Voluntary AEMT Accreditation to Launch January 1, 2025
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NREMT Board of Directors Rescinds Expanded Eligibility Resolution
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>
CAAS | GVS V3.0 Draft for Public Comment #2
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Lights & Siren Vehicle Operations on Emergency Medical Services (EMS) Responses
Joint Statement on Lights & Siren Vehicle Operations on Emergency Medical Services (EMS) Responses
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:
- The primary mission of the EMS system is to provide out-of-hospital health care, saving lives and improving patient outcomes, when possible, while promoting safety and health in communities. In selected time-sensitive medical conditions, the difference in response time with L&S may improve the patient’s
- EMS vehicle operations using L&S pose a significant risk to both EMS practitioners and the public. Therefore, during response to emergencies or transport of patients by EMS, L&S should only be used for situations where the time saved by L&S operations is anticipated to be clinically important to a patient’s outcome. They should not be used when returning to station or posting on stand-by
- Communication centers should use EMD programs developed, maintained, and approved by national standard-setting organizations with structured call triage and call categorization to identify subsets of calls based upon response resources needed and medical urgency of the call. Active physician medical oversight is critical in developing response configurations and modes for these EMD protocols. These programs should be closely monitored by a formal quality assurance (QA) program for accurate use and response outcomes, with such QA programs being in collaboration with the EMS agency physician medical
- Responding emergency agencies should use response based EMD categories and other local policies to further identify and operationalize the situations where L&S response or transport are clinically Response agencies should use these dispatch categories to prioritize expected L&S response modes. The EMS agency physician medical director and QA programs must be engaged in developing these agency operational policies/guidelines.
- Emergency response agency leaderships, including physician medical oversight and QA personnel should monitor the rates of use, appropriateness, EMD protocol compliance, and medical outcomes related to L&S use during response and patient
- Emergency response assignments based upon approved protocols should be developed at the local/department/agency level. A thorough community risk assessment, including risk reduction analysis, should be conducted, and used in conjunction with local physician medical oversight to develop and establish safe response
- All emergency vehicle operators should successfully complete a robust initial emergency vehicle driver training program, and all operators should have required regular continuing education on emergency vehicle driving and appropriate L&S
- Municipal government leaders should be aware of the increased risk of crashes associated with L&S response to the public, emergency responders, and patients. Service agreements with emergency medical response agencies can mitigate this risk by using tiered response time expectations based upon EMD categorization of calls. Quality care metrics, rather than time metrics, should drive these contract
- Emergency vehicle crashes and near misses should trigger clinical and operational QA reviews. States and provinces should monitor and report on emergency medical vehicle crashes for better understanding of the use and risks of these warning devices.
- EMS and fire agency leaders should work to understand public perceptions and expectations regarding L&S use. These leaders should work toward improving public education about the risks of L&S use to create safer expectations of the public and government
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.
Sponsoring Organizations and Representatives:
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
References:
- Use of warning lights and siren in emergency medical vehicle response and patient transport. Prehosp and Disaster Med. 1994;9(2):133-136.
- Grant CC, Merrifield Analysis of ambulance crash data. The Fire Protection Research Foundation. 2011. Quincy, MA.
- Kahn CA, Pirallo RG, Kuhn EM. Characteristics of fatal ambulance crashes in the United States: an 11-year retrospective Prehosp Emerg Care. 2001;5(3):261-269.
- Ray AF, Kupas DF. Comparison of crashes involving ambulances with those of similar-sized vehicles. Prehosp Emerg Care. 2005;9(4):412-415.
- S. Fire Administration. Firefighter fatalities in the United States in 2013. 2014. Emmitsburg, MD.
- Maguire Transportation-related injuries and fatalities among emergency medical technicians and paramedics.
Prehosp Disaster Med. 2011;26(5): 346-352.
- Maguire BJ, Hunting KL, Smith GS, Levick Occupational fatalities in emergency medical services: A hidden crisis.
Ann Emerg Med, 2002;40: 625-632.
- Drucker C, Gerberich SG, Manser MP, Alexander BH, Church TR, Ryan AD, Becic Factors associated with civilian drivers involved in crashes with emergency vehicles. Accident Analysis & Prevention. 2013; 55:116-23.
- Clawson JJ, Martin RL, Cady GA, Maio RF. The wake effect: emergency vehicle-related collisions. Prehosp Disaster Med. 1997; 12 (4):274-277.
- Kupas DF. Lights and siren use by emergency medical services: Above all, do no harm. National Highway Traffic Safety Administration. 2017. Available online at https://www.ems.gov/pdf/Lights_and_Sirens_Use_by_EMS_May_2017.pdf
- Watanabe BL, Patterson GS, Kempema JM, Magailanes O, Brown LH. Is use of warning lights and sirens associated with increased risk of ambulance crashes? A contemporary analysis using national EMS information system (NEMSIS) Ann Emerg Med. 2019;74(1):101-109.
- Jarvis JL, Hamilton V, Taigman M, Brown LH. Using red lights and sirens for emergency ambulance response: How often are potentially life-saving interventions performed? Prehosp Emerg Care. 2021; 25(4): 549-555.
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Statement for House Ways & Means Hearing on America’s Mental Health Crisis
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:
- During the current public health emergency and for at least two years thereafter, eligibility for first responder training and staffing grant programs administered by the U.S. Department of Health and Human Services (such as SAMHSA Rural EMS Training Grants and HHS Occupational Safety and Health Training Project Grants) should be expanded to include for-profit entities. Spending on training and services for mental health should also be included as eligible program
- Congress should authorize the establishment of a new HHS grant program open to public and private nonprofit and for-profit ambulance service providers to fund paramedic and EMT recruitment and training, including employee education and peer-support programming to reduce and prevent suicide, burnout, mental health conditions and substance use
- Any initiatives to fund hero pay or death benefits for first responders should be inclusive of all provider models—for-profit, non-profit, and
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.
- Prevalence of PTSD and common mental disorders amongst ambulance personnel: A systematic review and meta-analysis. Soc Psychiatry Psychiatr 2018;53(9):897-909.
- ALmutairi MN, El Mahalli AA. Burnout and Coping Methods among Emergency Medical Services Professionals. J Multidiscip Healthc. 2020;13:271-279. Published 2020 Mar 16. doi:10.2147/JMDH.S244303
- Stanley, I. H., Hom, M. A., & Joiner, T. E. (2016). A systematic review of suicidal thoughts and behaviors among police officers, firefighters, EMTs, and Clinical Psychology Review, 44, 25–44. https://doi.org/10.1016/j. cpr.2015.12.002
- Doverspike D, Moore S. 2021 Ambulance Industry Employee Turnover Study. 3rd Washington, DC: American Ambulance Association; 2021.
Wall Time Toolkit
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.
EMTALA – Emergency Medical Treatment and Labor Act
Summary of Major Provisions
- The Emergency Medical Treatment and Labor Act (EMTALA) is a federal law that was enacted as part of the Consolidated Omnibus Budget Reconciliation Act (COBRA) of 1985 (42 U.S.C. §1395dd).
- EMTALA provides that when an individual comes to an emergency department, he/she/they must be stabilized and treated, regardless of their insurance status or ability to pay.
- EMTALA is often referred to as the “anti-dumping” law and was designed to prevent hospitals from transferring uninsured or Medicaid patients to another hospital without, at a minimum, providing a medical screening examination to ensure they were stable for transfer.
- EMTALA requires the hospital to provide a screening examination to determine if an emergency medical condition exists and, if so, provide stabilizing treatment to resolve the patient’s emergency medical condition.
- EMTALA requires Medicare-participating hospitals with emergency departments to screen and treat the emergency medical conditions of patients in a non-discriminatory manner to anyone, regardless of their ability to pay, insurance status, national origin, race, creed, or color.
EMTALA & Ambulance Patient Offloading Times (APOT)
- EMS agencies have been struggling with extended Emergency Department patient offload times. This has been exacerbated over the last few years of the COVID-19 pandemic.
- This has impacted the ability of EMS agencies to provide services and respond to ambulance service requests. Additionally, it is impacting many public safety agencies that are responding to medical emergencies.
- Centers for Medicare & Medicaid Services (CMS) issued a memorandum on extended ambulance patient offload times and EMTALA in July 2006.
- In the memorandum, CMS noted “Many of the hospital staff engaged in such practice believe that unless the hospital “takes responsibility” for the patient, the hospital is not obligated to provide care or accommodate the patient”
- CMS stated that this practice may result in a violation of the Emergency Medical Treatment and Labor Act (EMTALA) and “raises serious concerns for patient care and the provision of emergency services in a community.”
- Additionally, CMS notes that this practice may also result in a violation of 42 CFR 482.55, the Conditions of Participation for Hospitals for Emergency Services, which requires that a hospital meet the emergency needs of patients in accordance with acceptable standards of practice.
- EMTALA defines[1] when a patient “presents” at an emergency department in the following way:
(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.
APOT Strategies
- EMS agencies who are experiencing extended ambulance patient offload times should engage the hospital leadership to collaborate to identify possible solutions. Often, we assume that the hospital leadership is aware that the EMS crews are being held for extended periods of time. Also, the hospital may not understand how APOT is impacting your organization and the overall EMS and public safety response. Emphasize that EMS is one piece of a larger EMS system.
- EMS agencies should consider educating or reminding the hospital leadership about their obligations under EMTALA.
- Consider placing a transfer coordinator or another member of your staff to stay with patients during the transition between EMS and ED care. The EMS agency is under no obligation to do this and could set a precedent or expectation by the hospital that extended APOT is the EMS agency’s responsibility. However, it may serve to free up valuable EMS resources.
EMTALA & APOT Frequently Asked Questions
- Are EMS personnel required to remain with the patient until an emergency department personnel “accept” report or “takes over care” of the patient?
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.
- What if the patient’s condition requires constant attention and the patient cannot be left alone without causing the patient harm?
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.
- What do I do if the emergency department staff fail/refuse to take a report or take over care of the patient?
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.
- Can I be accused of patient abandonment if I leave a patient in the ED without a member of the ED staff taking over the care of the patient?
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
In the News:
EMS crews forced to wait hours to drop patients at overwhelmed hospitals
CAAS Releases GVS V3.0 Draft for Public Comment
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.
More Court Injunctions Impacting the Federal Contractor & CMS Mandatory Vaccination Rules
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Federal Court Injunctions Impacting the Federal Contractor & CMS Mandatory Vaccination Rules
This content is for AAA members only.
Please either or Join!
Federal Court Enjoins the Federal Contractor Vaccine Mandates in KY, OH, TN
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Study | EMS education research priorities during COVID-19
From 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
Objective
Our objective was to identify research priorities to understand the impact of COVID-19 on initial emergency medical services (EMS) education.
Methods
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.
Results
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.
Conclusions
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.
HHS | $103mm for Healthcare Workforce Resiliency and to Address Burnout
FOR IMMEDIATE RELEASE
Contact: HHS Press Office
202-690-6343
media@hhs.gov
202-690-6343
media@hhs.gov
HHS Announces $103 Million from American Rescue Plan to Strengthen Resiliency and Address Burnout in the Health Workforce
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:
- Promoting Resilience and Mental Health Among Health Professional Workforce – Approximately 10 awards will be made totaling approximately $29 million over three years to health care organizations to support members of their workforce. This includes establishing, enhancing, or expanding evidence-informed programs or protocols to adopt, promote and implement an organizational culture of wellness that includes resilience and mental health among their employees.
- Health and Public Safety Workforce Resiliency Training Program – Approximately 30 awards will be made totaling approximately $68 million over three years for educational institutions and other appropriate state, local, Tribal, public or private nonprofit entities training those early in their health careers. This includes providing evidence-informed planning, development and training in health profession activities in order to reduce burnout, suicide and promote resiliency among the workforce.
- Health and Public Safety Workforce Resiliency Technical Assistance Center – One award will be made for approximately $6 million over three years to provide tailored training and technical assistance to HRSA’s workforce resiliency programs.
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.
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Webinar 7/7 | Lights & Sirens Responses
Flipping OFF the Switch on HOT Emergency Medical Vehicle Responses!
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!
Speakers
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
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.
CMS Releases CY 2021 Physician Fee Schedule
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.
CMS Relaxes Physician Certification Statement Signature Requirements During Public Health Emergency for COVID-19
CMS Relaxes Physician Certification Statement Signature Requirements During Public Health Emergency for COVID-19
By Kathy Lester, J.D., M.P.H.
The Centers for Medicare & Medicaid Services (CMS) has released guidance that recognizes the difficulty ambulance service providers and suppliers may have during the COVID-19 Public Health Emergency (PHE) in obtaining a physician certification statement (PCS) signed by a physician or other authorized professional. The question and answer below indicates that CMS (and its contractors by extension) will not deny claims during a future medical audit even if there is no signature for non-emergency ambulance transports, absent an indication of fraud or abuse. Ambulance service providers and suppliers should indicate in the documentation that a signature was not able to be obtained because of COVID-19. The AAA advises completing the PCS form and then indicating if a physician, or other appropriate personnel, has not signed it by writing “COVID-19 Public Health Emergency” on the signature line. CMS also reminds providers and suppliers that medical necessity still needs to be met.
The American Ambulance Association has been advocating for CMS to ease its restrictions on signature requirements during the COVID-19 PHE. The FAQ posted by CMS is consistent with our recommendations.
The specific Q&A is below:
Q. For ambulance services that require a physician, or, in lieu of that, certain non-physician personnel, to sign and certify that a non-emergency ambulance transport is medically necessary, are these signature requirements not required during the COVID-19 PHE?
A. We understand that in certain situations during the COVID-19 PHE it may not be feasible to obtain the practitioner signature. Therefore, for claims with dates of service during the COVID- 19 PHE (January 27, 2020 until expiration), CMS will not review for compliance with appropriate signature requirements for non-emergency ambulance transports during medical review, absent indication of fraud or abuse. Ambulance providers and suppliers should indicate in the documentation that a signature was not able to be obtained because of COVID-19. However, we note that Medicare Part B covers ambulance transport services only if they are furnished to a Medicare beneficiary whose medical condition is such that other means of transportation are contraindicated, and the beneficiary’s condition must require both the ambulance transportation itself and the level of service provided in order for the billed service to be considered medically necessary.
The full Q&A document can be accessed here.
Infographic | What Does the CMS COVID-19 IFR Mean for EMS?
Looking for highlights from the new CMS IFR? See below for an infographic! (Members, read Kathy Lester, Esq.’s comprehensive summary.)
CMS Waives Restrictions on Ground Ambulances During COVID-19 Pandemic
The Centers for Medicare and Medicaid Services (CMS) promulgated an interim final rule with comment period (IFC) entitled “Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency.” Consistent with the recommendations the AAA made to CMS, for the duration of the public health emergency (PHE), the IFC allows ground ambulance service providers and suppliers to transport patients both on an emergency or non-emergency basis to any destination that is equipped to treat the condition of the patient consistent with Emergency Medical Services (EMS) protocols established by state and/or local laws where the services will be furnished. In related guidance, CMS has suspended most Medicare Fee-For-Service (FFS) medical review during the emergency period due to the COVID-19 pandemic, waived patient signature requirements, and is pausing the Repetitive, Scheduled Non-Emergent Ambulance Transport Prior Authorization Model. The policies of the IFC are effective retroactively to March 1, 2020.
On March 11, the AAA sent CMS a letter specifically requesting for the agency to waive during the COVID-19 pandemic the regulatory restrictions that prevent coverage for transport to alternative destinations. Separately, the AAA has been pressing CMS to provide relief from signature requirements. The AAA had also been working with CMS to lifting of these restrictions and others to eliminate barriers the current Medicare regulations in responding to the COVID-19 crisis.
Paying for Transports to Alternative Destinations. During the duration of the crisis, CMS has expanded the list of destinations for which Medicare covers ambulance transportation to include all destinations, from any point of origin, that are equipped to treat the condition of the patient consistent with Emergency Medical Services (EMS) protocols established by state and/or local laws where the services will be furnished.
These destinations may include, but are not limited to: any location that is an alternative site determined to be part of a hospital, critical access hospital (CAH) or skilled nursing facility (SNF), community mental health centers, federal qualified health clinic (FQHCs), rural health clinics (RHCs), physicians’ offices, urgent care facilities, ambulatory surgery centers (ASCs), any location furnishing dialysis services outside of an ESRD facility when an ESRD facility is not available, and the beneficiary’s home.
This expanded list of destinations applies to medically necessary emergency and non-emergency ground ambulance transports of beneficiaries during the PHE for the COVID-19 pandemic. The IFC does not waive the medically necessary requirements for ground ambulance transport of a patient in order for an ambulance service to be covered.
The AAA is working closely with CMS to confirm that patients who require isolation meet the medical necessity requirements.
Suspension of Audits and Relief on Patient Signatures. In guidance released separately, CMS indicates that it is suspending nearly all audits of providers and suppliers for the duration of the PHE.
CMS has suspended most Medicare Fee-For-Service (FFS) medical review during the emergency period due to the COVID-19 pandemic. This includes pre-payment medical reviews conducted by Medicare Administrative Contractors (MACs) under the Targeted Probe and Educate program, and post-payment reviews conducted by the MACs, Supplemental Medical Review Contractor (SMRC) reviews and Recovery Audit Contractor (RAC). No additional documentation requests will be issued for the duration of the PHE for the COVID-19 pandemic. Targeted Probe and Educate reviews that are in process will be suspended and claims will be released and paid. Current postpayment MAC, SMRC, and RAC reviews will be suspended and released from review. This suspension of medical review activities is for the duration of the PHE. However, CMS may conduct medical reviews during or after the PHE if there is an indication of potential fraud.
CMS also indicates in this guidance that a beneficiary’s signature will not be required for proof of delivery, as it relates to durable medical equipment services, during the PHE. In a follow-up exchange with CMS, the AAA has confirmed that this policy of not requiring a beneficiary’s signature also applies to ground ambulance providers and suppliers. The AAA has requested that this clarification for ground ambulances also be provided in a written FAQ.
Pause in the Non-Emergency Prior Authorization Model. CMS has paused the claims processing requirements for the Repetitive, Scheduled Non-Emergent Ambulance Transport Prior Authorization Model, effective March 29 until the end of the PHE. During this pause, claims for repetitive, scheduled non-emergent ground ambulance transports for the COVID-19 pandemic in States in which the model operates will not be stopped for pre-payment review if prior authorization has not been requested by the fourth round trip in a 30-day period. During the pause, the MAC will continue to review any prior authorization requests that have already been submitted, and ambulance suppliers may continue to submit new prior authorization requests for review during the pause. Claims that have received a provisional affirmative prior authorization decision and are submitted with an affirmed unique tracking number (UTN) will continue to be excluded from future medical review. Following the end of the PHE for the COVID-19 pandemic, the MACs will conduct postpayment review on claims otherwise subject to the model that were submitted and paid during the pause.
Telehealth Services. While CMS does not provide authority for ambulance organizations to bill directly for telehealth services, it does modify for the duration of the PHE the “direct supervision” requirements to allow physicians enter into a contractual arrangement with an entity that provides ambulance services to allow the physician to use the ambulance organization’s personnel as auxiliary personnel under a leased agreement. Under such circumstances, the provider or supplier would seek payment for any services it provided from the billing physician and would not submit claims to Medicare for such services directly.
Ongoing work of the AAA. The rule does not address two critical issues: (1) reimbursement for treatment in place and (2) direct reimbursement for telehealth services. The AAA will continue to work with CMS and the Congress to address these issues that are critical to meeting the needs of patients and your community during the epidemic.
CMS Grants State of Florida’s 1135 Waiver Request for Coronavirus Response
On March 16, 2020, CMS approved an 1135 Waiver request submitted by the State of Florida. The State had requested the flexibility to waive prior authorization requirements, streamline its Medicaid enrollment process, and allow care to be provided in alternative settings to the extent an existing health care facility needs to be evacuated. The key provisions of the waiver are summarized below:
1. Payments to Out-of-State Providers: Under current CMS coverage guidelines, the Florida Medicaid Program had the authority to reimburse out-of-state providers that were not enrolled in the Florida Medicaid Program provided certain criteria were met. However, this authority was limited to situations involving: (a) a single instance of care furnished over a 180-day period or (b) multiple instances of care furnished to a single Florida Medicaid beneficiary over a 180-day period. Under the waiver, CMS is removing the 180-day restriction for the duration of the emergency.
2. Expedited Enrollments: With respect to providers that are not currently enrolled in the Medicare Program or with another State Medicaid Agency, CMS is waiving the following screening requirements: (a) the payment of the application fee, (b) the fingerprint-based criminal background checks, (c) the required site visits, and (d) the in-state/territorial licensing requirements. Under the waiver, the state would still be required to check enrolling providers against the OIG exclusion list, and confirm that the out-of-state provider is properly licensed in their home state.
3. Cessation of Revalidation Efforts: CMS granted Florida the authority to temporarily cease the revalidation of enrolled in-state Medicaid providers and suppliers who are directly impacted by the emergency.
4. Waiver of Prior Authorization Requirements: CMS has granted Florida the right to waive any prior authorization requirements that are currently part of the State Medicaid Plan. This waiver applies to services provided on or after March 1, 2020, and will continue through the termination of the emergency declaration.
5. Waiver Allowing Evacuating Facilities to Provide Services in Alternative Settings: CMS will allow facilities, including nursing facilities, intermediate care facilities for individuals with intellectual and developmental disabilities, psychiatric residential treatment facilities, and hospitals to be reimbursed for services rendered during an emergency evacuation to an otherwise unlicensed facility. This waiver will extend for the duration of the declared emergency; however, CMS will require the unlicensed facility to seek licensure with the state after 30 days.
Understanding Medicare, Medicaid, and SCHIP Coverage of Ambulance Services under a Declared National State of Emergency
On March 13, 2020, President Donald J. Trump announced a national state of emergency in response to the COVID-19 pandemic. Previously, HHS Secretary Alex Azar had declared a public health emergency under Section 319 of the Public Health Service Act in response to COVID-19.
This has prompted many AAA members to ask what impact, if any, these declarations have on the coverage of ambulance services under federal health care programs?
The short answer is that these declarations give CMS the authority under Section 1135 of the Social Security Act to waive certain Medicare, Medicaid, and SCHIP Program requirements. This waiver authority includes, but is not necessarily limited to:
• Waiving certain conditions of participation and/or certification requirements;
• Waiving certain pre-approval requirements;
• Waiving the requirements that a provider or supplier be licensed in the state in which they are providing services;
• Waiving EMTALA requirements related to medical screening examinations and transfers; and
• Waiving certain limitations on payments for services provided to Medicare Advantage enrollees by out-of-network providers.
One situation where an 1135 waiver may be of use to an ambulance provider or supplier would be where the ambulance provider or supplier is sending vehicles and crews to a state that is outside its normal service area. The ambulance provider or supplier is unlikely to be licensed by the state in which it is responding. As a result, under normal circumstances, it would be ineligible for payment under federal health care program rules. The 1135 waiver would permit it to submit claims for the services it furnishes in the other state.
Of more immediate significance to the current national emergency, an 1135 waiver may permit hospitals and other institutional health care providers to establish an off-site treatment center for initial screenings of patients. For example, hospitals may establish triage sites in parking lots and other open spaces for the initial intake of patients suspected of being infected with the COVID-19 virus. In theory, this waiver could also extend to drive-thru testing sites to the extent they are operated by the hospital or another health care provider. When a hospital has obtained an 1135 waiver to operate an off-site treatment center, the off-site area becomes a part of the hospital for Medicare payment purposes. Therefore, ambulance transports to an approved off-site treatment area should be submitted to Medicare using the “H” modifier for the destination.
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