and what level of medical personnel will be on staff.[/SIZE][/FONT]
What level is required before you would call it a PCA and why? I see nothing in 517 that requires a doctor present to make an area a PCA. Anytime blood is collected in my area it is at least a nurse practitioner.
I am at a loss to understand why if 'psychiatric care' = health care facility, why the removal of bodily fluids would not be?
The notion that because blood can be collected anywhere has anything to do with a purpose built building is IMO ridiculous.
Advanced life support is routinely administered anywhere an ambulance goes that does not have anything what so every to do with the wiring methods used in an emergency room.
We will have to remain in disagreement, it is after all the AHJs responsibility to make these determinations.