PA Department of Health Defines Factors and Uses for “Innovative Hospital Models”

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
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