Virginia Regulatory Town Hall
Agency
Virginia Department of Health
 
Board
State Board of Health
 
chapter
Virginia Emergency Medical Services Regulations [12 VAC 5 ‑ 31]
Action Amend current regulations to include new regulations as a result of legislative changes and changes in the practice of EMS.
Stage Proposed
Comment Period Ended on 3/19/2010
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2/24/10  4:18 pm
Commenter: Stephen Simon, Roanoke County Fire and Rescue Deparment

12VAC5-31-1552 and 12VAC5-31-1401 EMS Education Coordinator Re-Certification Process
 

EMS Education Coordinator Recertification Process

I have a concern that the language in the new regulation concerning 12VAC5-31-1552 does not clearly state that the recertification test can be waived by the OMD.  This topic has been discussed at length at the last two EMS Symposiums (ALS/EMT Instructor Updates).  As by state statue, all EMS Certifications that are up for renewal which require a test to be re-certified can be waived by the Operational Medical Director if all other recertification requirements have been met.  I recommend that 12VAC5-31-14010 GENERAL RECERTIFICATION REQUIRMENTS be referenced under 12VAC5-31-1552 so all EMS Education Coordinators realize that they do have the option to have the test waived if their medical director desires to waive their test.

12VAC5-31-1552 is very vague and based on the OEMS Committee meetings that discussed this issue it was apparent that a minority of the committee wanted to have more control over who could instruct EMS Certification Courses in Virginia and the current proposed language may lead some OEMS Officials to believe that the recertification testing wavier that an OMD can approve would not apply to the EMS Education Coordinator. 

My second suggestion is to have the term EMS Education Coordinator referred to with all of the other EMS Certifications so their will be no mistake that the EMS Education Coordinator’s re-certification test can be waived if the EMS Education Coordinator’s OMD desires to do so and the EMS Education Coordinator has met all other requirements.

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CommentID: 13125