EMTALA: Access to Emergency Medical Care
Edward C. Liu
Legislative Attorney
July 1, 2010
Congressional Research Service
7-5700
www.crs.gov
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repared for Members and Committees of Congress

EMTALA: Access to Emergency Medical Care

Summary
The Emergency Medical Treatment and Active Labor Act (EMTALA) ensures universal access to
emergency medical care at all Medicare participating hospitals with emergency departments.
Under EMTALA, any person who seeks emergency medical care at a covered facility, regardless
of ability to pay, immigration status, or any other characteristic, is guaranteed an appropriate
screening exam and stabilization treatment before transfer or discharge. Failure to abide by these
requirements can subject hospitals or physicians to civil monetary sanctions or exclusion from
Medicare. Hospitals may also be subject to civil liability under the statute for personal injuries
resulting from the violation.
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EMTALA: Access to Emergency Medical Care

Contents
The Screening Requirement ........................................................................................................ 1
When Is the Screening Requirement Triggered? .............................................................. 2
What Constitutes an “Appropriate Screening Exam”?...................................................... 3
The Stabilization Requirement .................................................................................................... 3
Interpretations of the Stabilization Requirement .................................................................... 4
Stabilization and Inpatient Status..................................................................................... 4
Stabilization of Known Emergency Conditions................................................................ 6
Requirements for Transfers After Stabilization ................................................................ 6
Hospital Liability to Third Parties ............................................................................................... 7

Contacts
Author Contact Information ........................................................................................................ 8

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EMTALA: Access to Emergency Medical Care

n 1986, Congress enacted the Emergency Medical Treatment and Active Labor Act
(EMTALA)1 to address the problem of “patient dumping” in hospital emergency departments.
I Patient dumping refers to instances in which a hospital turns away indigent or uninsured
persons seeking treatment so that the hospital will not have to absorb the cost of treating them.
Although attempts to facilitate indigent access to emergency health care already existed in state
and federal law, legal frameworks prior to EMTALA were plagued with poor enforcement
mechanisms and vague standards of conduct.2 Amid graphic media reports of hospitals sending
away critically ill patients without proper stabilization treatment and delivery rooms unwilling to
accept indigent or uninsured women in labor, Congress passed EMTALA as part of the
Consolidated Omnibus Budget Reconciliation Act of 1985.3
EMTALA’s statutory scheme has traditionally been deconstructed into two principal categories:
(1) provisions that ensure an appropriate medical screening, and (2) provisions that require
stabilization before transfer or discharge.4 EMTALA only requires stabilization of whatever
emergency conditions a hospital detects, and does not provide a right to indefinite care for anyone
who comes to an emergency room. EMTALA’s requirements may be suspended by the Secretary
of Health and Human Services during national emergencies, such as the recent landfall of
Hurricane Ike in Texas.5 Hospitals and physicians that fail to comply with these requirements may
be fined $50,000 and/or excluded from participation in Medicare, and hospitals may also be held
civilly liable to persons who suffer personal injury.6
The Screening Requirement
Only hospitals that (1) participate in Medicare and (2) maintain an emergency department are
required to screen patients under EMTALA.7 Hospitals that do not have a “dedicated emergency
department” are not subject to the screening requirement of EMTALA.8 Similarly, emergency

1 P.L. 99-272, 100 Stat. 164 (1986) codified at 42 U.S.C. § 1395dd et seq. (2007).
2 Tiana Mayere Lee, An EMTALA Primer: The Impact of Changes in the Emergency Medicine Landscape on EMTALA
Compliance and Enforcement
, 13 ANNALS OF HEALTH L. 145, 146-147 (2004) (discussing the Hill-Burton Act and state
statutory and common law). See also H.Rept. 99-241, pt. 3, at 5 (1985) (discussing state remedies).
3 Lee, supra note 2 at 147-148, 151.
4 42 U.S.C. § 1395dd(a), (b).
5 42 U.S.C. § 1320b-5(b)(3). See Waiver or Modification of Requirements Under Section 1135 of the Social Security
Act, Michael O. Leavitt, Secretary of the Department of Health and Human Services, (Sept. 11, 2008), available at
http://www.hhs.gov/disasters/emergency/naturaldisasters/hurricanes/ike/1135waiver.html. Sanctions are only lifted for
inappropriate transfers or redirections. 42 C.F.R. § 489.24(a)(2).
6 42 U.S.C. § 1395dd(d). Civil fines are limited to $25,000 for hospitals with fewer than 100 beds. Id. at (d)(1)(A).
Private suits may not be brought against physicians individually. See e.g. Heimlicher v. Steele, 442 F. Supp. 2d 685
(N.D. Iowa 2006) (citing King v. Ahrens, 16 F.3d 265 (8th Cir. 1994), Delaney v. Cade, 986 F.2d 387 (10th Cir. 1993),
and Baber v. Hosp. Corp. of Am., 977 F.2d 872 (4th Cir. 1992)). Medicare termination appears to be infrequently
invoked as a sanction. Laura D. Hermer, The Scapegoat: EMTALA and Emergency Department Overcrowding, 14 J. L.
& Policy 695, 701 n. 29 (2006) (stating that between 1986 and 2001 only four hospitals had their Medicare agreements
terminated).
7 42 U.S.C. § 1395dd(a), (d)(1)(A), and (e)(2). Although the screening and stabilization requirements are phrased such
that they apply to “hospitals” generally, enforcement of EMTALA is only authorized against hospitals that have
entered into a Medicare provider agreement. Id.
8 42 U.S.C. § 1395dd(a). A dedicated emergency department is defined as any facility that is licensed or held out to the
public as such, or that provides urgent care to one third of its outpatients during the preceding calendar year. 42 C.F.R.
§ 489.24(b).
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care providers that are unaffiliated with a hospital need not comply with EMTALA, even where
those providers are the only medical care facilities reasonably accessible.9 For example, in
Rodriguez v. American Int’l Ins. Co. of Puerto Rico, the First Circuit declined to extend EMTALA
protections to a 24-hour emergency room clinic in rural Puerto Rico because the clinic was not
associated with a hospital. The Federal District Court for the District of Puerto Rico had initially
held that, because the clinic was the primary provider of 24-hour emergency health care in its
area, applying EMTALA to the clinic best furthered the statutory goal of universal access to
emergency medical care.10 However, the First Circuit reversed, holding that any considerations of
the goals of Congress were inappropriate where the text of the statute was clear.11
When Is the Screening Requirement Triggered?
The screening requirement is triggered when an individual “comes to the emergency department”
of a hospital and requests to be treated.12 Under HHS regulations, an individual may be deemed to
have come to the emergency department in certain circumstances, even though the individual is
not physically present in the emergency department or elsewhere on the hospital campus.13 For
example, a patient en-route to a hospital in an ambulance or air transport owned by that hospital
has “come to the emergency department” of that hospital and may not be refused a screening
exam under EMTALA. These regulations also state that incoming patients in ambulances that are
not owned by the receiving hospital have not “come to the emergency department.” The
regulations further allow the hospital to redirect the non-owned ambulance if the hospital is in
“diversionary status.”14 However, at least one Federal Court of Appeal has rejected this
interpretation of the statute and has held that EMTALA could be triggered by an incoming
ambulance that was not owned by the receiving hospital.15
In Morales v. Sociedad Espanola, the hospital had argued that HHS regulations clearly state that
patients in non-owned ambulances have not yet “come to the emergency department,” and
therefore EMTALA did not apply. However, according to the First Circuit’s reading of the
pertinent regulations, a hospital is only permitted to take the affirmative action of refusing a non-
owned ambulances if it is actually in “diversionary status.” The court argued that this reading

9 Rodriguez v. American Int'l Ins. Co. of Puerto Rico, 402 F.3d 45 (1st Cir. 2005).
10 Rodriguez v. American Int'l Ins. Co. of Puerto Rico, 263 F. Supp. 2d 297 (D. Puerto Rico 2003) (arguing that the
nature of the services provided should be determinative, not whether a facility is defined as a hospital).
11 Rodriguez v. American Int'l, 402 F.3d at 49 (noting that Congress was free in drafting the statute to extend EMTALA
to rural clinics unaffiliated with hospitals, but had not done so). EMTALA does apply to facilities designated as
“critical access hospitals,” which provide 24-hour emergency services and acute inpatient care to rural areas. 42 U.S.C.
§ 1395dd(e)(5).
12 42 U.S.C. § 1395dd(a). Requests for treatment may be made on the individual’s behalf and a request may be implied
if a prudent layperson observer would believe that the individual needs emergency medical care. 42 C.F.R. § 489.24(b)
(2006).
13 42 C.F.R. § 489.24(b). The campus includes areas within 250 yards of a hospital’s main buildings. 42 C.F.R. §
413.65(b).
14 42 C.F.R. § 489.24(b). A hospital is in diversionary status if it lacks the staff or facilities to treat additional
emergency patients. See also Arrington v. Wong, 237 F.3d 1066, 1072 (9th Cir. 2001) (reasoning through negative
implication that a hospital may not divert an ambulance if it is not in diversionary status).
15 Morales v. Sociedad Española de Auxilio Mutuo y Beneficencia, 524 F.3d 54 (1st Cir. 2008) (cert. denied Sociedad
Espanola v. Morales, 77 U.S.LW. 3396 (2009)).
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gives effect to every word in the regulation and also best effectuates EMTALA’s statutory goal of
preventing patient dumping.16
Regardless of whether the ambulance is owned by a hospital or not, should an ambulance ignore a
redirection request, EMTALA is triggered if the patient physically arrives on the hospital’s
property.17
What Constitutes an “Appropriate Screening Exam”?
Although hospitals with dedicated emergency departments are required to perform screening
exams, it is not necessarily a violation of EMTALA if a screening exam falls short of either a
local or national medical malpractice standard.18 The language of the statute requires only “an
appropriate medical screening exam.”19 The majority of the federal circuits have held that,
because the chief evil sought to be prevented was the lack of access for uninsured patients, an
“appropriate” exam is one comparable to what a paying patient would receive under similar
circumstances.20 However, the Sixth Circuit has construed the statute more narrowly, holding that
there is no violation of EMTALA without the additional allegation of an “improper motive” that
led to a substandard screening exam.21
The Stabilization Requirement
Like the screening requirement, the stabilization requirement applies to all Medicare participating
hospitals with a dedicated emergency department. However, in some cases the stabilization
requirement may also apply to a Medicare participating hospital even if it does not have an
emergency department. For example, if treatment of an individual’s medical condition requires a
particular hospital’s unique equipment or expertise, federal regulations compel that hospital to
accept a transfer of that patient from any nearby U.S. hospital.22
The stabilization requirement is triggered when a hospital discovers that an individual has an
emergency medical condition. Actual knowledge of an emergency medical condition is

16 Id. at 59-62.
17 42 C.F.R. § 489.24(b). Prior to the promulgation of these regulations, the Seventh Circuit had held that contacting a
hospital via telemetry alone does not invoke EMTALA. Johnson v. Univ. of Chicago Hosps., 982 F.2d 230 (7th Cir.
1993). These regulations are consonant with that holding.
18 Phillips v. Hillcrest Med. Ctr., 244 F.3d 790 (10th Cir. 2001) (noting that EMTALA was not enacted to create a
federal medical malpractice standard).
19 42 U.S.C. § 1395dd(a). Screening exams may vary based upon a hospital’s capabilities and the nature of an
individual’s request. 42 C.F.R. § 489.24(a)(i) and (c).
20 Correa v. Hosp. San Francisco, 69 F.3d 1184 (1st Cir. 1995), Baber v. Hosp. Corp. of America, 977 F.2d 872 (4th Cir.
1992), Marshall v. E. Carroll Parish Hosp. Serv., 134 F.3d 319 (5th Cir. 1998), Summers v. Baptist Med. Ctr.
Arkadelphia, 91 F.3d 1132 (8th Cir. 1996), Jackson v. E. Bay Hosp., 246 F.3d 1248 (9th Cir. 2001), Holcomb v.
Monahan, 30 F.3d 116 (11th Cir. 1994), Gatewood v. Wash. Healthcare Corp., 933 F.2d 1037 (D. C. Cir. 1991).
21 Cleland v. Bronson Health Care Group, Inc., 917 F2d 266, 272 (6th Cir. 1990). Gender, race, nationality, financial
insolvency, bias against a particular medical condition, and personal animosity were examples of improper motivation
offered by the Cleland court.
22 42 C.F.R. § 489.24(f). Examples of specialized equipment or expertise include burn units, shock-trauma units,
neonatal intensive care units, or regional referral centers.
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required.23 Therefore, if a hospital fails to accurately detect an individual’s emergency condition
and discharges that individual without stabilizing the medical condition, the hospital may not
have violated EMTALA’s stabilization provisions. However, the hospital may still be civilly liable
to the individual based upon state medical malpractice claims if the failure to detect an emergency
condition was due to negligence during the screening exam.24
Interpretations of the Stabilization Requirement
Except where medically necessary, hospitals must ensure that an individual is stabilized before
discharge or transfer. Federal regulations define an individual as stabilized as either (1) when
there is a reasonable assurance that no material deterioration would result from that individual’s
transfer or discharge from the hospital or, (2) in the case of women in labor, after delivery of the
child and placenta.25 Unlike the screening requirement, the language of the stabilization
requirement does not qualify the care to be given as “appropriate.”26 Based on this textual
distinction, the U.S. Supreme Court has held that no “improper motive” need be alleged to show a
violation of EMTALA’s stabilization provisions.27
Stabilization and Inpatient Status
When an emergency medical condition is detected, a hospital may decide to admit the individual
as an inpatient for further treatment. Whether the stabilization requirement continues to apply to
patients after they have been admitted is a disputed issue. Because the statute only defines
“stabilization” in the context of transfers, the Fourth, Ninth and Eleventh Circuits have held that a
hospital has no stabilization duties that are enforceable under EMTALA once an individual has
been admitted.28 However, the Sixth Circuit had held otherwise in Thornton v. Southwest Detroit
Hospital
.29 In that case, a stroke victim alleged she was discharged from the ICU without being
stabilized, in violation of EMTALA, after 21 days of inpatient care. The Sixth Circuit held that
EMTALA still required stabilization before discharge, despite her inpatient status.30
Despite this split in circuit authority, the Supreme Court declined to rule on this issue in Roberts
v. Galen
, although it had an opportunity to do so.31 During oral arguments for that case, the office
of the Solicitor General, arguing as amicus curiae, informed the Court that the Department of
Health and Human Services intended to begin rule-making procedures to provide guidance on

23 42 U.S.C. § 1395dd(b)(1) and 42 C.F.R. § 489.24(a)(1)(ii).
24 Bryant v. Adventist, infra note 28 at 1166.
25 42 C.F.R. § 489.24(b).
26 42 U.S.C. § 1395dd(b)(1)(A).
27 Roberts v. Galen, 525 U.S. 249, 252-3 (1999). The Court expressly declined to decide whether the “improper
motive” requirement was required with respect to EMTALA’s screening provisions. Id. at 253 n.1. See also supra notes
20-21 and accompanying text.
28 Bryan v. Rectors & Visitors of the Univ. of Virginia, 95 F.3d 349, 352 (4th Cir. 1996), Bryant v. Adventist Health
Sys., 289 F.3d 1162, 1168-1169 (9th Cir. 2002), Harry v. Marchant, 291 F.3d 767 (11th Cir. 2002).
29 Thornton v. Southwest Detroit Hosp., 895 F.2d 1131, 1135 (6th Cir. 1990).
30 The Sixth Circuit argued in dictum that if EMTALA did not apply to inpatients, hospitals could avoid EMTALA
liability by admitting, and immediately discharging, a patient. Id. at 1135.
31 Roberts v. Galen, 525 U.S. at 253-4 n.2.
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this question.32 In 2002, the Centers for Medicare and Medicaid Services (CMS) issued a notice
of a proposed rule extending EMTALA protections to inpatients.33 Many comments noted the
Bryant v. Adventist34 decision holding otherwise,35 and in 2003, CMS reversed its position, stating
that if, after performing a screening exam, a hospital admits an individual for treatment of an
emergency medical condition, then the hospital has satisfied its duties under EMTALA.36
In August of 2008, HHS further clarified its position by stating that EMTALA does not apply to
an individual who has been screened and admitted at one hospital but requires a transfer to a
second hospital that has specialized facilities.37 As described above, where a patient has not yet
been admitted, nearby specialized hospitals are generally required to accept transfers of the
patient from the original hospital.38 However, the new regulations clearly state that once the
individual has been admitted as an inpatient in one hospital, other specialized hospitals do not
continue to have a duty to accept a transfer under EMTALA.39
Despite the promulgation of these rules, the Sixth Circuit has continued to hold that the mere
admission of an individual, without further treatment, does not satisfy EMTALA.40 In Moses v.
Providence Hospital
, the court found CMS’s regulations to be contrary to the plain language of
the statute. Therefore, the regulations were not entitled to deference.41 In particular, the court
relied upon language in EMTALA which prohibits hospitals from releasing patients with
emergency medical conditions without providing treatment to stabilize the condition. According
to the court, the CMS regulations would permit hospitals to avoid EMTALA liability by simply
admitting and immediately discharging patients, without providing any treatment. The court
found such a construction to be unreasonable and contrary to the language of the statute.42
However, one could argue that by admitting an individual, a hospital is subject to potential
medical malpractice liability under state law. Therefore, while the CMS regulations may provide
a means of avoiding EMTALA liability by admitting and discharging individuals, compliance
with CMS’s interpretation would not necessarily immunize hospitals from applicable state law
claims. Insofar as the intent of EMTALA was to prevent situations in which hospitals could
“dump” patients without incurring any liability, providing an incentive for hospitals to admit
emergency room patients may be consistent with that goal. Once a patient is admitted, it could be
argued that EMTALA liability is unnecessary as state medical malpractice law could provide an
incentive for the hospital to ensure the provision of necessary stabilizing treatment.

32 Transcript of Oral Argument at 17-20, Roberts v. Galen, supra note 27. The Solicitor General also argued that the
question of inpatient status had not been properly raised in the courts below.
33 Notice of Proposed Rule, 67 Fed. Reg. 31,403, 31,475-6 (May 9, 2002).
34 Bryant v. Adventist Health Sys., 289 F.3d at 1168-1169.
35 Notice of Final Rule, 68 Fed. Reg. 53,221, 53,243-5 (Sept. 9, 2003). Comments also expressed concerns that
EMTALA would usurp existing protections for inpatients.
36 42 C.F.R. § 489.24(d)(2). Inpatients are still protected by other Medicare conditions of participation. Persons
admitted for elective treatment or diagnosis are still covered under EMTALA. Id.
37 73 Fed. Reg. 48,656-61.
38 See supra note 22 and accompanying text.
39 42 C.F.R. 489.24(f)(2).
40 Moses v. Providence Hosp. & Med. Ctrs., Inc., 561 F.3d 573, 582 (6th Cir. 2009), cert. denied, Providence Hosp. v.
Moses, 2010 U.S. LEXIS 5301 (June 28, 2010).
41 Id. at 583.
42 Id.
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The defendant hospital in Moses petitioned the Supreme Court for review, but the Court declined
to hear the case.43 This would appear to indicate that a split of circuit authority remains with
respect to EMTALA’s application to admitted persons. However, it should be noted that the Sixth
Circuit’s decision in Moses also relied on the fact that the underlying hospital visit occurred in
2002 before CMS had promulgated its regulations on inpatient status. Additionally, the Court
noted that CMS’s regulations did not expressly indicate an intent to apply retroactively.
Furthermore, presuming retroactive application would have adversely affected the patient’s
expectations at the time care was sought, based on the Sixth Circuit’s earlier decision in
Thornton. Because of these considerations, the Sixth Circuit held, in the alternative, that even if
CMS’s interpretation of the statute was entitled to deference in prospective cases, it should not be
given retroactive effect to the specific facts before it.44 However, despite these alternative
grounds, at least one federal district court in the Sixth Circuit has cited Moses for the proposition
that “EMTALA imposes an obligation on a hospital beyond simply admitting a patient with an
emergency medical condition to an inpatient care unit.”45
Stabilization of Known Emergency Conditions
The stabilization requirement may preempt certain state laws authorizing physicians to decline
administering treatment where deemed inappropriate based upon their medical judgment. In In re
Baby K
, a hospital sought a declaratory judgment that they were permitted to refuse to treat an
anencephalic infant in respiratory distress.46 The hospital argued that the prevailing standard of
care for anencephalic infants was to provide warmth and nutrition without mechanical respiration,
and that Virginia state law authorized physicians to refuse to provide care they believed would be
inappropriate.47 The Fourth Circuit disagreed and held that the requirement of stabilization prior
to transfer or discharge was compulsory once an emergency medical condition had been
identified by hospital personnel, even where the treating physician believed stabilization
treatment would have been futile. Furthermore, the court held that EMTALA preempted the
Virginia statute authorizing the physician to refuse to provide treatment he reasonably believed to
be inappropriate.48
Requirements for Transfers After Stabilization
All transfers must be conducted with qualified personnel and equipment. An individual may not
be transferred unless the receiving hospital consents to receive the individual. The receiving
hospital must have the capacity and expertise to treat the transferred individual, and all medical
records must be sent to the receiving hospital. It is the transferring hospital’s obligation to ensure
that the transfer has been performed as described above and the transferring hospital remains

43 Providence Hosp. v. Moses, 2010 U.S. LEXIS 5301 (June 28, 2010) (denying certiorari).
44 Moses v. Providence Hosp. & Med. Ctrs., Inc., 561 F.3d at 583-584.
45 Lilly v. Harper Hosp. Assocs., 2009 U.S. Dist. LEXIS 121405 ( E.D. Mich. Dec. 3, 2009) (finding that defendant
hospital did not violate EMTALA where patient was admitted for treatment and subsequently died at the hospital).
46 In re Baby K, 16 F.3d 590 (4th Cir. 1994).
47 Id. at 596-7.
48 Id. EMTALA explicitly preempts any state laws that directly conflict with EMTALA’s provisions. 42 U.S.C. §
1395dd(f). The Fourth Circuit later clarified Baby K’s holding in Bryan v. Univ. of Virginia, ruling that EMTALA only
mandates treating a patient’s emergency medical condition, not the patient’s general medical condition. Bryan v. Univ.
of Virginia, 95 F.3d at 352. Therefore, had the hospital admitted Baby K after stabilizing her emergency respiratory
distress, it would not have been required to then treat her underlying anencephaly beyond warmth and nutrition. Id.
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liable under EMTALA until an appropriate transfer is completed.49 It is not a violation of
EMTALA to transfer an individual who has not been stabilized when it is medically necessary to
do so. In such situations, a qualified medical person, as defined by the hospital’s own rules and
regulations, must certify that the benefits of transfer to a different facility outweigh the risks
involved.50
Hospital Liability to Third Parties
EMTALA provides a civil remedy to “any individual who suffers personal harm as a direct result
of a participating hospital’s violation.” In 2009, the Sixth Circuit held that this language provided
a civil remedy to third parties that were injured as a direct result of a violation of either the
screening or stabilization requirements.51 In the case before the court, the hospital was alleged to
have improperly discharged an emergency room patient who was psychiatrically unstable. Ten
days after his discharge the patient murdered his wife. The wife’s estate subsequently brought suit
against the hospital alleging that the hospital’s failure to stabilize before discharge was a direct
cause of her death. The defendants argued that the patient’s wife lacked standing under EMTALA
because it only permitted civil claims by persons that were personally denied treatment in
violation of the statute. In support of this argument, the defendants noted that, during
consideration of EMTALA, the House Judiciary Committee had issued a report stating
[The civil suit provision of EMTALA] authorizes only two types of actions for damages. The
first of these could be brought by the individual patient who suffers harm as a direct result of
[a] hospital’s failure to appropriately screen, stabilize, or properly transfer that patient. The
second type of action could be brought by a medical facility which received an improperly
transferred emergency patient.52
Because third parties were not mentioned in the legislative history, the defendants argued that this
suit should not be permitted. The Sixth Circuit disagreed, noting that
where a House committee’s explanation of the meaning of a statute seems to differ from the
statute’s actual wording, this Court should not rely on that committee’s statement as the
exclusive explanation for the meaning of the statute.... We recognize that our interpretation
of the civil enforcement provision may have consequences for hospitals that Congress may
or may not have considered or intended. However, our duty is only to read the statute as it is
written.53
In the court’s view, the statutory text afforded a civil remedy to “any individual who suffers
personal harm as a direct result” of the hospital’s actions, and the most logical reading of this text
permits suits to be brought by harmed third parties.54


49 42 C.F.R. § 489.24(e)(2).
50 42 C.F.R. § 489.24(e)(1)(ii)(B).
51 Moses v. Providence Hosp. & Med. Ctrs., Inc., 561 F.3d at 579-582.
52 H.Rept. 99-241, at 6.
53 Moses, 2009 U.S. App. LEXIS 7049, at 17-19.
54 42 U.S.C. § 1395dd(d)(2)(A) (emphasis added).
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Author Contact Information
Edward C. Liu
Legislative Attorney
eliu@crs.loc.gov, 7-9166

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