EMTALA: Testing the Good Faith Admission Requirement

The Fourth Circuit Court of Appeals' March 13, 2020 decision in Williams v. Dimension Health Corporation reintroduced scrutiny on the lesser-known mandate of The Emergency Medical Treatment and Active Labor Act (EMTALA) concerning good faith admission to the hospital. EMTALA was enacted by Congress in 1986 to prevent patient dumping by prohibiting hospitals with emergency departments from refusing to provide emergency medical treatment to patients unable to pay for treatment, and prohibiting the transfer of those patients before their emergency medical conditions are stabilized. The reach of EMTALA ends when a patient is admitted and consequently becomes an inpatient, because then the hospital believes the patient would benefit from admission, and discharge and transfer would not occur as outlined in EMTALA. This paper examines the analysis of this mandate in Williams v. Dimension Health Corporation, and closely investigates one particular aspect of it: that admission must be made in good faith; otherwise, application of EMTALA's screening and stabilization requirements has not yet terminated, and hospitals can still be found culpable.