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PPAEMA: Six Months In — What We’ve Learned

PPAEMA: Six Months In — What We’ve Learned

By Clive Savacool, Fire Chief (Ret.), EMT-P

It has been six months since the DEA’s final rule implementing the Protecting Patient Access to Emergency Medications Act (PPAEMA) took effect.

When the rule came out, there was a lot of scrambling. Agencies were trying to understand what had changed, whether they needed their own DEA registration, what their states were going to require, and what they needed to change internally. Even at LogRx, a software company founded on tracking controlled substances, we scrambled to ensure our program was compliant with the new regulations.

Six months later, some of those questions have been answered. Others haven’t.

I recently sat down with retired DEA Special Agent Dennis Wichern for a webinar looking specifically at what we’ve learned during the first six months. Dennis spent 30 years with the DEA, including serving as Special Agent in Charge of the Chicago Field Division. I’ve spent more than 30 years in fire and EMS, including as both a paramedic and a fire chief, so we come at this from two very different directions.

PPAEMA isn’t about changing the way paramedics practice medicine. It’s about accountability. To put it simply, the rules finally caught up with EMS.

The Rules Finally Caught Up With EMS

The Controlled Substances Act was written more than 50 years ago. EMS didn’t fit particularly well into the regulatory framework that developed around it.

Dennis described the purpose of the new rule as formalizing EMS regulations within the Code of Federal Regulations. For decades, the federal rules focused primarily on prescribers, hospitals, pharmacies and other traditional registrants. EMS was never addressed particularly well.

PPAEMA changed that. The new rule provides much clearer direction on how EMS agencies can register, store controlled substances at multiple locations, carry medications aboard EMS vehicles and administer them under standing or verbal orders. All of which is a good thing.

One of the early misconceptions was that the DEA was suddenly cracking down on EMS. The reality is that this legislation helps EMS agencies. It finally gives us some structure around how we’re supposed to operate. And if you’ve spent any time in fire or EMS, you know we tend to like structure.

Registration Has Been Harder Than It Should Be

If there is one issue we’ve consistently heard about during the first six months, it’s registration. Some agencies have had difficulty determining what their state requires before they can obtain a federal DEA registration. Others have struggled simply getting someone at DEA to return a call. Part of the problem is that federal and state requirements have to work together.

As Dennis explained, DEA generally isn’t going to issue a registration until the applicant has whatever authorization is required by the state. That becomes a problem when the federal regulation changes before a state has established a clear process for EMS agencies to follow.

We’ve seen that play out differently across the country. My advice to agencies running into this problem is simple: document what you’re doing. If you’ve called DEA, follow up with an email. Keep the dates. Keep the names. Keep copies of your correspondence. If someone later asks why your registration hasn’t been completed, you should be able to demonstrate that you’ve been actively trying to resolve it.

It’s not that the folks at the DEA don’t want to help. Often the reality is that, like most of us, they’ve got a full workload, and frankly, EMS isn’t at the top of their problem list. Good in some ways, bad in others. In my experience, when I’ve spoken with DEA representatives, they’ve been more than willing to help and are passionate about improving our industry. They just don’t always have the bandwidth to give us the attention we’d like.

The 11 Data Points Are Where the Details Matter

One of the more significant operational changes involves the information agencies need to maintain when controlled substances are administered. There are now 11 required and welldefined data points associated with those records.

Most agencies were already capturing much of this information. But there are details that have caused some confusion. One example is documenting whether a medication was administered pursuant to a standing or verbal order and identifying the appropriate medical authority associated with that administration.

Those may seem like small details until you are asked to produce the records.

As I explained during the webinar, if DEA audits your agency, those records need to be readily retrievable. If demonstrating compliance requires searching through several software systems, paper records and patient care reports just to reconstruct a single administration, you’re making the process much harder than it needs to be and starting off on the wrong foot with a DEA audit.

This is one of the areas we had to focus on at LogRx: not just ensuring compliance, but making sure all records, including DEA Form 222s and Form 41s, could be “readily retrievable” along with all 11 data points for every drug administration. When you’re sitting across from an inspector, it needs to be that easy.

Dennis boiled the DEA’s role down even further: “It’s all about counting beans… can you track the medication from the time it hits your station till when you use it?” That’s probably one of the simplest explanations of controlled-substance accountability I’ve heard.

One issue that actually isn’t new, but still isn’t fully understood, is the difference between waste and destruction. This continues to generate questions.

Waste and Destruction Are Not the Same Thing

In normal EMS operations, we often use the words waste, destruction and disposal interchangeably. DEA doesn’t necessarily look at them that way.

If a paramedic administers part of a syringe and properly wastes the remainder, that waste is documented as part of the administration record.

Destruction is different. Expired medication, damaged inventory and other controlled substances being removed from inventory may require a DEA Form 41 and the appropriate destruction process. Dennis admitted that even when he first joined DEA, the distinction seemed strange:

“When I first heard about the differences between wasting and destruction, I thought, who invented this? Aren’t they the same?” But from a recordkeeping standpoint, the distinction makes sense. One documents what happened to medication associated with a patient administration. The other accounts for controlled substances being removed from inventory. Agencies need to make sure their policies and tracking systems recognize the difference. And again, readily retrievable.

“Good Luck Reinforces Bad Habits”

This may be the biggest lesson from the first six months. EMS has been managing controlled substances for decades. Many agencies have processes that have existed almost as long. That doesn’t necessarily mean those processes are compliant. During the webinar I used an expression I’ve always liked: “Good luck reinforces bad habits.”

If you’ve driven the same stretch of highway at 70 mph every day for years and never received a ticket, eventually 70 starts to feel like the speed limit. Controlled-substance practices can work the same way. We’ve always thrown the remainder in a sharps container. We’ve always kept that record over here. We’ve always transferred narcotics this way at shift change. Nobody has ever questioned it.

That doesn’t necessarily mean it’s right.

PPAEMA gives agencies a good reason to go back and look at practices that may have been passed from one generation of paramedics to another without anyone stopping to ask why they’re doing it that way.

Don’t Confuse Best Practice With a DEA Requirement

This is another area where I think the six-month conversation has become more nuanced.

There are things an agency must do under DEA regulations, and there are things a well-run agency probably should do. Those aren’t always the same thing. Shift-change chain-of-custody documentation is a good example.

Dennis explained that maintaining a log showing that drugs remain intact during shift changes is smart practice, but that level of shift-to-shift documentation is not itself one of DEA’s core federal recordkeeping requirements. That distinction matters.

The goal shouldn’t be to attribute every good narcotics-control practice to DEA. Agencies should understand what federal law actually requires, what their state requires, and what additional controls make sense operationally. There is nothing wrong with exceeding the minimum. In many cases, I think you should, and it sets the right tone for your organization’s culture.

What Happens if DEA Walks in Tomorrow?

This is probably the question I would ask every EMS chief or administrator responsible for controlled substances: If DEA walked through your door tomorrow, could you produce your records without having to search multiple locations? Would you have to call around to different staff members for reports? Could you produce them in ten minutes or less? Or would you be sweating and wishing you’d called in sick?

Dennis identified three areas he would expect an agency to have readily available: its required inventory records, acquisition records such as DEA Form 222s and invoices, and the records associated with controlled-substance administrations. And “readily available” matters.

As Dennis put it during the webinar, “You want one person in charge of the records, and you want he or she to know what they’re talking about.” That doesn’t mean one person needs to handle every controlled substance in the organization. It means somebody owns the process. If an inspector walks in, there shouldn’t be five people standing around trying to figure out who knows where the records are.

Use PPAEMA as a Reset Button

If I were running an EMS agency today, I’d do three things.

First, conduct a self-assessment. Look at how controlled substances move through your organization from the moment they’re received until they’re administered, wasted, destroyed or otherwise leave your inventory. Identify the gaps.

Second, update your policies.

Your policy needs to bring together the federal requirements, your state’s requirements, your local EMS requirements, your medical director’s protocols and your organization’s own procedures.

And third — probably the hardest one — work on the culture. You can have a perfect policy sitting in a binder and still have a terrible controlled-substance program.

Use the new regulations as a reset button. Tell your people why procedures are changing. Train them. Then train them again. Make narcotics accountability part of how your organization operates rather than something everyone thinks about only when there’s a discrepancy.

As I said during the webinar, “The staff is going to take it as serious as you do.” That’s ultimately a leadership issue.

Six Months In

Six months into PPAEMA, I don’t think EMS agencies should look at these regulations as something to fear. They should look at them as an opportunity to clean things up.

The DEA now has regulations that better recognize how EMS actually operates. Agencies have clearer rules for registration, storage, administration and recordkeeping than they had before. It’s almost like they’ve recognized us as an industry. In a way, we should be flattered.

There are still problems, however. Registration remains frustrating in some states. Some of the terminology isn’t intuitive. And there will continue to be questions as agencies put the rule into practice. But the basic test isn’t complicated.

Pick a vial of fentanyl in your system. Can you tell me where it came from? Where it went? Who had it? What happened to it? And can you show me the documentation? If you can do that quickly, you’re probably on the right track. If you can’t, six months into PPAEMA is a pretty good time to figure out why. There are a lot of resources out there to help you get on track; the key is finding the right one to get your agency heading in the right direction, so you can focus on why we exist: to help our patients.

By Clive Savacool, Fire Chief (Ret.), EMT-P

Clive Savacool is a retired fire chief and paramedic with more than 30 years in fire and EMS. He is cofounder and CEO of LogRx, a controlled-substance tracking platform built for EMS and fire agencies. [Watch the full PPAEMA six-month webinar with retired DEA Special Agent in Charge Dennis Wichern here.]

Employee Turnover Survey – Open Now!

Survey will be open June 1 – June 30, 2026.

The American Ambulance Association is partnering with Newton 360, an ambulance industry partner, to conduct our eighth annual industry turnover study. Our intent is to comprehensively collect and analyze ambulance industry employee turnover data to produce a report that provides useful, actionable data. We are inviting selected EMS organizations to participate in the study. The purpose of the study is to better quantify and understand the reasons for turnover at nearly every organizational level within the EMS industry. The study will be conducted and managed by Dennis Doverspike, PhD, and Rosanna Miguel, PhD, affiliated with the Center for Applied Talent Analytics at John Carroll University. Each individual or organizational response will be strictly confidential; no individual organization will be identified in any report or publication. Participating organizations will have full access to the final report at no charge.

Why participate in the survey?

  1. Educate elected officials, municipalities, and healthcare clients regarding regulatory and funding policies at the federal, regional, or local level.
  2. Validate the critical staffing challenges faced by the EMS industry.
  3. Gain insight into combating staff shortages.

Before You Start

Estimated completion time is approximately 20-30 minutes. We recommend you gather information about your employees and about turnover before completing the questionnaire. We will be asking about headcount (filled and open positions) and the number of employees leaving the organization for each of the following job categories: supervisor, dispatch, EMT, part-time EMT, paramedic, and part-time paramedic. We will also be asking about volunteer positions and the costs of recruitment, selection, and training.

The survey will open on June 1, 2026, and close on June 30, 2026. The survey can be accessed by following the link below. If the hyperlink does not work when clicked, please copy the hyperlink and paste it into your browser.

Click here to access the link: AAA – Newton 360 Turnover Survey

Or copy and paste the link:  https://johncarroll.qualtrics.com/jfe/form/SV_ehQfLtOWwA6TEbQ

Thank you,

 

Scott Moore, Esq.

Newton 360

Workforce Dynamics, Inc.

(781) 236-4411 office

(781) 771-9914 mobile

www.newton360.com

2025 Medicaid Rate Survey Released

The American Ambulance Association is pleased to release its 2025 State Medicaid Rate Survey.  This survey sets forth the fee-for-service Medicaid rates for all 50 states.  For each state, the Survey lists the rate paid for each of the following procedure codes:

  • A0428 – BLS Non-Emergency
  • A0429 – BLS Emergency
  • A0426 – ALS Non-Emergency
  • A0427 – ALS Emergency
  • A0433 – ALS-2
  • A0434 – SCT
  • A0225 – Neonate Transport
  • A0998 – Treatment, No Transport
  • A0425 – Mileage
  • A0422 – Oxygen
  • A0382/A0398 – BLS/ALS Routine Disposable Supplies
  • A0420 – Wait Time
  • A0424 – Extra Attendant

The rates set out in this survey are based on publicly available information provided by the various state Medicaid agencies.  While the AAA has taken steps to verify the accuracy of the information on this Survey, it is possible that the rates provided in the Survey may not reflect changes to a state’s reimbursement policies that have not been made publicly available.  These rates may also not reflect any emergency budgetary measures or other temporary reductions imposed by a state.

The AAA’s goal is to make this survey as accurate as possible.  Therefore, if you believe the rates for your state are inaccurate, please contact hello@ambulance.org for assistance.

Download From the AAA Store

The survey is free to AAA members.

 

Whitepaper | State-Level Ambulance Balance Billing Overview

The American Ambulance Association (AAA) is pleased to announce the release of its new state-level whitepaper, Ground Ambulance Balance Billing: Overview and Recommendations. Developed by a collaborative team of industry experts, this comprehensive resource provides an in-depth examination of the complex regulatory landscape surrounding ground ambulance billing and the ongoing challenges of keeping consumers out of the middle of payment disputes. The whitepaper offers an overview of existing state laws, gaps in current policy, and pragmatic recommendations—including standardized payment methods and consumer protections—that can inform both policymakers and EMS providers nationwide.

By sharing promising practices from around the country and highlighting the recent work of the Ground Ambulance and Patient Billing Advisory Committee, Ground Ambulance Balance Billing: Overview and Recommendations underscores the AAA’s commitment to safeguarding patients while supporting fair, sustainable reimbursement for ambulance services. We encourage all EMS stakeholders, insurers, and legislators to review this important paper and join us in shaping policies that protect patients and ensure the ongoing availability of these vital, life-saving services.

Download in the AAA Store

(Free to AAA members. $1000 list.)

SURVEY | 2024 Ambulance Industry Employee Turnover Study

The American Ambulance Association is partnering with Newton 360, an ambulance industry partner and Human Resource support firm, to conduct our sixth annual industry turnover study. Our intent is to comprehensively collect and analyze ambulance industry employee turnover data so as to produce a report that provides useful and actionable data. We are inviting EMS organizations to participate in the study. The study will be conducted and managed by Dennis Doverspike, PhD, and Rosanna Miguel, PhD, who are associated with the Center for Applied Talent Analytics at John Carroll University. Each individual or organizational response will be strictly confidential.

The purpose of the study is to better quantify and understand the reasons for turnover at nearly every organizational level within the EMS Industry. Thank you very much for your time and support.
Take Survey Now

Laying the Groundwork for Reducing Employee Turnover

Why participate in the survey?

  1. Educate elected officials, municipalities, and healthcare clients. The insight gained from this survey can help influence the actions, practices, or decisions of officials regarding regulatory and funding policies at the federal, regional, or local level. Specifically, this important data can help validate the critical staffing challenges faced by the EMS industry.
  2. This study is critical to gaining insight into combating staff shortages. The AAA / Newton 360 2024 Ambulance Industry Employee Turnover Study aims to yield the information that organizations need to identify and benchmark their turnover challenges. Over the years this survey has been conducted, it has generated the largest response to a turnover survey ever published for the private EMS industry.
  3. Participating organizations will have full access to the final report at no charge. The comprehensive results of the study will be shared exclusively with each participating organization. Shorter write-ups and summaries of the results may be shared at conferences or published in relevant periodicals or journals.

Before You Start

It is recommended you gather information about your employees and about turnover before completing the questionnaire.

In this survey, we will be asking about headcount (filled and open positions), number of employees leaving the organization, and reasons for employees leaving. We will be asking these questions for each of the following job categories: supervisor, dispatch, EMT, part-time EMT, paramedic, and part-time paramedic. Headcount refers to the number of filled and open positions for each job category at the end of 2023. Filled positions refer to the number of employees in each job category that were on payroll at the end of 2023. For each job category, the number of filled positions should be added to the number of open positions at the end of 2023 to determine the total headcount.

The survey will open on March 18, 2024, and close at end of day, April 12, 2024. The survey can be accessed by following the link below. Word has an issue with some hyperlinks; this hyperlink is safe. If the hyperlink does not work when clicked, please copy the hyperlink ( https://johncarroll.qualtrics.com/jfe/form/SV_0qZ3r9Mqgp5GwZM ) and past it into your browser.

Take Survey Now

Thank you,

Scott Moore, Esq.
Newton 360
Workforce Dynamics, Inc.

Employee Turnover Study Due 4/30 | iPad Raffle

The American Ambulance Association is partnering with Newton 360, an ambulance industry partner and Human Resource support firm, to conduct our fifth annual industry turnover study. Our intent is to comprehensively collect and analyze ambulance industry employee turnover data to produce a report that provides useful and actionable data. We are inviting EMS organizations to participate in the study. The study will be conducted and managed by Dennis Doverspike, PhD, and Rosanna Miguel, PhD, who are associated with the Center for Applied Talent Analytics at John Carroll University. Each individual or organizational response will be strictly confidential.

The purpose of the study is to better quantify and understand the reasons for turnover at nearly every organizational level within the EMS Industry. Thank you very much for your time and support.

Laying the Groundwork for Reducing Employee Turnover

Why participate in the survey?

  1. Educate elected officials, municipalities, and healthcare clients. The insight gained from this survey can help influence the actions, practices, or decisions of officials regarding regulatory and funding policies at the federal, regional, or local level. Specifically, this important data can help validate the critical staffing challenges faced by the EMS industry. This year, we continue to have queries related to the COVID-19 Public Health Emergency (PHE) even though it is scheduled to end on May 11, 2023. We feel that it is important to understand the lingering impact of the PHE on EMS turnover and its related costs.
  2. This study is critical to gaining insight into combating staff shortages. The AAA / Newton 360 2023 Ambulance Industry Employee Turnover Study aims to yield the information that organizations need to identify and benchmark their turnover challenges. Over the years this survey has been conducted, it has generated the largest response to a turnover survey ever published for the private EMS industry.
  3. Participating organizations will have full access to the final report at no charge. The comprehensive results of the study will be shared exclusively with each participating organization. Shorter write-ups and summaries of the results may be shared at conferences or published in relevant periodicals or journals.

Before You Start

It is recommended you gather information about your employees and about turnover before completing the questionnaire.

In this survey, we will be asking about headcount (filled and open positions), the number of employees leaving the organization, and reasons for employees leaving. We will be asking these questions for each of the following job categories: supervisor, dispatch, EMT, part-time EMT, paramedic, and part-time paramedic. Headcount refers to the number of filled and open positions for each job category at the end of 2022. Filled positions refer to the number of employees in each job category that were on payroll at the end of 2022. For each job category, the number of filled positions should be added to the number of open positions at the end of 2022 to determine the total headcount.

The survey will open on April 17th, 2023, and close at end of the day, on April 30th, 2023. The survey can be accessed by following the link below. If the hyperlink does not work when clicked, please copy the hyperlink and paste it into your browser.
https://johncarroll.qualtrics.com/jfe/form/SV_57s6B8d92GW44wS

Take the Survey

Thank you,
Scott Moore, Esq.
Newton 360
Workforce Dynamics, Inc.
(781) 236-4411 office
(781) 771-9914 mobile
www.newton360.com

4th Annual Study Shows Worsening EMS Turnover

Results from AAA/Newton 360 Fourth Annual EMS Industry Turnover Study Shows Worsening Employee Turnover

The American Ambulance Association (AAA) and Newton 360, an Emergency Medical Services (EMS)-based workforce management software platform, joined forces again this year to conduct the fourth annual survey of employee turnover in the EMS industry. The 2022 survey presents turnover data from 119 EMS organizations, representing more than 12,000 employees. This year, the survey included data regarding the percentage of positions reported to be open at the time of the survey, which showed that EMS agencies are having difficulty filling open positions.

Over the last few years, EMS organizations were impressive in meeting the challenges in the face of the continuing COVID-19 global pandemic. The EMS workforce rose to the challenge and battled the disease, despite the workforce shortages that have plagued the EMS profession and other healthcare partners for nearly a decade. EMS organizations have offered innovative solutions to public health crises, including establishing testing and vaccinations sites around the country, suggesting that EMS employers and employees are prepared to expand their role to include greater provision of preventive services and community-based healthcare.

Turnover Rates by Year by Occupational Category

(2021 Results Appear in Parentheses Below the 2022 Results)

 

  Average Turnover for the Year 2021 Percentage of Open Positions Summer of 2022
Occupation Overall Turnover Voluntary Turnover Involuntary Turnover Open Rate
Full-time EMT 36%

(24%)

31%

(19%)

5%

(5%)

11%
Part-time EMT 36%

(28%)

36%

(24%)

4%

(5%)

39%
Full-time Paramedic 27%

(26%)

26%

(20%)

3%

(3%)

30%
Part-time Paramedic 30%

(23%)

29%

(19%)

2%

(3%)

55%
Supervisor 21%

(15%)

16%

(11%)

2%

(3%)

13%
Dispatch 29%

(30%)

22%

(23%)

6%

(6%)

15%

 

Voluntary and overall turnover increased for 2022, with the turnover rate being in the 20 to 36 percent range for EMTs and Paramedics, a 6% increase over the prior year. Meaning that EMS agencies are experiencing a full turnover of all staff every 3-4 years. Greater than one third of all new hires, turnover within their first year of employment. Not surprisingly, this converted into a relatively high rate of currently open positions, especially for EMTs and Paramedics at EMS agencies around the country.

In keeping with prior year’s surveys, the primary reasons for cited for turnover across all positions within EMS agencies is low pay and benefits, followed by a change in career. While many agencies offered stipends and increase wages in an effort to incentivize employees, it has not flattened the turnover curve. One of the key findings in this year’s survey is the significant increase in open positions for those EMTS and Paramedics working in a part time capacity.  The open position rate for part-time paramedics was at a staggering 55%, suggesting that those who previously worked EMS as a second job no longer find it an attractive part time career choice.

This study evidences a need to embark upon a larger initiative to collect data on the EMS workforce in the U.S. A report published by the Health Resources and Services Administration (HRSA) stated that there will be a need for an additional 40,000 EMS personnel by 2030, in part, because of the recognition of the valuable education, training, and experience individuals working in the EMS field offer in other healthcare settings. This will necessitate an extensive understanding of the nature and reasons for turnover in EMS-related occupations.

New for Members | 2022 Human Resources Manual!

The 2022 Human Resources Toolkit includes the addition of numerous practice notes intended to provide EMS leaders with a more practical understanding of the legal principles that necessitate much of the language found in many of the sample policies in the HR Manual. Additionally, the practice notes provide suggestions for EMS agencies to better insulate the organization from legal liability.

Members, Download Your Free PDF Copy!

Study | EMS Super-Utilizers

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.

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