OSHA Proposed Emergency Response Rule Comment Deadline This Monday
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The National Registry Board of Directors voted to rescind 22-Resolution-13 (the resolution on extending eligibility requirements) yesterday afternoon and will continue this conversation with national partners and key stakeholders to progress towards more inclusive solutions. Read more>
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February 14, 2022
Douglas F. Kupas, Matt Zavadsky, Brooke Burton, Shawn Baird, Jeff J. Clawson, Chip Decker, Peter Dworsky, Bruce Evans, Dave Finger, Jeffrey M. Goodloe, Brian LaCroix, Gary G. Ludwig, Michael McEvoy, David K. Tan, Kyle L. Thornton, Kevin Smith, Bryan R. Wilson
Download PDF Position Statement
The National Association of EMS Physicians and the then National Association of State EMS Directors created a position statement on emergency medical vehicle use of lights and siren in 1994 (1). This document updates and replaces this previous statement and is now a joint position statement with the Academy of International Mobile Healthcare Integration, American Ambulance Association, American College of Emergency Physicians, Center for Patient Safety, International Academies of Emergency Dispatch, International Association of EMS Chiefs, International Association of Fire Chiefs, National Association of EMS Physicians, National Association of Emergency Medical Technicians, National Association of State EMS Officials, National EMS Management Association, National EMS Quality Alliance, National Volunteer Fire Council and Paramedic Chiefs of Canada.
In 2009, there were 1,579 ambulance crash injuries (2), and most EMS vehicle crashes occur when driving with lights and siren (L&S) (3). When compared with other similar-sized vehicles, ambulance crashes are more often at intersections, more often at traffic signals, and more often with multiple injuries, including 84% involving three or more people (4).
From 1996 to 2012, there were 137 civilian fatalities and 228 civilian injuries resulting from fire service vehicle incidents and 64 civilian fatalities and 217 civilian injuries resulting from ambulance incidents. According to the
U.S. Fire Administration (USFA), 179 firefighters died as the result of vehicle crashes from 2004 to 2013 (5). The National EMS Memorial Service reports that approximately 97 EMS practitioners were killed in ambulance collisions from 1993 to 2010 in the United States (6).
Traffic-related fatality rates for law enforcement officers, firefighters, and EMS practitioners are estimated to be 2.5 to 4.8 times higher than the national average among all occupations (7). In a recent survey of 675 EMS practitioners, 7.7% reported being involved in an EMS vehicle crash, with 100% of those occurring in clear weather and while using L&S. 80% reported a broadside strike as the type of MVC (8). Additionally, one survey found estimates of approximately four “wake effect” collisions (defined as collisions caused by, but not involving the L&S operating emergency vehicle) for every crash involving an emergency vehicle (9).
For EMS, the purpose of using L&S is to improve patient outcomes by decreasing the time to care at the scene or to arrival at a hospital for additional care, but only a small percentage of medical emergencies have better outcomes from L&S use. Over a dozen studies show that the average time saved with L&S response or transport ranges from 42 seconds to 3.8 minutes. Alternatively, L&S response increases the chance of an EMS vehicle crash by 50% and almost triples the chance of crash during patient transport (11). Emergency vehicle crashes cause delays to care and injuries to patients, EMS practitioners, and the public. These crashes also increase emergency vehicle resource use through the need for additional vehicle responses, have long-lasting effects on the reputation of an emergency organization, and increases stress and anxiety among emergency services personnel.
Despite these alarming statistics, L&S continue to be used in 74% of EMS responses, and 21.6% of EMS transports, with a wide variation in L&S use among agencies and among census districts in the United States (10).
Although L&S response is currently common to medical calls, few (6.9%) of these result in a potentially lifesaving intervention by emergency practitioners (12). Some agencies have used an evidence-based or quality improvement approach to reduce their use of L&S during responses to medical calls to 20-33%, without any discernable harmful effect on patient outcome. Additionally, many EMS agencies transport very few patients to the hospital with L&S.
Emergency medical dispatch (EMD) protocols have been proven to safely and effectively categorize requests for medical response by types of call and level of medical acuity and urgency. Emergency response agencies have successfully used these EMD categorizations to prioritize the calls that justify a L&S response. Physician medical oversight, formal quality improvement programs, and collaboration with responding emergency services agencies to understand outcomes is essential to effective, safe, consistent, and high-quality EMD.
The sponsoring organizations of this statement believe that the following principles should guide L&S use during emergency vehicle response to medical calls and initiatives to safely decrease the use of L&S when appropriate:
In most settings, L&S response or transport saves less than a few minutes during an emergency medical response, and there are few time-sensitive medical emergencies where an immediate intervention or treatment in those minutes is lifesaving. These time-sensitive emergencies can usually be identified through utilization of high-quality dispatcher call prioritization using approved EMD protocols. For many medical calls, a prompt response by EMS practitioners without L&S provides high-quality patient care without the risk of L&S-related crashes. EMS care is part of the much broader spectrum of acute health care, and efficiencies in the emergency department, operative, and hospital phases of care can compensate for any minutes lost with non-L&S response or transport.
Academy of International Mobile Healthcare Integration
American Ambulance Association
American College of Emergency Physicians
Center for Patient Safety
International Academies of Emergency Dispatch
International Association of EMS Chiefs
International Association of Fire Chiefs
National Association of EMS Physicians
National Association of Emergency Medical Technicians
National Association of State EMS Officials
National EMS Management Association
National EMS Quality Alliance
National Volunteer Fire Council
Prehosp Disaster Med. 2011;26(5): 346-352.
Ann Emerg Med, 2002;40: 625-632.
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Committee on Ways and Means
U.S. House of Representatives Hearing on “America’s Mental Health Crisis”
Statement of Shawn Baird, President, American Ambulance Association
February 2, 2022
Chairman Neal, Ranking Member Brady, and members of the Committee, on behalf of the members of the American Ambulance Association (AAA), I greatly appreciate the opportunity to provide you with a written statement on America’s Mental Health Crisis. Simply put, America’s hometown heroes who provide emergency medical services and transitional care need the Congress to recognize the significant stress and trauma paramedics and emergency medical technicians (EMTs) have experienced as a result of this pandemic. The AAA urges members of Congress not to forget these heroes and to expressly include all ground ambulance service personnel in efforts to address America’s Mental Health Crisis.
Emergency medical services (EMS) professionals are ready at a moment’s notice to provide life-saving and life-sustaining treatment and medical transportation for conditions ranging from heart attack, stroke, and trauma to childbirth and overdose. These first responders proudly serve their communities with on-demand mobile healthcare around the clock. Ground ambulance service professionals have been at the forefront of our country’s response to the mental health crisis in their local communities. Often, emergency calls related to mental health services are triaged to the local ground ambulance service to address.
While paramedics and EMTs provide important emergency health care services to those individuals suffering from a mental or behavioral health crisis, these front-line workers have been struggling to access the federal assistance they need to address the mental health strain that providing 24-hour care, especially during a COVID-19 pandemic, has placed on them. We need to ensure that there is equal access to mental health funding for all EMS agencies, regardless of their form of corporate ownership so that all first responders can receive the help and support they need.
EMS’s Enhanced Role in the Pandemic
As if traditional ambulance service responsibilities were not enough, paramedics and EMTs have taken on an even greater role on the very front lines of the COVID-19 pandemic. In many areas, EMS professionals lead Coronavirus vaccination, testing, and patient navigation. As part of the federal disaster response subcontract, EMS personnel even deploy to other areas around the country to pandemic hotspots and natural disasters to bolster local healthcare resources in the face of extraordinarily challenging circumstances.
Mental & Behavioral Health Challenges Drive Staffing Shortages on the Front Line
Myriad studies show that first responders face much higher-than-average rates of post- traumatic stress disorder[1], burnout[2], and suicidal ideation[3]. These selfless professionals work in the field every day at great risk to their personal health and safety—and under extreme stress.
Ambulance service agencies and fire departments do not keep bankers’ hours. By their very nature, EMS operations do not close during pandemic lockdowns or during extreme weather emergencies. “Working from home” is not an option for paramedics and EMTs who serve at the intersection of public health and public safety. Many communities face a greater than 25% annual turnover[4] of EMS staff because of these factors. In fact, across the nation EMS agencies face a 20% staffing shortage compounded by near 20% of employees on sick leave from COVID-19. This crisis-level staffing is unsustainable and threatens the public safety net of our cities and towns.
Sadly, to date, too few resources have been allocated to support the mental and behavioral health of our hometown heroes. I write today to ask for Congressional assistance to help the helpers as they face the challenges of 2022 and beyond.
Equity for All Provider Types
Due to the inherently local nature of EMS, each American community chooses the ambulance service provider model that represents the best fit for its specific population, geography, and budget. From for-profit entities to municipally-funded fire departments to volunteer rescue squads, EMS professionals share the same duties and responsibilities regardless of their organizational tax structure. They face the same mental health challenges and should have equal access to available behavioral health programs and services.
Many current federal first responder grant programs and resources exclude the tens of thousands of paramedics and EMTs employed by for-profit entities from access. These individuals respond to the same 911 calls and provide the same interfacility mobile healthcare as their governmental brethren without receiving the same behavioral health support from
Federal agencies. To remedy this and ensure equitable mental healthcare access for all first responders, we recommend that:
The rationale for the above requests is twofold. First, ensuring the mental health and wellness of all EMS professionals—regardless of their employer’s tax status—is the right thing to do.
Second, because keeping paramedics and EMTs employed by private ambulance agencies who are on the frontlines of providing vital medical care and vaccinations during this pandemic is the smart thing to do.
Thank you for considering this request to support ALL of our nation’s frontline heroes. They are ready to answer your call for help, 24/7—two years into this devastating pandemic, will Congress answer theirs?
Please do not hesitate to contact American Ambulance Association Senior Vice President of Government Affairs, Tristan North, at tnorth@ambulance.org or 202-486-4888 should you have any questions.
Extended ambulance patient offload times (APOT), or “wall times,” at hospitals are causing long waits for 911 and interfacility patients and exacerbating the EMS workforce shortage. Ambulance services across the country are continually trying to meet demand with fewer resources; when EMS providers are kept out of service for extended periods of time because they are unable to transfer patient care at the hospital, wait times for both 911 and inter-facility patients increase and both emergency and non-emergency calls pile up.
We recognize that the issue of extended wall times is not new, but an existing problem exacerbated by the ongoing battle with COVID-19 across the country. Increased wall times are a symptom of a much larger problem for which there is no easy solution.
This toolkit will provide an overview of EMTALA, highlight the intersection between EMTALA and APOT, and address some frequently asked questions along with links to resources and examples of how services are addressing this issue across the country.
(1) Has presented at a hospital’s dedicated emergency department, as defined in this section, and requests examination or treatment for a medical condition, or has such a request made on his or her behalf. In the absence of such a request by or on behalf of the individual, a request on behalf of the individual will be considered to exist if a prudent layperson observer would believe, based on the individual’s appearance or behavior, that the individual needs examination or treatment for a medical condition;
(2) Has presented on hospital property, as defined in this section, other than the dedicated emergency department, and requests examination or treatment for what may be an emergency medical condition, or has such a request made on his or her behalf. In the absence of such a request by or on behalf of the individual, a request on behalf of the individual will be considered to exist if a prudent layperson observer would believe, based on the individual’s appearance or behavior, that the individual needs emergency examination or treatment;
(3) Is in a ground or air ambulance owned and operated by the hospital for purposes of examination and treatment for a medical condition at a hospital’s dedicated emergency department, even if the ambulance is not on hospital grounds. However, an individual in an ambulance owned and operated by the hospital is not considered to have “come to the hospital’s emergency department” if –
(i) The ambulance is operated under communitywide emergency medical service (EMS) protocols that direct it to transport the individual to a hospital other than the hospital that owns the ambulance; for example, to the closest appropriate facility. In this case, the individual is considered to have come to the emergency department of the hospital to which the individual is transported, at the time the individual is brought onto hospital property;
(ii) The ambulance is operated at the direction of a physician who is not employed or otherwise affiliated with the hospital that owns the ambulance; or
(4) Is in a ground or air nonhospital-owned ambulance on hospital property for presentation for examination and treatment for a medical condition at a hospital’s dedicated emergency department. However, an individual in a nonhospital-owned ambulance off hospital property is not considered to have come to the hospital’s emergency department, even if a member of the ambulance staff contacts the hospital by telephone or telemetry communications and informs the hospital that they want to transport the individual to the hospital for examination and treatment. The hospital may direct the ambulance to another facility if it is in “diversionary status,” that is, it does not have the staff or facilities to accept any additional emergency patients. If, however, the ambulance staff disregards the hospital’s diversion instructions and transports the individual onto hospital property, the individual is considered to have come to the emergency department.
[1] 42 CFR § 489.24(b) – Special responsibilities of Medicare hospitals in emergency cases.
Answer: No, the EMS crew is not legally required to remain with the patient until the hospital personnel take a report or take over patient care. As the EMTALA provisions above cite, the EMS crew may choose to remain with the patient but, as soon as that patient arrives on hospital property or enters the emergency department, the hospital is legally responsible for the patient.
Answer: If the patient’s condition dictates that the patient cannot be safely left alone, the crew would have an ethical obligation to continue to care for the patient until care can be safely transferred to the appropriate caregiver. The EMS crew should continue to provide patient care and should contact a supervisor or Officer in Charge (OIC) at their agency to inform them of the situation and request assistance with facilitating the transfer of care.
Answer: The EMS crew should attempt to provide a verbal report to an emergency department staff member if possible. If no one is available, or the hospital staff will not make someone available to take a verbal report, the crew should tell an ED staff member that the EMS crew will be leaving the patient, where the patient was left and the patient’s general condition. EMS providers should document how long they waited after arriving at the ED, where they left the patient, which ED staff member they notified, and the patient’s condition when they left in their patient care report. EMS providers should be sure to leave a copy of their patient care report or an abbreviated patient care report with the hospital staff or with the patient.
In some states, extended APOT may be reportable to the state-level oversight agency, such as the state EMS Office or the Department of Public Health.
If hospitals are unresponsive to the initial conversation, you could also consider escalating the issue to your State Survey Agency, the agency primarily charged with taking EMTALA complaints.
We have created a draft letter for use in communicating with your State Survey Agency; be sure to update the draft letter to include specific examples and data that illustrate the particular issues your service is facing and the steps you’ve taken to try and resolve the issue so far.
Answer: Because the legally becomes the hospital’s responsibility upon arrival on hospital property or upon arrival in the ED, it is highly unlikely that a claim of abandonment could be sustained. The most important thing EMS providers can do is to exercise reasonable care of the patient before, upon, and after arrival at the ED. EMS providers who reasonably attempt to furnish a report to the ED staff or who ensure that the patient can be safely left at the ED with either an abbreviated or full patient care report will likely be protected from liability.
Additional Resources
Best Practices for Mitigating Ambulance ED Delays webinar
California Emergency Medical Services Authority Ambulance Patient Offload Time (APOT) webpage
Statewide Method of Measuring Ambulance Patient Offload Times
State Survey Agency Directory
This is the agency primarily charged with receiving EMTALA complaints.
Wall time Collaborative a partnership to reduce ambulance patient off-load delays
presentation from 2013
EMS crews forced to wait hours to drop patients at overwhelmed hospitals
The Commission on Accreditation of Ambulance Services (CAAS) formed a Ground Vehicle Standard Revision Committee to develop V3.0 of the GVS document. Based on industry feedback, this Committee has developed a list of proposed changes to V2.0.
To ensure that anyone with an interest in the medical transportation industry has a voice in the Standard revision process, CAAS has now posted the proposed changes for public comment. These proposed changes will be posted for 60 days, commencing January 7, 2022. Interested parties who care to comment on the changes should complete the online feedback form and submit their input during this public comment period.
The GVS Committee will review all submissions received during the period and will consider each of the comments received. Following this first round review, a second 60-day public comment period will be held to give further opportunity to comment on any items that may have been changed from the first draft as part of the process. The CAAS GVS V3.0 document has a scheduled effective date of July 1, 2022.
If you have any questions, please contact Mark Van Arnam, Administrator, CAAS GVS.
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orFrom the Journal of the American College of Emergency Physicians
Emergency medical services education research priorities during COVID-19: A modified Delphi study
Rebecca E. Cash PhD, MPH, William J. Leggio EdD, Jonathan R. Powell MPA, Kim D. McKenna PhD, Paul Rosenberger EdD, Elliot Carhart EdD, Adrienne Kramer PhD, Juan A. March MD, Ashish R. Panchal MD, PhD, for the Pandemic Educational Effects Task Force
Our objective was to identify research priorities to understand the impact of COVID-19 on initial emergency medical services (EMS) education.
We used a modified Delphi method with an expert panel (n = 15) of EMS stakeholders to develop consensus on the research priorities that are most important and feasible to understand the impact of the COVID-19 pandemic on initial EMS education. Data were collected from August 2020 to February 2021 over 5 rounds (3 electronic surveys and 2 live virtual meetings). In Round 1, participants submitted research priorities over 9 specific areas. Responses were thematically analyzed to develop a list of research priorities reviewed in Round 2. In Round 3, participants rated the priorities by importance and feasibility, with a weighted score (2/3*importance+1/3*feasibility) used for preliminary prioritization. In Round 4, participants ranked the priorities. In Round 5, participants provided their agreement or disagreement with the group’s consensus of the top 8 research priorities.
During Rounds 1 and 2, 135 ideas were submitted by the panel, leading to a preliminary list of 27 research priorities after thematic analysis. The top 4 research priorities identified by the expert panel were prehospital internship access, impact of lack of field and clinical experience, student health and safety, and EMS education program availability and accessibility. Consensus was reached with 10/11 (91%) participants in Round 5 agreeing.
The identified research priorities are an important first step to begin evaluating the EMS educational infrastructure, processes, and outcomes that were affected or threatened through the pandemic.
Today, the U.S. Department of Health and Human Services (HHS), through the Health Resources and Services Administration (HRSA), announced the availability of an estimated $103 million in American Rescue Plan funding over a three-year period to reduce burnout and promote mental health among the health workforce. These investments, which take into particular consideration the needs of rural and medically underserved communities, will help health care organizations establish a culture of wellness among the health and public safety workforce and will support training efforts that build resiliency for those at the beginning of their health careers.
“The Biden-Harris Administration is committed to ensuring our frontline health care workers have access to the services they need to limit and prevent burnout, fatigue and stress during the COVID-19 pandemic and beyond,” said HHS Secretary Xavier Becerra. “It is essential that we provide behavioral health resources for our health care providers – from paraprofessionals to public safety officers – so that they can continue to deliver quality care to our most vulnerable communities.”
Health care providers face many challenges and stresses due to high patient volumes, long work hours and workplace demands. These challenges were amplified by the COVID-19 pandemic, and have had a disproportionate impact on communities of color and in rural communities. The programs announced today will support the implementation of evidence-informed strategies to help organizations and providers respond to stressful situations, endure hardships, avoid burnout and foster healthy workplace environments that promote mental health and resiliency.
“This funding will help advance HRSA’s mission of developing a health care workforce capable of meeting the critical needs of underserved populations,” said Acting HRSA Administrator Diana Espinosa. “These programs will help to combat occupational stress and depression among our health care workers as they continue their heroic work to defeat the pandemic.”
There are three funding opportunities that are now accepting applications:
To apply for the Provider Resiliency Workforce Training Notice of Funding Opportunities, visit Grants.gov. Applications are due August 30, 2021.
Learn more about HRSA’s funding opportunities.
Free Webinar July 7 | 14:00–15:15 ET
HOT (red light and siren) responses put EMS providers and the public at significant risk. Studies have demonstrated that the time saved during this mode of vehicle operation and that reducing HOT responses enhances safety of personnel, with little to no impact on patient outcomes. Some agencies have ‘dabbled’ with responding COLD (without lights and sirens) to some calls, but perhaps none as dramatic as Niagara Region EMS in Ontario, Canada – who successfully flipped their HOT responses to a mere 10% of their 911 calls! Why did they do it? How did they do it? What has been the community response? What has been the response from their workforce? Has there been any difference in patient outcomes? Join Niagara Region EMS to learn the answers to these questions and more. Panelists from co-hosting associations will participate to share their perspectives on this important EMS safety issue!
Kevin Smith, BAppB:ES, CMM III, ACP, CEMC
Chief
Niagara Emergency Medical Services
Jon R. Krohmer, MD, FACEP, FAEMS
Team Lead, COVID-19 EMS/Prehospital Team
Director, Office of EMS
National Highway Traffic Safety Administration
Douglas F. Kupas, MD, EMT-P, FAEMS, FACEP
Medical Director, NAEMT
Medical Director, Geisinger EMS
Matt Zavadsky, MS-HSA, NREMT
Chief Strategic Integration Officer
MedStar Mobile Integrated Healthcare
Bryan R. Wilson, MD, NRP, FAAEM
Assistant Professor of Emergency Medicine
St. Luke’s University Health Network
Medical Director, City of Bethlehem EMS
Robert McClintock
Director of Fire & EMS Operations
Technical Assistance and Information Resources
International Association of Fire Fighters
Mike McEvoy, PhD, NRP, RN, CCRN
Chair – EMS Section Board – International Association of Fire Chiefs
EMS Coordinator – Saratoga County, New York
Chief Medical Officer – West Crescent Fire Department
Professional Development Coordinator – Clifton Park & Halfmoon EMS
Cardiovascular ICU Nurse Clinician – Albany Medical Center
The Penn State College of Medicine is conducting a national study of social needs in EMS patients, particularly in regards to potential interventions for EMS super-utilizers (frequent flyers). The study consists of an approximately 7 minute online survey with questions about provider (911-EMT, Paramedic, EMS Physician) knowledge of social needs, recognition of patient needs, perceptions of possible interventions, and background information. Those who participate will have the option to enter into a drawing for a $50 gift card.
With the implementation of programs such as ET3, we are hoping to hear from as many EMS providers as possible to give them a voice in how to best to address social needs and EMS super-utilizers. As such, we are hoping you consider sharing our study flyer, study overview from JEMS, or the study link with your employees and/or social media.
The Centers for Medicare & Medicaid Services (CMS) has released the Physician Fee Schedule Proposed Rule for Calendar Year (CY) 2021 which has traditionally included proposed changes to the Ambulance Fee Schedule for the same year. The American Ambulance Association (AAA) has confirmed with CMS that the reason there are no references to the Ambulance Fee Schedule in the Proposed Rule is because the temporary add-ons were built into the regulations themselves. Thus, the governing regulations already indicate that the temporary add-on payments for ground ambulance transports are effective for services furnished through December 31, 2022. The regulations are at 42 CFR §414.610 (c)(1)(ii) and 42 CFR §414.610 (c)(5)(ii).
The Proposed Rule also seeks to extend or make permanent several of the telehealth waivers CMS has implemented during the public health emergency. Because CMS does not believe it has the authority to reimburse ambulance providers or suppliers for services provided without transportation also occurring, these waivers have not applied to ground ambulance. However, we will review these provisions of the rule closely to identify potential opportunities to include ground ambulance providers and suppliers in these policies.