Does this regulation on its own contribute to the improvement or decline of mortality rate versus contributing to the improvement or decline in EMS responder safety.  Does it make sense to apply this same requirement to both a PSAP call for service of a Blood Pressure Check  and one for Uncontrolled Bleeding, or Cardiac Arrest?

The decision to run lights and siren ("hot") to a call for service is a calculated risk based on information obtained and supplied during each individual call.  That calculation should not be unduly influenced by a single arbitrary response threshold.

Instead, OEMS should be promoting an EMS Quality Management System that supports continuous process improvement with respect to delivery of patient care.  This should include measuring and assessing  all facets of delivering EMS care, such as:

·         Proper triaging of PSAP calls for service to determine resources required (EMS response, Nurse referral, etc.)

·         Properly prioritizing EMS response via an EMD system

·         Measuring and reviewing EMS response against thresholds established for each priority, not a single catch-all threshold

·         Measuring and reviewing delivery of care and patient outcome for EMS responses.

This regulation as written is designed to reward systems that set an arbitrary high number and punish those systems that try to be more aggressive, and should be withdrawn unless a prioritization scheme is also enforced to properly categorize PSAP calls for service.  Only then should enforcement of thresholds  for each priority be considered.

It does not make sense to enforce a single attribute outside of a coordinated management system.