Recently, the Pennsylvania Department of Health (DOH) posted new guidance to its Facility Message Board (see message 12 of 15), entitled “Observation Units Outside or Adjacent to the Emergency Department 7-11-19” (posted 7/18/19) to update hospitals about a new category of beds that are available on hospital licensure applications, effective immediately.

The new category, “Hospital-Observation,” will apply to beds in observation units located outside of or adjacent to hospital emergency department beds in units that have been identified as observation units or areas of the hospital that have been designated as observation areas. Hospital-Observation beds must be licensed and comply with the guidelines of the Facility Guidelines Institute (FGI).  The DOH mandated compliance with the FGI Guidelines for construction and renovation projects at hospitals and ambulatory surgical facilities on November 1, 2018.

The DOH intends that these requirements will provide assurance that patients kept overnight for up to three days in such beds will receive the same level of care as if they were admitted to an inpatient unit.

The DOH advised that hospitals should work closely with their local Health Facility Quality Examiner Surveyor to make sure that such beds are properly classified. Observation patients outside of the emergency department (ED) must be in a licensed bed.  As further guidance, the DOH included three scenarios to illustrate the potential impact to hospitals on existing and new observation beds:

  • If a hospital was previously approved to have an observation unit outside of the ED but did not add these beds to the license, then the DOH Field Office will work with the hospital to add the beds to the hospital’s license.
  • If a hospital was previously approved to have an observation unit outside of the ED and has already added these beds to the license, then the Field Office will work with the hospital to change the bed type from Observation Unit beds to “Hospital- Observation.” There will be no charge to the facility because it had already paid for the beds.
  • If a hospital wants to create a new observation unit, either inside or outside of the ED, then it must obtain: 1) plan review approval from the DOH Division of Safety Inspection (DSI);  and 2) occupancy approval from the DSI and the DOH Division of Acute and Ambulatory Care.

The DOH clarified in the post that a hospital placing an observation patient on a floor that has licensed beds, such as a medical-surgical unit, is not required to change the bed type to Hospital-Observation on its license.

Observation Unit beds outside of the ED will be added as “Hospital-Observation” in the DOH data system and such status is already available on the facility on-line application.