Section 1 – Definitions pg. 4 - Arkansas Ambulance Association

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Transcript Section 1 – Definitions pg. 4 - Arkansas Ambulance Association

Comprehensive Review
of the proposed
Arkansas
EMS Rules & Regulations
December 12, 2012
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Section 1 – Definitions
pg. 4
• F. Air Ambulance Service – Emergency
• G. Air Ambulance Service
“unsure of need for two separate definitions”
“does the addition of EMERGENCY open the
the door making air ambulance a PRIMARY
RESPONSE entity?”
Definitions
pg. 5
• P. Emergency Medical Services
“consider adding language that also addresses
the care and transportation interfacility, to
places of residence, to alternative care sites,
etc. – not just to a medical facility.”
Definitions
pg. 6-7
• EE. Ground Ambulance Service Area
• Topic of much debate
• Limited to “within a county boundary”
Definitions
pg. 7
• FF. Intercept
**suggestion**
Intercept: Instances where a transporting
service requests assistance from an
ambulance service which provides a higher
level of medical care and/or transport, and in
accordance with written contracts or
agreements between the ambulance service
and city/county governments as may exist.
Definitions
pg. 7
• II. Mass Casualty Incident
• Better define ALS provider’s role in performing
triage and being able to handoff (assign) care
and transport roles to BLS and ALS resources
as may respond to the MCI event
Definitions
pg. 7
• JJ. Medical Director (ALS Services)
• ArAA has received many calls and comments
concerning this definition
• Key: “board certified” OR “board eligible”
• Clarification: define “current experience in
emergency medicine”
Definitions
pg. 8
• Of Sound Mind
• This is actually the term “Of Unsound Mind”
as defined in the Arkansas Code referenced
(Ark. Code 20-9-601)
• Syntax edit – change Sound to Unsound
Definitions
pg. 8
• WW. Reaction Time
• ArAA recommends leaving this definition
unchanged
Definitions
pg. 8
• ZZ. Service Area
• Why is this defined again?
• Ground and Air Ambulance Service Areas
previously defined.
• Add “and on file with the Department” to
previous definitions
Definitions
pg. 9
• CCC. Specialty Care Members
• DDD. Specialty Mission
• Simple text edits:
….by the Medical Director of an a ambulance
service ….
....An assignment for an ambulance service….
Definitions
• Two Minute Reaction Time
pg. 9
**suggestion**
“The time from when the emergency call is
received by the ambulance service and
adequate information is made available which
identifies the location and nature of the call,
and until the ambulance is enroute.
Definitions
pg. 9
• Probation
• This term has been stricken from the
definitions section but is referenced in the
Violations section later in the document
• Suggestion: reinstate definition
SECTION II: PURPOSE
pg. 9
• Consider expanded definition
• We do more than just prehospital EMS
• Suggestion – change all references to
prehospital to “out-of-hospital” (consistent with
terminology in Agenda for the Future documents)
SECTION III
LICENSURE OF AMBULANCE SERVICES
• A. 1. Patient’s choice of nearest appropriate
medical facility
• Insert at end
…, or the destination as indicated by the
Arkansas Trauma Advisory Council.
Section III
pg. 11
• 7. Non-transferability of License
• Too inflexible for business ownership
• Suggest changing to Transferability
• License become transferable but would still
require all updated documents and
credentials be on file with the Department
Section III
pg. 12
• 10. Service Area
• Insert the following:
The service area of each licensed ambulance shall be clearly
identified on a map provided by the Department and submitted
annually to the Department. A licensed Service may cross county
lines to serve a portion of an adjoining county with an agreement
with the licensed Service(s) in the adjoining county, and in
accordance with written contracts or agreements between the
ambulance service and city/county governments as may exist. This
agreement shall be submitted Department annually with the
service area map. This excludes Air Ambulance Services.
Section III
pg. 14
• 18. Transportation of non-patient care
equipment
• Over reaching
• Would prohibit transporting items for
“Toys for Tots”
• Suggestion: omit Item 18
Section IV
pg. 15
• A. 4. (first occurrence)
• Advanced Response Services do not have
ambulances; change all references (here and
throughout the document to VEHICLE(S)
*Note: item 4 is duplicated which will change
all subsequent items in this section
Section IV
pg. 15
• B. 1.
• We suggest that this section reflect the ability
to used tiered dispatch protocols to dictate
the actual level of permitted vehicle(s)
dispatched to the emergency response.
Section IV
pg. 17
• B. 7.
• Any authorized representative of the Department shall
have the right to enter the premises of any service or
permitted ambulance at any time in order to make
whatever inspection necessary in accordance with the
minimum standards and regulations prescribed herein
(subject to applicable privacy laws). Each service shall
maintain and make available to the Department for
inspection records including, but not limited to:
Section IV
pg. 17
• B. 7.
…..herein (subject to applicable privacy laws).
Each service shall maintain and make available
(during normal business hours) to the
Department for inspection records including,
but not limited to:
Section IV
pg. 18
• C. 4. I.
• This item needs to be worded to include
advanced providers handing off to BLS level of
care when appropriate by triage or during MCI
Section IV
pgs. 18-19
• C. 5. a.
….emergency evacuation services only, and
does not participate in the business of
providing continuous general population
response for emergency medical services, and
is limited to pediatrics, neonatal, high risk
obstetrical, or the industrial settings.
Section IV
pg. 19
• 7. Licensed Medical Facility Transport Service
• Subsection b. 1)
Strike the words “Agree to…”
1)
Agree to use license……
* Also looking at language within the stretcher van rules & reg’s
which requires transports only within the facility’s system
Section V
pg. 21
(vehicle permitting)
• B. 6.
• Edit for clarification of medical equipment
“Any medical equipment carried……
• B. 10.
• Change “Request” to “Notice”
Section V
pg. 21
• B. 11.
• In all subsections a., b., and c. strike
references to size of lettering
• Allow the service to determine size and
schema of its branding
• For consistency, include “may be displayed”
for each item
Section V
pg. 22
• B. 19.
• Edit to read as
“….with the main oxygen tank’s regulator
indicating the cylinder pressure visible from
within the patient compartment. the EMSP’s
seat that indicates cylinder pressure.”
Section V
pg. 23
• B. 26.
• Change “sanitary” to “clean”
• No way to ensure sanitary conditions
Section V
pg. 24
• For consistency, in the Section C, change all
references to “vehicle” to “ambulance”, except
in C.4.
• 4. Advanced Response Permitted Vehicle Ambulance
Sections VI – VII Air Ambulance
• No specific comments or suggested changes
Section VIII
pg. 36
• Subsection A
• Clarification concerning a paramedic responding
within the service area where more than one ALS
provider may be licensed.
• Medic initiates care thinking his/her service is
responding, but another agency within the service
area responds.
• Would this be a violation?
• “…arrival of the transporting ambulance from his
service….
Section VIII
pg. 38
• B. 1. Procedures and skills for all EMSP’s
• Add clarification that these “may be
performed”
Section IV – Education, Testing and Licensure
• Request to include and recognize Professional
Rescuer CPR credentials as may be issued by a
qualified ECSI training center.
• Emergency Care and Safety Institute
(formerly National Safety Council)
• Used often by industrial groups
• Meets exact curriculum and criteria as AHA
• Add to all subsections where AHA and Red Cross are
referenced (first occurrence on pg. 42, item c.)
Section IX
pg. 44
• C. 3. g. “Submit a signed letter of good
standing from the Training Site in which your
EMSP instructor certification is aligned with.
• New requirement for instructors (alignment)
• What happens if an instructor cannot align
with a training site?
• Same problem as with providers who cannot
achieve backfill agreements
Section XI
pg. 50
• EMSP Training Sites
• F. Course instructor must be an Arkansas
Licensed Physician or an EMS-Instructor
licensed at the Paramedic level.
• This would require even basic EMT courses to
be taught only by a paramedic level instructor
Section XII
pg. 52
• B. 6. a.
• “…..within a medical facility with hospital
concurrence.”
• With the use of alternative clinical sites (ie.
free standing surgery centers, clinics, etc.), we
recommend striking “with hospital
concurrence.”
Section XIV
pg. 60
• C. 3. Security
• “All other prescription drugs shall be stored
under a single lock security.”
• Clarification of whether or not the locked
vehicle constitutes a single lock security
system.
Section XIV
pg. 63
• H. Storage of Pharmaceuticals …..
• Could this force inclusion of heated and/or
refrigerated compartments as part of
ambulance design / retrofit?
• Suggest simply stating “storage to follow
manufacturer’s recommendations for all
pharmaceuticals carried.”
Section XV - TRAUMA SYSTEM pg. 63
• The ArAA recommends the inclusion of the
clarifier “for ambulance services
participating in the trauma system”
• Suggest to include as a header to this section.
Section XV. TRAUMA SYSTEM
For those ambulance services participating in
the Arkansas trauma system,
Section XV
pg. 64
• Urgent Trauma Transfers
The hospital seeking the urgent trauma transfer shall contact the ATCC to provide
patient condition information and to obtain concurrence with the urgent trauma
transfer classification. All urgent trauma transfers shall prompt involvement of the
medical director of ATCC in real time. The medical director shall verify the urgent
nature of the transfer and concur there is reasonable evidence the two conditions
of an urgent trauma transfer are met. If the above conditions are met and
concurrence from ATCC is obtained, this transfer qualifies as an urgent trauma
transfer. As soon as the sending hospital recognizes the need for an urgent
trauma transfer, the hospital shall alert the local EMS provider.
Once the ATCC confirms the patient meets the criteria for urgent trauma transfer,
ATCC shall gains acceptance by the receiving hospital, contact the EMS provider
identified by the transferring hospital to coordinate The ATCC shall confirm with
the transferring hospital the time the patient will pick-up and communicate that to
the EMS provider.
Section XVI – Violations
pg. 64
• Scalability of violations has been taken away
• A hit, is a hit, is a hit -- 3 hits and your done!
• The ArAA requests separation of violations and
punitive actions by class:
– SERVICE LICENSEE TRAINING SITE
• Clearly define warnings, probation, suspension, etc.
• Don’t link the service to a provider’s actions in all
cases
Section XVI
pg. 65
• c. Three (3) formal citations during license
term for failure to comply with Arkansas Code
§ 20-13-2005 and any regulations
promulgated the Department in regard to
ambulance services shall result in revocation
of the ambulance service license. However….
• Change “shall” to “may”
Section XVI
pgs. 65-68
• OFFENSES:
• Grocery list is too long and not stratified
• References are made to “probation” but
probation is no longer a defined term
• Earlier comments concerning splitting by class
apply here as well
• Also suggest adding “or under the influence of
prescription drugs” everywhere “drugs” is
included in the potential violations
MINIMUM REQUIRED EQUIPMENT LIST
• Soft Supplies
– Saline drops
Is this eye drops? Would NS from
IV bag suffice?
• Transport
– Pedi-Mate or Equivalent
There is no certified
device currently. The
Section of EMS is
working on this one.
MINIMUM REQUIRED EQUIPMENT LIST
• Paramedic / ALS
– New mandatories:
•
•
•
•
Adenosine
Dobutamine Drip
Glucagon $123.00 a dose (1 year shelf life at longest)
Magnesium Sulfate
» begs the question, what about CaCL as antidote?
• Lidocaine Drip (but no required Lidocaine bolus)
» What if service opts to carry Amiodarone as the
antiarrythmic?
MINIMUM REQUIRED EQUIPMENT LIST
• Other mandatory drugs:
– IV Nitroglycerine
Would require IV pumps to
safely administer
– What is included in …
ALL Advanced Cardiac Life Support Medications
*cardizem, diltiazem, isoproteronol, inderal, ACE
inhibitors, fibrinolytics
MINIMUM REQUIRED EQUIPMENT LIST
• Basic / EMT-Speciality / EMT-Volunteer
– What are roof hooks?
– For services giving medications (optional), what is
the need to carry Sterile Saline drops?
– Medications has a ** notation, but no clarifier
– Glucose should be ORAL glucose
Next Steps
• Open now for additional comments
• Summarize the ArAA comments and
suggestions on the Section of EMS forms
• Submit to the Section by Monday, December
17, 2012
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