.

Adam J. Fulginiti

Portrait of Adam J. Fulginiti

Adam concentrates his practice in medical malpractice and defends a variety of health care providers, including physicians and nurses, nursing homes and hospitals. He also serves as chair of the Telehealth and Telemedicine Practice Group, helping clients navigate the intersection of heath care, technology and the law. Additionally, Adam has an extensive practice in the arena of social services, where he represents foster care and adoption agencies, residential treatment facilities and community social service agencies.

Adam was selected to serve as the 2020 Board Observer for the Legal Clinic for the Disabled (LCD) as part of the Philadelphia Bar Foundation's Board Observer program. In this role, Adam attended board meetings and fundraisers and observed other events and activities of the organization. The LCD provides free, quality legal services to low income people with physical disabilities and to the deaf and hard-of-hearing in Philadelphia, Bucks, Chester Delaware and Montgomery Counties.

In May 2010, Adam received his juris doctor from the Rutgers University School of Law at Camden. While in law school, Adam worked as an associate editor for the Rutgers Journal of Law and Religion, where he published work addressing Constitutional implications for bioethical, philosophical and religious principles.   

Prior to beginning his legal career, Adam received his Bachelor's Degree in Biological Sciences from the University of Delaware, and performed clinical genetic research at the Children's Hospital of Philadelphia. During his time at CHOP, his work was published in the American Journal of Medical Genetics.

    • Rutgers Law School (J.D., 2010)
    • University of Delaware (B.A., 2007)
    • New Jersey, 2010
    • Pennsylvania, 2010
    • The Best Lawyers: Ones to Watch©, Health Care Law (2024-2025)
    • Pennsylvania Super Lawyers Rising Star (2016-2020)
    • American Bar Association
    • Pennsylvania Bar Association
    • Part of the defense team that successfully obtained a defense verdict during arbitration in a medical malpractice case. Our client performed major reconstructive surgery for a patient with a highly complex and longstanding history of severe right foot problems. The plaintiffs alleged that our client failed to properly evaluate the patient and perform the surgery at issue, causing complications that required three additional surgeries to correct. We argued that the plaintiff's postoperative course, including the clinical manifestations that developed and the subsequent surgeries he received, constituted a series of known complications/outcomes regarding the complex surgery he underwent. An arbitration verdict was made in favor of our client.
    • Successfully defended a long-term care facility in a nursing home malpractice matter, which involved claims of vicarious as well as corporate liability. After leveraging the case into binding arbitration, Adam obtained a complete defense verdict of “no negligence” on behalf of the facility and its corporate affiliates. 
    • Obtained a dismissal in a nursing home malpractice case. After removing the case to federal court, the EDPA judge granted the motion to dismiss the case on all counts, with prejudice. 
    •  Issues Impacting Telemedicine and Healthcare Claims, client webinar, December 17, 2024
    • What Claims and Telemedicine Professionals Should Know About the COVID-19 Public Health Emergency Transition, AM Best Insurance Law Podcast, March 23, 2023
    • Telehealth Providers and Controlled Substances: Navigating the Challenges of Telehealth Prescribing, Strafford webinar, August 10, 2022
    • Taking the Telemedicine Time-Out, Philadelphia Area Society of Healthcare Risk Management (PASHRM) webinar, May 13, 2022
    • Telemedicine Takeaways for 2022, Marshall Dennehey Trends in Health Care and Health Law Seminar, May 5, 2022
    • Staying Ahead of the Curve with Telehealth and Risk Mitigation: Navigating Legal Pitfalls in a Rapidly Expanding Industry, webinar, November 4, 2021
    • Charting the Course of Telehealth in the Post-COVID Landscape, ASHRM Webinar Series, April 27, 2021
    • Telehealth Emerging Legal and Regulatory Issues: Adopting and Implementing Innovative Solutions, Strafford webinar, November 5, 2020
    • Telehealth Update: Information and Best Practices to Protect Patients and Clinicians, webinar for Pennsylvania Association for Healthcare Risk Management 2020 Annual Fall Conference, September 11, 2020
    • Telehealth and Documentation in the Time of COVID-19: Information and Best Practices to Protect Patients and Clinicians webinar, April 23 and May 14, 2020 
    • Navigating Mental Health Issues in Professional Liability Litigation: Privacy, Privileges and Protections, Marshall Dennehey Health Care and Health Law Seminar, November 7, 2019
    • Recent Trends in Pennsylvania Medical Malpractice Litigation, Philadelphia Area Society for Healthcare Risk Management (PASHRM) monthly educational meeting, May 24, 2018

Results

Thought Leadership

The Quarterly Dose

Managing Risks in ER Psychiatric and Behavioral Health Treatment

May 1, 2024

As mental and behavioral health care grows more universal, and the delivery of healthcare services becomes more diverse, providers must be prepared to account for shifting landscapes regarding the standard of care. Given new trends emerging within this field, there are best practices providers can utilize to manage and mitigate risk in the emergency room setting. Vetting and Training Personnel Within the context of behavioral health emergency room treatment, vetting and training of personnel constitutes a key factor in litigation which often manifests in corporate negligence claims. Institutional providers may face exposure not only for the actions of their staff related to the patient, but also the operation of the facility itself. This includes factors such as the hiring and retaining of personnel, the adequacy of policies and procedures, adequacy of facilities and equipment, and notably, training and oversight of staff. While all licensed providers in the ER should ideally be proficient in handling behavioral health patients, treatment of these patients should be assigned to providers with relevant experience, given the unique challenges these patients present. Providers should be proficient in modalities germane to behavioral health, which include screening tools regarding depression, violent ideations, trauma, and substance abuse. They should also be competent in the performance of safety checks regarding risks for ligature, suffocation, and/or items that can be thrown, broken, or otherwise used to harm the patient or others. Proficiency should be demonstrated by physicians, nurses and other mid-level providers, as well as other “ancillary staff.” Behavioral health settings often include a safety observer and security personnel who can also be utilized in crisis cases involving agitation or risk/history of violence/self harm. Social workers and other crisis specialists may also be employed. Regardless of the role of the personnel involved, providers interacting with behavioral health patients in the ER should be proficient in observation, communication, and engagement. In addition to ensuring proper vetting and training of ER staff, documentation of these processes should be created and maintained in credentialing and/or personnel files. Examples of relevant materials include initial training/orientation, acknowledgment of receipt related to policies and procedures, and ongoing education and training.  Telemedicine in the Behavioral Health ER Logistically, telemedicine can and often is utilized to supplement staffing and maintain continuity of services. For larger institutions, daytime and evening shifts may employ in-person coverage but for overnight hours, psychiatric telemedicine services may be utilized. Smaller institutions, which typically have less access to in-person staff, may utilize psychiatric telemedicine with greater frequency. In either scenario, psychiatric telemedicine enhances the ability of healthcare institutions to service and treat a broader array of patients, irrespective of the staff physically present. While the benefits of psychiatric telemedicine may be obvious, they come at a cost, as the risks and exposure common to all telemedicine practice exist and, in fact, may be enhanced, within the setting of ER behavioral health treatment. This primarily derives from the lack of in-person contact, the quintessential element of telemedicine. Generally speaking, the inability of a provider to be physically present with a patient can impact the therapeutic dynamic. This “disconnect” between in-person care and telemedicine can be pronounced in the context of behavioral health treatment, where factors such as body language, eye contact, and other manifestations may be more difficult to appreciate. Lack of in-person contact may also impact the provider’s rapport with the patient, potentially limiting the patient’s trust. This may affect the patient’s candor with the provider, which may in turn diminish the provider’s ability to generate a properly-informed diagnosis and treatment plan. In light of these challenges, institutions should ensure telemedicine providers involved with behavioral health patients are proficient with this type of practice. Tactics such as maintaining patient engagement, conducting objective screening, and obtaining as detailed a history as possible are key to mitigating potential adverse outcomes. The institution should also maintain up-to-date telemedicine-related technology to minimize challenges associated with behavioral health telemedicine in the ER. In the event the telemedicine provider determines in-person care or admission is necessary, institutions must be prepared to handle such a recommendation, be it through on-site treatment or the facilitation of transfer to another facility. Subcontracted Services Larger healthcare institutions, especially those in an academic setting, maintain their own psychiatric medicine service, which is flush with attending physicians, fellows, residents, and other mid-level providers. Consequently, the need to subcontract outside providers to assist with behavioral health treatment in the ER is typically unnecessary. However, smaller healthcare institutions may not have access to in-house psychiatric services, or, may have limited access throughout a 24-hour time period. Smaller institutions may therefore need to subcontract with an outside psychiatric provider in order to furnish or supplement in-house psychiatric services. Additionally, the need for security services in the ER has been on the rise. In a 2022 American College of Emergency Physicians survey, 85% of those surveyed expressed that the rate of violence experienced in emergency departments has increased over the past five years. In this regard, 55% said they had been physically assaulted, almost all by patients, with a third of those resulting in injuries. Notwithstanding the societal stigma imposed upon psychiatric patients and those struggling with addiction, these same physicians reported that psychiatric patients, along with those seeking drugs or under the influence of drugs or alcohol, comprised over 80% of the assaults experienced. Given the increasing risk that ER providers face, institutions may opt to retain and/ or increase their security staff and technology, often through subcontracting with a third party. The importance of delineating parameters of the subcontractor relationship, particularly responsibility for certain tasks, is key. To the extent such companies are enlisted to provide services, institutions should understand what services these entities are obliged to perform and what they are not. This typically can be addressed through service agreements or similar contracts, which provide guidance regarding the apportionment of responsibilities. Within these contracts, indemnity provisions are critical to identifying exposure in the event of an adverse outcome and potential litigation. For example, when contracting with an outside provider to provide in-house psychiatry services, the parties must have a clear understanding of their respective roles in the hiring, orientation and training, credentialing, supervision, and control over the provider. The contract should clearly layout each party’s responsibilities. Such contracts typically require outside vendors to hire the provider and to ensure they are qualified for the proposed role in the ER. At the same time, the contract may significantly limit the vendor’s role regarding supervision/control over the care furnished by the provider. The hospital typically has responsibility for the orientation and credentialing of the provider, as well as supervision of their work pursuant to hospital/ER policies and procedures. The contract should address other issues such as scheduling, disciplinary action, removal or termination of the provider, and, of course, indemnity and contribution. For security staff, many of the same issues exist. There must be a clear delineation of responsibility for vetting and hiring the security staff, and responsibility for ensuring they are qualified and receive the proper and necessary training. The ability to discipline and/or terminate security staff should also be clearly stated. As for behavioral health, depending on the ratio of behavioral health patients in the ER, a healthcare provider should consider providing security staff with advanced training on how to manage patients with behavioral health issues, including those actively in crisis. Either way, the ER should have a sufficient number of properly trained security staff present at all hours to effectively manage a typical shift’s behavioral health caseload. Crisis Management and Facilities Behavioral health patients come with their own unique challenges, especially those who present to the ER in active crisis. Proper screening and assessment of patients in crisis is necessary to not only protect the patient and provide them with the proper treatment, but also to protect others. In addition to vetting and training personnel, the use of telemedicine, and the decision to subcontract certain functions, the ER must have comprehensive policies and procedures regarding provision of care to behavioral health patients. For patients in crisis, policies and procedures should include where the crisis patient should be located in the ER, the protocol for monitoring/surveillance, and the protocol for security (often dependent on the presence, or lack thereof, of a history of violence or indication of potential violence). If possible, a specific number of treatment rooms should be set up for patients in crisis, with all potentially harmful objects removed from the room. These rooms should be located in an area of the ER where security can be effectively provided and which do not allow easy access to exit points. Consideration should be given to security cameras to assist with monitoring, as surveillance footage may be pertinent in the event of an incident and potential, future litigation. If there are crisis intervention specialists in the ER, these specialists must be able to appropriately monitor and access patients in order to facilitate safety and treatment needs. If specific rooms cannot be designated for crisis patients, then the ER should have a plan for what to do when a crisis patient arrives in the building. This includes accounting for where patients are screened and assessed, where they are located, how they are monitored, how to make their environment safe and keep them safe, and how to protect the safety of others.  Reprinted with permission from the April 23, 2024, issue of the The Legal Intelligencer © 2024 ALM Media Properties, LLC. Further duplication without permission is prohibited. All rights reserved.    The Quarterly Dose – April 2024, has been prepared for our readers by Marshall Dennehey. It is solely intended to provide information on recent legal developments and is not intended to provide legal advice for a specific situation or to create an attorney-client relationship. We welcome the opportunity to provide such legal assistance as you require on this and other subjects. If you receive the alerts in error, please send a note to tamontemuro@mdwcg.com. ATTORNEY ADVERTISING pursuant to New York RPC 7.1. © 2024 Marshall Dennehey. All Rights Reserved.

Telemedicine Consequences Resulting from the End of the COVID-19 Public Health Emergency on May 11, 2023

February 9, 2023

On January 30, 2023, the White House issued a statement that the Biden Administration will end the COVID-19 public health emergency on May 11, 2023. President Biden confirmed this event during the February 7, 2023, State of the Union Address. Consequently, this will impact flexibilities created to expand access to telemedicine during the COVID-19 public health emergency, with some going away, and others continuing on a permanent or semi-permanent basis. The upcoming transition period requires health care providers and health care plans to assess current telehealth practices, identify how standards are changing, and determine how to make the necessary adjustments within the immediate future. Extension of Waivers Through the Consolidated Appropriations Act The Consolidated Appropriations Act of 2023 continues many telehealth-related flexibilities for Medicare patients. Some of these flexibilities will be extended on a permanent basis and some on a temporary basis. Key permanent changes under the Consolidated Appropriations Act will include: Federally Qualified Health Centers and Rural Health Clinics may serve as a distant site provider for behavioral/mental telehealth services. There will be no geographic restrictions applicable to the originating site for behavioral/mental telehealth services. Medicare patients may, therefore, continue to receive behavioral/mental telehealth services in their home. Rural hospital emergency departments will also be accepted as an originating site. Behavioral/mental telehealth services may be delivered using audio-only communication platforms. On the other hand, temporary changes, i.e., those extended through December 31, 2024, will include the following: Medicare patients may, in their home, receive telehealth services authorized in the Calendar Year 2023 Medicare Physician Fee Schedule. An in-person visit within six months of an initial behavioral/mental telehealth service will not be required. Telehealth services may be provided by a physical therapist, an occupational therapist, a speech language pathologist, or an audiologist. Increased Scrutiny of Telemedicine Practices to Ensure HIPAA-Compliance The U.S. Department of Health and Human Services Office for Civil Rights confirmed that it will roll back the HIPAA telehealth flexibilities established in the March 17, 2020, Notice of Enforcement Discretion. Following the conclusion of the COVID-19 public health emergency, the OCR will continue flexibilities for health care providers and health plans utilizing remote communication technologies for audio-only telehealth. For the most part, however, covered entities will be expected to return to pre-COVID-19 privacy measures related to telehealth use. This will require ensuring that telemedicine platforms are HIPAA-compliant, that telehealth practices meet the needs of disabled/non-English speaking patients, and that business associate agreements are in place with telemedicine platforms utilized by the covered entity. Nondiscrimination in Telehealth The Department of Health & Human Services Office for Civil Rights, along with the Department of Justice Civil Rights Division, issued guidance mandating that covered entities ensure that telemedicine practices provide accessibility to individuals with disabilities, and to Limited English Proficient (LEP) persons. Covered entities are expected to comport with this mandate, unless doing so would result in an undue financial or administrative burden, or a fundamental alteration of the health program. Covered entities must implement telemedicine practices that accommodate individuals who are disabled, including visually-impaired and hearing-impaired patients. Covered entities must also have HIPAA-compliant systems in place to secure interpreters for LEP persons. Conclusion The coming weeks require covered entities to assess PHE-related adjustments to telemedicine practices and to determine whether those adjustments will be permissible as the United States transitions out of the COVID-19 public health emergency. The failure to do so in the immediate timeframe may put covered entities at risk in the event that certain practices, once afforded during the COVID-19 public health emergency, are no longer permitted.   Legal Update for Telehealth and Telemedicine, February 9, 2023, is prepared by Marshall Dennehey to provide information on recent legal developments of interest to our readers. This publication is not intended to provide legal advice for a specific situation or to create an attorney-client relationship. We would be pleased to provide such legal assistance as you require on these and other subjects when called upon. ATTORNEY ADVERTISING pursuant to New York RPC 7.1 Copyright © 2023 Marshall Dennehey, all rights reserved. No part of this publication may be reprinted without the express written permission of our firm. For reprints or inquiries, or if you wish to be removed from this mailing list, contact tamontemuro@mdwcg.com.

Firm Highlights

Thought Leadership

The Tolling Trap: Filing Alone Will Not Toll the Statute Without Good-Faith Service

The Eastern District of Pennsylvania recently reinforced a critical limitation on bad faith claims, holding that a timely filing alone will not preserve a cause of action absent a good-faith effort to serve the original process. The plaintiff had presented a claim for underinsured motorist benefits to his auto insurer. The insurer evaluated the claim and determined that the plaintiff’s accident-related damages did not exceed the bodily injury liability insurance limits of the at-fault driver and denied his claim. Among other claims, the plaintiff sought to present a claim for insurance bad faith under 42 Pa. C.S.A. § 8371, to which a two year statute of limitation applies. He first filed a praecipe for writ of summons before the expiration of the statute of limitation. However, the plaintiff did not attempt to serve the praecipe or writ until after the statute of limitations had expired. Additionally, the service failed as the plaintiff had mailed the original process to an incorrect address. Despite receipt of the Postal Service’s failure to deliver the original process, the plaintiff did not attempt to re-serve the writ. Two months later, the plaintiff filed a complaint and then successfully served that complaint. The insurer sought to dismiss the plaintiff’s bad faith claim as time-barred by the statute of limitations. The district court agreed. Though the plaintiff had filed a praecipe for a writ of summons prior to the expiration of the statute of limitations, the statute is only tolled if there is a good faith effort to serve that original process. In this case, the court determined that the plaintiff had failed to perform a “good faith effort to serve the original process”. Additionally, though the filing and service of a complaint can serve as alternative original process when the lawsuit is commenced by the filing of a praecipe for a writ of summons, the plaintiff filed his complaint after the statute of limitations had expired. The plaintiff’s bad faith claim was therefore determined to be barred by the statute of limitations and dismissed by the court, with prejudice. A key takeaway for the defense is not to assume that the statute of limitations has been successfully tolled by a plaintiff merely because a praecipe for a writ of summons or complaint has been filed prior to the expiration of the statute. A filed complaint or writ is only part of the equation. The defense should carefully review the docket and filings to confirm that the plaintiff also performed the requisite good faith effort to serve that original process. A thorough review of the docket may reveal that the plaintiff failed to make the good-faith service efforts necessary to toll the statute of limitations.

Thought Leadership

Florida Supreme Court Rules Florida Statute §627.70152 Does not Apply Retroactively

In a decision that resolves years of appellate uncertainty and confirms that insurers and insureds alike can rely on the legal framework in place when a policy is issued, the Supreme Court of Florida last week found that Florida Statute §627.70152, which involves an insured’s requirement to provide an insurer with pre-suit notice before filing a suit, cannot be applied retroactively. In Universal Property & Casualty Insurance Company v. Hughes, the Court was presented with the issue of whether the statutory pre-suit notice requirement applied retroactively and whether it would apply to a breach of contract of an insurance policy that was issued before the statute went into effect. Before the Court was an appeal from a homeowner, Ms. Hughes, who sued her insurance carrier, Universal Property & Casualty Insurance Company (Universal) for breach of contract under an insurance policy that was in effect from April 24, 2019 through April 24, 2020. During the policy period, Ms. Hughes suffered a loss and, on May 29, 2019, made a claim for water damage. The carrier investigated the loss and issued payment; Ms. Hughes disputed the payment, finding the amount insufficient for repairs. On July 1, 2021, Florida Statute §627.70152 went into effect, which required insureds to provide notice of intent to initiate litigation against the carrier prior to filing a lawsuit; if an insured filed the lawsuit without complying with §627.70152, a court must dismiss the case without prejudice. On August 4, 2021, Ms. Hughes filed her lawsuit against Universal for breach of contract. Universal moved to dismiss based on her failure to comply with §627.70152. Ms. Hughes contended the notice requirement could not be applied retroactively. The trial court disagreed and dismissed the lawsuit without prejudice, and Ms. Hughes appealed. During the appeal, the Fourth District Court of Appeal, in Cole v. Universal Property & Casualty, 363 So. 3d 1089 (Fla. 4th DCA 2023), ruled that Florida Statute §627.70152 did apply retroactively to policies issued before the effective date of §627.70152. However, the Sixth District Court agreed with Ms. Hughes and overturned the trial court’s ruling, finding the statute could not retroactively apply to policies issued prior to the statute effective date. Thereafter, the other district courts weighed in, with the Third District Court agreeing with the Fourth District Court, and the First, Second and Fifth District Courts agreeing with the Sixth District Court. In resolving the conflict amongst the district courts, the Supreme Court advised “as a general rule, ‘the statute in effect at the time an insurance contract is executed governs substantive issues arising in connection with that contract.’ Hassen v. State Farm Mut. Auto. Ins. Co., 674 So. 2d 106, 108 (Fla. 1996). The Court applied the two-step test when deciding whether a statute has retroactive application: “First, the Court must ascertain whether the Legislature intended for the statute to apply retroactively. Second, if such an intent is clearly expressed, the Court must determine whether retroactive application would violate any constitutional principles.” Menendez v. Progressive Exp. Ins. Co., 35 So. 3d 873, 877 (Fla. 2010). In analyzing the Legislature’s intent, the Court must determine whether the Legislature has manifested a clear command for retroactivity in the statutory text.  In review of the statutory text, the Court found nothing in the language of the statute to indicate that the phrase “all suits” was serving another purpose of expanding its reach to suits based on policies that both predate and postdate the enactment of the statute. Buis v. Universal Prop. & Cas. Ins. Co., 394 So. 3d 738, 741 (Fla. 2d DCA 2024). Further, the Court noted the statute has an effective date, which has long been considered to be evidence against retroactive application of a statute. The Court concluded that, on its face, no provision of §627.70152 speaks to application of the statute to insurance policies issued before the statute’s effective date and therefore, the Legislature did not clearly command retroactivity of the statute to include insurance policies issued prior to the enactment of the statute. The Court briefly reviewed Universal’s argument that the presuit notice requirement was procedural, not substantive, and therefore should be applied retroactively; however, the Court agreed with the Sixth District Court’s finding that, in its entirety, §627.70152 transformed an insured’s ability to sue an insurance company under a property insurance policy and an insurer’s obligations to respond to and pay insurance claims, thus making the requirement a substantive change. The Court thereby upheld the decision of the Sixth District and disapproved the decision of the Fourth District in Cole.

Thought Leadership

Commonwealth Court Reaffirms the Constitutionality of Act 111's IRE Provisions

In this case, the claimant sustained a work injury of January 6, 1994, which was acknowledged by Notice of Compensation Payable (NCP). After the claimant’s receipt of 104 weeks of temporary total disability benefits, the employer filed a Request for an Impairment Rating Examination (IRE). The IRE was performed in May 2023 and the IRE physician found that the claimant had a 5% whole person impairment, under the AMA Guides. The employer filed a Petition based on the IRE results, and the Petition was granted by the WCJ. During litigation, the claimant argued that the IRE provisions of Act 111 (Section 306(a.3) of the Act) were not applicable to her injury, since it predated June 24, 1996, the date Act 57 went into effect, and that the IRE provisions were unconstitutional. The Workers’ Compensation Judge (WCJ)) granted the Petition and the Board affirmed. On appeal to the Commonwealth Court, the claimant argued that Act 111 violated the nondelegation doctrine and that its retroactive application to the claimant’s injury was unconstitutional. The court rejected the arguments on the basis that they had already found the same arguments without merit in multiple, prior cases. The court also addressed an argument made by the claimant that Act 111 was procedurally defective under the Pennsylvania Constitution because it was only considered on two days in each House after having undergone amendments and reassignments. The court noted that the Pennsylvania Constitution requires every bill to be considered on three different days in each House. The claimant maintained that, according to the legislative history, the bill did not receive three separate days of consideration from each House when it was assigned a new bill number. The court pointed out, however, that the bill number, H.B. 1840 remained constant and was considered on three occasions by the House. Further, the court concluded that minor amendments to the bill were germane to its original subject, which was to modify the Act’s IRE process, in accordance with Protz II.