.

Adam J. Fulginiti

Portrait of Adam J. Fulginiti

Adam concentrates his practice in medical malpractice and defends a variety of health care providers, including physicians and nurses, nursing homes and hospitals. He also serves as chair of the Telehealth and Telemedicine Practice Group, helping clients navigate the intersection of heath care, technology and the law. Additionally, Adam has an extensive practice in the arena of social services, where he represents foster care and adoption agencies, residential treatment facilities and community social service agencies.

Adam was selected to serve as the 2020 Board Observer for the Legal Clinic for the Disabled (LCD) as part of the Philadelphia Bar Foundation's Board Observer program. In this role, Adam attended board meetings and fundraisers and observed other events and activities of the organization. The LCD provides free, quality legal services to low income people with physical disabilities and to the deaf and hard-of-hearing in Philadelphia, Bucks, Chester Delaware and Montgomery Counties.

In May 2010, Adam received his juris doctor from the Rutgers University School of Law at Camden. While in law school, Adam worked as an associate editor for the Rutgers Journal of Law and Religion, where he published work addressing Constitutional implications for bioethical, philosophical and religious principles.   

Prior to beginning his legal career, Adam received his Bachelor's Degree in Biological Sciences from the University of Delaware, and performed clinical genetic research at the Children's Hospital of Philadelphia. During his time at CHOP, his work was published in the American Journal of Medical Genetics.

    • Rutgers Law School (J.D., 2010)
    • University of Delaware (B.A., 2007)
    • New Jersey, 2010
    • Pennsylvania, 2010
    • The Best Lawyers: Ones to Watch©, Health Care Law (2024-2025)
    • Pennsylvania Super Lawyers Rising Star (2016-2020)
    • American Bar Association
    • Pennsylvania Bar Association
    • Part of the defense team that successfully obtained a defense verdict during arbitration in a medical malpractice case. Our client performed major reconstructive surgery for a patient with a highly complex and longstanding history of severe right foot problems. The plaintiffs alleged that our client failed to properly evaluate the patient and perform the surgery at issue, causing complications that required three additional surgeries to correct. We argued that the plaintiff's postoperative course, including the clinical manifestations that developed and the subsequent surgeries he received, constituted a series of known complications/outcomes regarding the complex surgery he underwent. An arbitration verdict was made in favor of our client.
    • Successfully defended a long-term care facility in a nursing home malpractice matter, which involved claims of vicarious as well as corporate liability. After leveraging the case into binding arbitration, Adam obtained a complete defense verdict of “no negligence” on behalf of the facility and its corporate affiliates. 
    • Obtained a dismissal in a nursing home malpractice case. After removing the case to federal court, the EDPA judge granted the motion to dismiss the case on all counts, with prejudice. 
    •  Issues Impacting Telemedicine and Healthcare Claims, client webinar, December 17, 2024
    • What Claims and Telemedicine Professionals Should Know About the COVID-19 Public Health Emergency Transition, AM Best Insurance Law Podcast, March 23, 2023
    • Telehealth Providers and Controlled Substances: Navigating the Challenges of Telehealth Prescribing, Strafford webinar, August 10, 2022
    • Taking the Telemedicine Time-Out, Philadelphia Area Society of Healthcare Risk Management (PASHRM) webinar, May 13, 2022
    • Telemedicine Takeaways for 2022, Marshall Dennehey Trends in Health Care and Health Law Seminar, May 5, 2022
    • Staying Ahead of the Curve with Telehealth and Risk Mitigation: Navigating Legal Pitfalls in a Rapidly Expanding Industry, webinar, November 4, 2021
    • Charting the Course of Telehealth in the Post-COVID Landscape, ASHRM Webinar Series, April 27, 2021
    • Telehealth Emerging Legal and Regulatory Issues: Adopting and Implementing Innovative Solutions, Strafford webinar, November 5, 2020
    • Telehealth Update: Information and Best Practices to Protect Patients and Clinicians, webinar for Pennsylvania Association for Healthcare Risk Management 2020 Annual Fall Conference, September 11, 2020
    • Telehealth and Documentation in the Time of COVID-19: Information and Best Practices to Protect Patients and Clinicians webinar, April 23 and May 14, 2020 
    • Navigating Mental Health Issues in Professional Liability Litigation: Privacy, Privileges and Protections, Marshall Dennehey Health Care and Health Law Seminar, November 7, 2019
    • Recent Trends in Pennsylvania Medical Malpractice Litigation, Philadelphia Area Society for Healthcare Risk Management (PASHRM) monthly educational meeting, May 24, 2018

Results

Thought Leadership

The Quarterly Dose

Managing Risks in ER Psychiatric and Behavioral Health Treatment

May 1, 2024

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.

Telemedicine Consequences Resulting from the End of the COVID-19 Public Health Emergency on May 11, 2023

February 9, 2023

On January 30, 2023, the White House issued a statement that the Biden Administration will end the COVID-19 public health emergency on May 11, 2023. President Biden confirmed this event during the February 7, 2023, State of the Union Address. Consequently, this will impact flexibilities created to expand access to telemedicine during the COVID-19 public health emergency, with some going away, and others continuing on a permanent or semi-permanent basis. The upcoming transition period requires health care providers and health care plans to assess current telehealth practices, identify how standards are changing, and determine how to make the necessary adjustments within the immediate future. Extension of Waivers Through the Consolidated Appropriations Act The Consolidated Appropriations Act of 2023 continues many telehealth-related flexibilities for Medicare patients. Some of these flexibilities will be extended on a permanent basis and some on a temporary basis. Key permanent changes under the Consolidated Appropriations Act will include: Federally Qualified Health Centers and Rural Health Clinics may serve as a distant site provider for behavioral/mental telehealth services. There will be no geographic restrictions applicable to the originating site for behavioral/mental telehealth services. Medicare patients may, therefore, continue to receive behavioral/mental telehealth services in their home. Rural hospital emergency departments will also be accepted as an originating site. Behavioral/mental telehealth services may be delivered using audio-only communication platforms. On the other hand, temporary changes, i.e., those extended through December 31, 2024, will include the following: Medicare patients may, in their home, receive telehealth services authorized in the Calendar Year 2023 Medicare Physician Fee Schedule. An in-person visit within six months of an initial behavioral/mental telehealth service will not be required. Telehealth services may be provided by a physical therapist, an occupational therapist, a speech language pathologist, or an audiologist. Increased Scrutiny of Telemedicine Practices to Ensure HIPAA-Compliance The U.S. Department of Health and Human Services Office for Civil Rights confirmed that it will roll back the HIPAA telehealth flexibilities established in the March 17, 2020, Notice of Enforcement Discretion. Following the conclusion of the COVID-19 public health emergency, the OCR will continue flexibilities for health care providers and health plans utilizing remote communication technologies for audio-only telehealth. For the most part, however, covered entities will be expected to return to pre-COVID-19 privacy measures related to telehealth use. This will require ensuring that telemedicine platforms are HIPAA-compliant, that telehealth practices meet the needs of disabled/non-English speaking patients, and that business associate agreements are in place with telemedicine platforms utilized by the covered entity. Nondiscrimination in Telehealth The Department of Health & Human Services Office for Civil Rights, along with the Department of Justice Civil Rights Division, issued guidance mandating that covered entities ensure that telemedicine practices provide accessibility to individuals with disabilities, and to Limited English Proficient (LEP) persons. Covered entities are expected to comport with this mandate, unless doing so would result in an undue financial or administrative burden, or a fundamental alteration of the health program. Covered entities must implement telemedicine practices that accommodate individuals who are disabled, including visually-impaired and hearing-impaired patients. Covered entities must also have HIPAA-compliant systems in place to secure interpreters for LEP persons. Conclusion The coming weeks require covered entities to assess PHE-related adjustments to telemedicine practices and to determine whether those adjustments will be permissible as the United States transitions out of the COVID-19 public health emergency. The failure to do so in the immediate timeframe may put covered entities at risk in the event that certain practices, once afforded during the COVID-19 public health emergency, are no longer permitted.   Legal Update for Telehealth and Telemedicine, February 9, 2023, is prepared by Marshall Dennehey to provide information on recent legal developments of interest to our readers. This publication is not intended to provide legal advice for a specific situation or to create an attorney-client relationship. We would be pleased to provide such legal assistance as you require on these and other subjects when called upon. ATTORNEY ADVERTISING pursuant to New York RPC 7.1 Copyright © 2023 Marshall Dennehey, all rights reserved. No part of this publication may be reprinted without the express written permission of our firm. For reprints or inquiries, or if you wish to be removed from this mailing list, contact tamontemuro@mdwcg.com.

Firm Highlights

Thought Leadership

Pennsylvania Supreme Court to Review Whether Legal Malpractice Claims May Be Recast as Breach of Contract Claims

The Pennsylvania Supreme Court recently granted allowance of appeal to consider whether a plaintiff may pursue a breach of contract claim against an attorney based on allegations that the attorney failed to provide competent legal services. The issue is significant in professional liability litigation because it concerns whether a plaintiff may avoid the statute of limitations applicable to professional negligence claims by characterizing the alleged misconduct as a breach of contract. Antoine Poteat retained attorneys Gary Asteak and Nino V. Tinari to represent him in a criminal matter. After his conviction was subsequently overturned through a Post Conviction Relief Act proceeding, Poteat filed suit against his former attorneys alleging that they breached their retainer agreements by failing to provide competent legal services. The attorneys argued that the claims sounded in professional negligence, rather than breach of contract, and were therefore time-barred. The trial court dismissed Poteat’s complaint, but the Superior Court, sitting en banc, reversed. The Superior Court held that the gist-of-the-action doctrine did not bar Poteat’s breach of contract claim because the alleged failure to provide competent legal services could constitute a breach of the parties’ agreement. The Court further held that a legal-services agreement contains an implied duty requiring an attorney to provide competent legal services, even where the agreement does not contain an express provision requiring such services. The Pennsylvania Supreme Court granted review in July 2026 and will consider whether the Superior Court’s decision conflicts with Pennsylvania precedent distinguishing contract and tort claims, including Bruno v. Erie Insurance Co. The Supreme Court will also address whether a plaintiff may maintain a breach of contract claim based on an implied duty to provide competent legal services without identifying a specific contractual provision that was breached. The Supreme Court’s decision could have significant implications for professional liability litigation in Pennsylvania, particularly where plaintiffs seek to characterize claims arising from alleged professional negligence as contractual claims.

Thought Leadership

Two Tracks, No Preclusion: Ohio Supreme Court Preserves Separate Damages Claims After Chapter 2506 Appeals

The Supreme Court of Ohio has clarified that an administrative appeal under Ohio Revised Code Chapter 2506 does not bar a separate action for damages and declaratory relief that could not have been pursued in the administrative appeal. The Ohio Supreme Court considered Sheetz, Inc. v. Centerville (2026-Ohio-3531) as a result of a certified question from the Southern District of Ohio. The question was whether Sheetz, the gas station/convenience store brand, was barred from seeking damages in a separate action since damages were not sought in their administrative appeal. Ultimately, the Ohio Supreme Court ruled that res judicata does not bar a separate action for damages after ruling on an administrative appeal because R.C. Chapter 2506 is limited to judicial review and cannot grant affirmative relief. The case arose after Centerville’s city council rejected a site plan proposed by Sheetz, Inc. that had received unanimous approval from the City’s planning commission. Sheetz filed an administrative appeal pursuant to R.C. 2506 in the Montgomery County Court of Common Pleas, and two months later filed a complaint for damages and declaratory relief under 42 USC § 1983 as a takings action with the city, city council, and other objectors as improper takings and a violation of due process, as well as interference with business and contractual relationship. The city and city council removed the § 1983 action for damages to federal court. Montgomery County Court of Common Pleas reversed the city council’s denial, and allowed the Sheetz project to move forward. Upon that ruling, the federal court issued a show-cause order questioning whether the § 1983 action was barred by the doctrine of res judicata via claim preclusion (which includes all theories of recovery).  Sheetz argued that Ohio courts of common pleas do not have authority to award damages or declaratory relief as party of the R.C. Ch. 2506 appeal, therefore res judicata could not be triggered to apply to the § 1983 action. Additionally, Sheetz moved to certify the issue to the Ohio Supreme Court, citing differing results between the second and sixth districts on this same issue. Centerville approached the question, not from a claim preclusion standpoint, but from the holding in Grava v. Parkman, Twp which states that a final judgment rendered on the merits bars all subsequent action based on the same transaction or occurrence.  In yet another approach, an objector argued that claim preclusion was satisfied because Sheetz could have raised its damages claims in the administrative appeal – Sheetz disagrees. In their analysis, the Supreme Court of Ohio broke down the elements of a claim preclusion analysis: 1) a prior final, valid decision on the merits by a court of competent jurisdiction; (2) a second action involving the same parties, or their privies, as the first; (3) a second action raising claims that were or could have been litigated in the first action; and (4) a second action arising out of the transaction or occurrence that was the subject matter of the previous action. The Court held that R.C. Ch. 2506 does not permit a party to argue damages as R.C. Ch. 2506 limits the common pleas jurisdiction as if it were sitting on appeal, and therefore can only affirm, reverse, vacate, or modify the appealed order, or can remand the case to the administrative body. Further, the Court held that Grava’s conclusion that a final judgment precludes additional litigation for different relief is inapplicable under this fact pattern because it was meant only to apply to those matters in which the plaintiff brings the exact same case twice, but for new relief. The Court found Grava was inapplicable because Sheetz could have requested damages or declaratory relief in the R.C. 2506 appeal. Therefore, Grava would be nothing more than dicta if it even did apply. Going further, the Ohio Supreme Court disavowed Sixth Circuit precedent which, in reliance on Grava and other district court decisions, permitted an owner to seeking relief under 42 U.S.C. § 1983 alongside an administrative appeal. See Moore v Hiram Twp., 988 F.3d 353 (6th Cir.2021). The Ohio Supreme Court found that the Sixth Circuit had disregarded a critical decision in Community Concerned Citizens, Inc. v. Union Twp. Bd. of Zoning Appeals, 1993-Ohio-115, which clearly held that a R.C. Ch. 2506 appeal cannot be combined with a complaint seeking other claims for relief. Id. at ¶ 11. To that end, the Ohio Supreme Court has determined that the decisions Moore relied on (outside of Grava) are no longer good law, and that Moore was wrongly decided. The decision draws a clear procedural boundary: Chapter 2506 provides judicial review of an administrative decision, not a forum for independent claims seeking affirmative relief. Although Grava may place claims arising from a single transaction within the potential scope of claim preclusion, those claims are not barred unless the complete claim-preclusion test is satisfied. Because Sheetz could not have pursued damages or declaratory relief in its Chapter 2506 appeal, the separate action was not precluded. The remaining question for practitioners looking to apply or defend against this exception is when does the statute of limitations begin to run on damages and declaratory relief claims related to an administrative decision on appeal? A takings action in federal court has a 2-year statute of limitations, or as a state claim, 4 years (like the other tortious claims raised therein). Correlating this case with others, an administrative appeal will not likely toll the statute of limitations on claims based on a final decision by a municipal authority. Therefore, practitioners should look for these cases to be brought simultaneously.

Thought Leadership

The Search-Incident-to-Arrest Doctrine Does Not License Strip Searches

In Beatty v. Gardner, No. 25-2860 (3d Cir. Sept. 16, 2026), Kyle Beatty sued police officers Clinton Gardner and Calvin Irvin under 42 U.S.C. § 1983 after they stopped, arrested, and searched him three times during a drug investigation in Williamsport, Pennsylvania. The officers initially smelled marijuana coming from the car in which Beatty was sitting and observed marijuana residue, giving them probable cause to arrest him. Beatty consented to the first pat-down, and the second search was conducted incident to his lawful arrest; neither search uncovered weapons or contraband. The officers then transported Beatty to the police station solely to strip-search him, but the strip search also revealed nothing. The District Court granted the officers summary judgment, concluding that the initial stop, arrest, and first two searches were reasonable and that qualified immunity protected the officers from liability for the strip search. The Third Circuit affirmed, but held that the strip search itself violated the Fourth Amendment. The court concluded that the search-incident-to-arrest doctrine does not automatically permit officers to strip-search an arrestee outside the jail or prison setting. Because strip searches are highly intrusive and the traditional justifications for searches incident to arrest (officer safety and preservation of evidence) did not justify the search of Beatty, the officers generally needed either the arrestee’s consent, exigent circumstances, or a warrant supported by probable cause to believe that a search beneath the clothing would reveal weapons, contraband, or evidence. Here, the officers had none of those justifications. Nevertheless, the court held that qualified immunity barred damages liability because, at the time of the search, the right against a warrantless strip search of an arrestee outside the institutional setting was not clearly established by Supreme Court or Third Circuit precedent. The court likewise upheld qualified immunity on Beatty’s First Amendment retaliation claim and affirmed summary judgment for the officers.