1. From the Definition section:

"Critical care" or "CC" in the air medical environment is a mission defined as an interfacility transport of a critically ill or injured patient whose condition warrants care commensurate with the scope of practice of a physician or registered nurse.

"Specialty care mission" in the air medical environment means the transport of a patient requiring specialty patient care by one or more medical professionals who are added to the regularly scheduled medical transport team.

"Specialty care provider" in the air medical environment means a provider of specialized medical care, to include but not limited to neonatal, pediatric, and perinatal.

Physicians Transport Service is concerned that this definition is too limiting. Medicare recognizes that paramedics with additional training can transport critically ill and specialty care patients. There is concern that there are not enough nurses to supplement ground transport ambulances. Office of EMS should expand the critical care and specialty care provider to include paramedics with advanced training in a ground ambulance. Specialty care transports of critically ill patients should not be limited to the air medical environment, nor should paramedics not be able to reach the critical care level.

2. 12VAC5-31-1050. Scope of practice.

EMS personnel shall only perform those procedures, treatments, or techniques for which he is currently licensed or certified, provided that he is acting in accordance with local medical protocols and medical direction provided by the OMD of the EMS agency with which he is affiliated and as authorized in the Emergency Medical Services Procedures and Medications Schedule as approved by OEMS.

We think that the OMD of an agency is the best judge of the agencies capabilities and would like to see this section changed to read:

12VAC5-31-1050. Scope of practice.

EMS personnel shall only perform those procedures, treatments, or techniques for which he is currently licensed or certified, provided that he is acting in accordance with local medical protocols and medical direction provided by the OMD of the EMS agency with which he is affiliated.

3. 12VAC5-31-540. Personnel records

B. An EMS agency shall have a record for each individual affiliated with the EMS agency documenting the results of a criminal history background check conducted through the Central Criminal Records Exchange operated by and the National Crime Information Center via the Virginia State Police, a driving record transcript from the individual's state Department of Motor Vehicles office, and any documents required by the Code of Virginia, no more than 60 days prior to the individual's affiliation with the EMS agency.

Physicians Transport Service is concerned that as a private agency it will meet resistance from the Virginia State Police in receiving information from the NCIC.