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The Quarterly Dose

Managing Risks in ER Psychiatric and Behavioral Health Treatment

The Quarterly Dose - May 2024

May 1, 2024

by Adam J. Fulginiti

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.

Firm Highlights

Thought Leadership

First DCA Reverses Excessive Jury Award Unsupported by the Evidence

In December 2019, the plaintiffs filed a claim with Universal for damages caused by a water and sewage back up through the plumbing system and existing through multiple fixtures including the washing machine drain, kitchen sink, dishwasher, bathtub and toilet. Universal investigated the claim, issued payment for resulting water damage totaling $7,000.00 in actual cash value ($12,000.00 in replacement cost value). The plaintiffs sought additional benefits for work needed to access the below-slab cast iron plumbing system due to the failure of the system from rust, deterioration, corrosion and breaks in the line. Universal denied any additional benefits for access. In 2021, the plaintiffs filed suit. During litigation, Universal sent a plumber to inspect the home and the plumber concluded the pipes were clogged but could be cleaned. The plaintiffs’ plumber testified that the plumbing system needed to be replaced due to holes and openings in the pipes. The plaintiffs introduced two estimates prepared by Triad Restoration services totaling $79,680.22 in replacement cost value and $50,219.97 in actual cash value and an executed contract with another company for repairs with the amounts of repair redacted. Since the insurance policy did not provide coverage for repair or replacement of the plumbing system, the jury only had to decide whether the plumbing system needed to be replaced, and if it did, Universal would owe for the access costs; the jury verdict form required the jury to determine both the replacement cost value and actual cash value amounts. The jury asked if it had to rely on the Triad estimates for their amounts. The trial court advised the amount awarded had to be based on the evidence presented at trial and the law given by the trial court. The jury awarded $335,000.00 in replacement cost value or $305,000.00 in actual cash value. Universal motioned for a new trial arguing the amount awarded was unsupported by the evidence and then moved for remittitur. The trial court denied both motions and this appeal followed. The court found that while a jury’s verdict should only be disturbed with caution and discretion, the trial court must give the properly challenged award close scrutiny and determine whether it bears a reasonable relation to the damaged provided, is supported by the evidence, and could have been reached in a logical manner by reasonable means §768.74(3), (5)(d)-(e), Fla. Stat. The court found the trial court did consider the statutory requirements at the hearing on Universal’s remittitur motion and was concerned about a reasonable relation to the amount of damages proved and injury suffered and whether the award was supported by the evidence, but ultimately denied the motion, reasoning that the jury had been properly instructed to fairly and adequately compensate the plaintiffs. The court noted the only evidence providing the basis for the jury verdict was Triad’s estimates and those valued the plaintiffs' claimed loss at $79,680.22 in replacement cost value and $50,219.97 in actual cash value; no valuation evidence reasonably supported the jury verdict. The plaintiffs argued that the jury was entitled to consider more than the estimates, but the court conveyed the evidence provided did not give the jury a way to reach the amounts they awarded. The court was also not swayed by the plaintiffs’ argument regarding inflation and later price increases, but the court noted that no evidence via the contract, nor testimony regarding increase in labor, material, fuel or construction costs were entered into the record.  The court concluded the jury may draw reasonable inferences from the evidence, but it may not supply a damages number by speculation. The court did not find any of the plaintiffs’ remaining argument persuasive either. The court reversed the denial of Universal’s remittitur motion and motion for new trial as to damaged and remanded the case. The court ended its opinion with advising the trial court must determine whether replacement cost value or actual cash value is the property measure of damages under the policy and order remittitur in an amount consistent with that determination and the evidence.

Thought Leadership

Appeals Court Reverses Trial Court Order Awarding Attorney’s Fees Due to Lack of Evidence to Support Fee Awarded

The Fourth District Court of Appeal reversed the trial court’s order awarding appellate fees to People’s Trust Insurance Company based upon a lack of evidence to support the attorney’s fee award in RM & Assocs. Consulting, Inc. v. People's Trust Ins. Co., 2026 Fla. App. LEXIS 4654 (Fla. 4th DCA 2026). People’s Trust was the insurer of a residential property that had sustained water damage. RM & Associates Consulting was hired by the homeowner to perform mitigation services at the property. The homeowner assigned post-loss benefits to RM and RM subsequently filed suit against People’s Trust alleging that it had not been paid the money it was owed for the mitigation services. People’s Trust defended the lawsuit on the ground that the policy required the insured to notify the insurer before authorizing repairs so People's Trust could elect to use its preferred contractor. Because the owner did not comply with that provision, People's Trust asserted its liability was limited to the amount that its preferred contractor would have charged for the work, which People's Trust contended was $2,000. People's Trust paid that amount to RM before RM filed suit. People’s Trust filed a motion for summary judgment which was granted. RM appealed the summary judgment ruling and the ruling was upheld by the Fourth District Court of Appeal. The appellate court also granted People’s Trust’s entitlement to appellate attorney’s fees, subject to the trial court’s determination of the amount of fees, based upon an offer of judgment made by People's Trust. On remand, the trial court held an evidentiary hearing to determine the amount of attorney’s fees People’s Trust was entitled to. At the hearing, People’s Trust presented testimony from it’s fee expert, supervising trial counsel and appellate counsel. People’s Trust sought recovery of $24,866.17 for work performed by appellate counsel. The request primarily consisted of work performed in preparation of the answer brief. The fee expert testified that more than ninety hours spent preparing the answer brief was reasonable given the complexity and significance of the underlying issue. The appellate court found that the fee expert’s testimony fell short of meeting the necessary standard of demonstrating that the hours expended were necessary. The appellate court found that the billing records did not serve to cure the deficient testimony, as the billing records did not contain adequate details regarding the specific tasks performed. Rather the records contained entries such as “answer brief” which the appellate court found to be insufficient. The appellate court noted that neither the fee expert or counsel addressed how the prior research and briefing in the parallel litigation informed the work in the instant matter. The appellate court noted this was significant in that a court's attorney's fees award must exclude excessive, redundant, or otherwise unnecessary hours, citing Florida Patient's Compensation Fund v. Rowe, 472 So. 2d 1145 (Fla. 1985). Based upon the record failing to support the finding of the trial court, the 4th DCA remanded the case to the trial court for a reconsideration and redetermination of reasonable appellate attorney’s fees supported by competent substantial evidence. The 4th DCA reiterated that the fee expert’s focus on the quality of the work and the importance of the work to People’s Trust did not make up for the perceived deficiencies in the position that spending over ninety hours on a single answer brief was reasonable. Whether moving for attorney’s fees or challenging the amount of fees being sought by an opposing party, practitioners should be mindful of the evidence being used to support the claims being made. Parties should pay close attention to whether the hours being sought may be impacted by prior litigation either party may have engaged in. A party must be prepared to address how prior litigation efforts did or did not impact the amount of hours being claimed in current litigation. Lastly, billing records must be sufficiently detailed so as to support any potential future fee claim.

News

106 Marshall Dennehey Attorneys Recognized in the 2027 Editions of The Best Lawyers in America® and the Best Lawyers: Ones to Watch® in America

Marshall Dennehey is proud to highlight the firm’s 106 attorneys who have been recognized in the 2027 editions of The Best Lawyers in America® and the Best Lawyers: Ones to Watch® in America. Less than 6% of all practicing lawyers in the U.S. were selected by their peers for this recognition. Additionally, four of the firm’s attorneys received the Best Lawyers® 2027 “Lawyer of the Year” awards in their respective practice areas and demographic regions. Since it was first published in 1983, Best Lawyers® has become universally regarded as the definitive guide to legal excellence. Best Lawyers lists are compiled based on an exhaustive peer-review evaluation. For more information, please visit https://www.bestlawyers.com/. OUR 2027 LAWYERS OF THE YEAR Harrisburg, PA Christopher Reeser, Personal Injury Litigation - Defendants Kacey Wiedt, Workers Compensation Law - Employers Roseland, NJ Justin F. Johnson, Medical Malpractice Law - Defendants Leonard Leicht, Personal Injury Litigation - Defendants   OUR 2026 BEST LAWYERS IN AMERICA Philadelphia, PA Nicholas D. Bowers, Personal Injury Litigation - Defendants Josh J. T. Byrne, Professional Malpractice Law - Defendants Jefferey J. Chomko, Insurance Law James H. Cole, Insurance Law John J. Delany III, Personal Injury Litigation - Defendants Laurianne Falcone, Personal Injury Litigation - Defendants John P. Gonzales, Employment Law - Management John Hare, Appellate Practice Daniel D. Krebbs, Personal Injury Litigation - Defendants Michele Punturi, Workers' Compensation Law - Employers Bradley D. Remick, Product Liability Litigation - Defendants Andrea Cicero Rock, Workers' Compensation Law - Employers Robin M. Romano, Workers' Compensation Law - Employers Daniel J. Ryan, Jr., Personal Injury Litigation - Defendants Gary M. Samms, Professional Malpractice Law - Defendants Christopher N. 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Thought Leadership

United State District Court for the Middle District of Florida finds Evidence of Replacement Cost Value is Admissible and Recoverable Even When Repairs Have Not Been Made

The plaintiff filed a claim for damage as a result of Hurricane Ian. It claimed damages were over $24 million, but the carrier accepted partial coverage and paid $8,307.49 for secondary components. The carrier found hurricane damage to the building, but it was below the insurance policy’s $3.6 million deductible. The plaintiff sued for breach of the insurance policy. The carrier argued in a motion for summary judgment that plaintiff could not recover replacement cost value (RCV) because the property repairs had not been effectuated. The policy provided for RCV, but only after the repairs were completed. The carrier argued that because the repairs were not completed, the plaintiff was not entitled to RCV damages. The plaintiff argued the carrier could not withhold the actual cost value (ACV) due, which was the main allegation of the lawsuit, then fault it for not making the repairs to unlock the RCV. The United States District Court for the Middle District of Florida rejected the carrier’s argument, finding that when an insurer allegedly breached the policy by withholding coverage, it could not hide behind a repair-contingent provision to block the insured from RCV damages at trial. The court found the issue to be whether the contractual language designed to preclude certain coverage until after repairs are completed barred an insured from seeking those damages at trial when repairs were not complete. The court noted the Eleventh Circuit had not resolved this issue and neither side pointed to a definitive answer from the Florida Supreme Court. The court reasoned that it must look to the Sixth District Court of Appeal (6th DCA), which is the court which would have heard this case if it was in state court. The court noted the 6th DCA recently addressed this issue in Universal Prop. & Cas. Ins. Co. v. Rodriguez, 427 So. 3d 676 (Fla. 6th DCA 2026). The Rodriguez Court found that a breach of contract action is designed to adjudicate not only whether the contract was breached, but also evaluate the damages incurred had the breach not occurred, which the Rodriguez court found to be recovery of the RCV. This court also noted basic Florida contract principles compelled the same result, as a material breach frees the nonbreaching party to suspend its own performance and can demand the full benefit of its bargain, including RCV damages. Finally, the court found the distinction between a full denial and partial denial did not compel a different result. It found the policy required the carrier to acknowledge coverage and pay ACV for all covered damages, and the failure to do that is a material breach, entitling the insured to all of the damages available under the contract, which included the RCV.