In essence they're urgent care clinics that follow the regulations of an emergency department, and therefore are able to bill as one. The core components that

In essence they're urgent care clinics that follow the regulations of an emergency department, and therefore are able to bill as one. The core components that I'm aware of: - An urgent care clinic can be staffed with just a nurse practitioner on duty. An ER requires a full doctor on duty at all times. - An urgent care clinic can close. An ER has to be open 24 hours a day. - An urgent care clinic can decline to see patients. An ER is legally obligated to accept all patients in need of critical care, regardless of ability to pay. - In some states, a freestanding ER has to have the word 'Emergency' in it. Although that's not a requirement in every state. - In some states, a freestanding ER has to be affiliated with a fully fledged hospital. Although that's not a requirement in every state. And being affiliated with a hospital doesn't actually mean you're owned by said hospital. "Upgrading" an urgent care clinic to a freestanding ER is effectively just a logistics concern. Adjust your staffing schedule to have a doctor on duty 24 hours a day, train your front desk on a new intake process that ensures you don't accidentally turn down indigent patients you're legally obligated to see, and you're good to go. In a few states, add on the additional steps of incorporating the word Emergency into your name and possibly pay a nominal licensing fee to borrow a hospital's name for affiliation purposes. Then, it's as simple as implicitly exploiting the consumer confusion that ensues for a decade or so, until the regulatory and insurance environment (hopefully) catches up with the practice.