to this policy. On this page you will find a variety of information related to this topic.
  
  
• May 31, 2002: AANS/CNS Action Alert (PDF 31KB)
  
  
• Sample Comment Letter (PDF 18KB)
  
  
• May 30, 2002: AANS/CNS Comment Letter to CMS (PDF 68KB)
  
  
• Executive Summary of AANS/CNS Comment Letter to CMS (PDF 42KB)
  
  
• May 9, 2002: EMTALA Federal Register Notice
  Go to http://www.access.gpo.gov/su_docs/fedreg/a020509c.html and scroll down to the Centers for Medicare and Medicaid Services. The EMTALA regulations are included in the "Hospital Inpatient Prospective Payment Systems and 2003 FY Rates." Because the document is so large it is divided into several files. The EMTALA regulations are on p.31469-31479. The on-call provisions begin on p. 31478.
  
  
• >May 8, 2002: (PDF 16KB)
  
  
• April 15, 2002: AANS/CNS Letter to HHS Secretary Tommy G. Thompson (PDF 60KB)
  
  
• EMTALA Interpretive Guidelines. Centers for Medicare and Medicaid Services
  http://www.hcfa.gov/pubforms/07_som/somap_v_013_to_034.htm
  
  
• EMTALA Quick Reference Guide for On-Call Physicians. American Medical Association
  http://www.ama-assn.org/ama/pub/category/2650.html
  
  
• For More Information: If you have any questions related to this or other health policy issues, please contact Katie O. Orrico, Director, AANS/CNS Washington Office at 202-628-2072 or via e-mail at korrico@neurosurgery.org.