12VAC5-31-10 Definitions

“Advanced Life Support” or “ALS” 

While this change seems small it has the potential to cause serious liability for providers and ultimately cause inefficient use of resources in many EMS systems.   Currently ALS providers often perform an assessment of a patient and turn care over to BLS providers if no advanced evaluations (ECG) or treatments are indicated.  The change in definition seems to make this unacceptable.  This change should be eliminated or clarified to insure that ALS providers are not obligated to remain with patients if no ALS procedures or assessments have been performed.

12VAC5-31-210

Application of civil penalty is proposed as a potential enforcement action for ANY violation.  This is unreasonable.  Civil penalties should be imposed only for violations of a serious, repeated or willful nature.  Many other state agencies allow specific punishments for specific violations, but not for others. There is no need to give blanket authorization for civil penalties, which in the case of minor or accidental violations are unnecessary and will foster animosity between OEMS and the agencies they supervise.   

12VAC5-31-530

The change places an unreasonable burden on agencies.  Callsheets are often removed from long term storage facilities for the purpose of review, copying or transfer.  The change means that storage in a locked cabinet within an ambulance station will be a violation, as many older stations are not equipped with full sprinkler systems.  Additionally, it is impossible to guarantee that callsheets will always be stored in water resistant containers without incurring unreasonable costs.  The change to the regulation is unreasonable and makes storage of paper callsheets nearly impossible under the regulations, forcing all agencies to digitize their record keeping.  While digital record keeping will, and should be achieved in the future, it places too large a financial burden to implement this regulation immediately.  The existing regulation places a sufficient burden on organizations to insure the safekeeping of records.

12VAC5-31-900

Requiring personnel to notify the office of EMS within 15 days of a change in phone number or email address is both overly burdensome and unnecessary.   

12VAC5-31-1140

We support this section and believe it should remain as written.  Providing a callsheet 24 hours after a patient is delivered to the hospital is not ideal and should not be the target to which any agency aspires, but this regulation seeks to set a minimum, violation of which is actionable by OEMS, not a goal.  Although agencies should try to deliver detailed written report as soon as possible, call volume or technical difficulties may cause an agency delays in producing written reports.  A requirement that reports be delivered at the time of transfer may cause ambulances to remain at the hospital for extended time periods and delay responses to other patients in need.