CHA News Article

Appellate Court Upholds Conditions of Admission Form

A California appellate court has ruled that a patient has no cause of action to challenge a hospital outpatient facility fee when the patient signed the hospital’s Conditions of Admission (COA) form and the hospital made its schedule of charges available as required by state law.

In the case, Nolte v. Cedars Sinai Medical Center, the patient alleged that the hospital engaged in unfair business practices by charging a facility fee — in addition to the independent physician’s charge — without specific prior notice. The patient had signed the hospital’s COA form, which is based on CHA’s model COA form. The form stated that the physician was an independent contractor who charged separately, and that the patient agreed to pay “in accordance with the regular rates and terms of the hospital.” The trial court agreed with the hospital and dismissed the case. The patient appealed, and the appellate court upheld the dismissal.

CHA provides manuals, including model forms and handouts, to help hospitals comply with the law and protect their interests. Information about the Conditions of Admission form may be found in CHA’s Consent Manual — A Reference for Consent and Related Healthcare Law. Details about the state law requiring hospitals to make their charges publicly available may be found in CHA’s California Hospital Compliance Manual. For more information about CHA resources, or to order, visit