Tristar Centennial Medical Center Agreed to Pay $725,000 for Allegedly Violating Patient Dumping Statute by Failing to Provide Available Stabilizing Treatment

On December 29, 2021, Tristar Centennial Medical Center (Tristar Centennial), Nashville, Tennessee, entered into a $725,000 settlement agreement with OIG. The settlement agreement resolves allegations that, based on OIG’s investigation, Tristar Centennial violated the Emergency Medical Treatment and Labor Act (EMTALA) when it failed to provide, with the staff and facilities available, further medical examination and treatment required to stabilize 29 patients’ emergency medical conditions. In each of these incidents, a patient presented to Tristar Centennial with an unstable psychiatric emergency medical condition. In two of these incidents, rather than admitting the patient to Tristar Centennial’s onsite psychiatric unit, Parthenon Pavilion, which had the capability and capacity to treat the patient, Tristar Centennial discharged the patient home with an unstable emergency medical condition. For other presentments, rather than admitting the patient to Parthenon Pavilion, Tristar Centennial held the patient inappropriately in its Emergency Department (ED) for over 24 hours before transferring the patient. The decision to transfer the patient, and where to transfer the patient, was made by Tristar Centennial and the Tristar Behavioral Health Transfer Center and was based, in part, on the patient’s insurance status. Tristar Centennial asserts that its decision to transfer the patients was based on a recommendation from a mobile crisis team. The patients had varied medical histories and presented with individualized complaints to the ED. While each individual was determined to have an unstable emergency medical condition, Tristar Centennial failed to provide needed and available stabilizing treatment to each of these individuals.

The following are examples of such incidents.

Patient M.R., a 57-year-old male, arrived by ambulance at Tristar Centennial’s ED on July 13, 2017, at 12:47 A.M. with complaints of delusions and mania. M.R. had out-of-state Medicaid insurance. At 12:59 a.m., an ED physician initiated an examination of M.R. and completed a Certificate of Need for Emergency Involuntary Admission. M.R. was transferred to a state psychiatric hospital, after being held in Tristar Centennial’s ED for 105 hours, during which time M.R. did not receive available stabilizing treatment.

Patient J.A., a 39-year-old female, was brought by ambulance to Tristar Centennial’s ED on July 16, 2017, at 7:47 A.M. with complaints of psychosis. J.A. appeared confused, disoriented, and was found walking through traffic. J.A. was uninsured. At 8:08 A.M., an ED physician initiated an examination of J.A., and a Certificate of Need for Emergency Involuntary Admission was completed. When J.A. attempted to leave the ED, she was administered Haldol and Valium. J.A. remained in the ED for 91 hours, without receiving stabilizing treatment, before being transferred to a state psychiatric hospital with an unstable emergency psychiatric condition.

Patient J.R., a 37-year-old male, presented to Tristar Centennial’s ED on October 11, 2017, at 3:06 P.M. with complaints of suicidal ideations and wanting to detox. J.R. was uninsured. At 3:15 P.M., a nurse practitioner initiated an examination of J.R. On October 13, 2017, at 5:00 A.M., an ED physician completed a Certificate of Need for Emergency Involuntary Admission. J.R. was transferred to a state psychiatric hospital after being held in the ED for 160 hours, during which time he did not receive available stabilizing treatment for his emergency medical condition.

Patient B.E., a 22-year-old male, arrived by ambulance to Tristar Centennial’s ED on April 2, 2016, at 9:18 P.M. with chief complaints of hallucinations and suicidal ideations. B.E. was homeless and uninsured. At 9:25 P.M., an ED physician initiated an examination of B.E. B.E. remained in the ED for 64 hours, without receiving stabilizing treatment, before being discharged with an unstable emergency psychiatric condition.

Similar incidents occurred for the following individuals presenting to the ED: N.A. (5/30/2017); J.S. (7/12/2017); W.H. (7/13/2017); R.S. (7/13/2017); J.W. (8/24/2017); D.M. (1/5/2017); L.R. (6/4/2017); K.J. (6/7/2017); A.H. (7/22/2016); A.H. (10/6/2016); A.H. (10/28/2016); A.H. (11/6/2016); A.H. (1/14/2017); J.F. (11/12/2015); A.R. (10/24/2015); M.H. (7/21/2016); J.H. (5/27/2017); R.A. (5/22/2017); F.H. (5/17/2017); C.H. (7/13/2017); M.F. (9/11/2016); J.S. (3/11/2016); T.B. (5/1/2017); J.B. (1/18/2017); and T.S. (2/2/2016).

In each of these cases, TriStar Centennial determined the individual had an unstable emergency medical condition and failed to provide needed and available treatment to stabilize that emergency medical condition. Senior Counsel Sandra Sands and Associate Counsel Tessa Deveraux represented OIG.

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