You may be set up like an Emergency Department but you are not an emergency department. Based on your own words, you are an office.

An emergency department is clearly defined:

An emergency department is defined as an organized hospital-based facility for the provision of unscheduled episodic services to patients who present for immediate medical attention. The facility must be available 24 hours a day.

This is in your CPT manual.

In addition, Federal Law (42 CFR 489.24) makes the following requirement for an emergency department:

(1) It is licensed by the State in which it is located under applicable State law as an emergency room or emergency department;

(2) It is held out to the public (by name, posted signs, advertising, or other means) as a place that provides care for emergency medical conditions on an urgent basis without requiring a previously scheduled appointment; or

(3) During the calendar year immediately preceding the calendar year in which a determination under this section is being made, based on a representative sample of patient visits that occurred during that calendar year, it provides at least one-third of all of its outpatient visits for the treatment of emergency medical conditions on an urgent basis without requiring a previously scheduled appointment.

So, is your clinic licensed under your State Law, as an emergency department? If not, then you are not an emergency department regardless of the fact that you have ED physicians staffed and you have some emergency equipment.

I would be very careful on calling yourself an emergency department. I am sure you are aware of the EMTALA law. What will you do if you call yourself an emergency department and you are treating a severly injured patient who is unstable upon arrival. The patient remains unstable in your clinic. How do you plan on getting the patient to the hospital while the patient remains unstable? You would be in violation of EMTALA if you attempted to transfer the patient.

I have been a paramedic for the last 33 years. If I put a gurrney, an oxygen tank, a bag containing splints and dressings in the back of my station wagon and put emergency symbols on the doors and windows of my station wagon, can I call it an ambulance?

To become a specialty hospital, you would have to be licensed by the State as such, and you would be required to undergo credentialization by JCAHO.