The new EMS Educator requirements are excessive.  They require EMS Educators to obtain an additional 12 hours of educator specific education EVERY recert period, this is in addition to the 50 hours already required to teach in 2 years.  That is a BRAND NEW UNFUNDED MANDATE, the cost of such classes is a financial burden to already budget-poor EMS systems/governments & EMS educators who will likely have to pay for such classes on their own, out of pocket, taking time off of work, especially in the volunteer sector of EMS.  They will be difficult classes to find, as they are RARE at best at the present time.  The second portion of this specific section of the regulations which I am gravely concerned for is the REQUIREMENT that EMS educators MUST TEST every recert time in order to keep serving as such.  NO OTHER HEALTH OR ALLIIED HEALTH PROFESSION REQUIRES THEIR EDUCATORS TO TEST aka "sing for their supper" every 2 to 4 years.  This is also not a requirement for any of the other public safety sector (fire, law enforcement, etc) Instructors to do this so why is it now becoming a regulatory requirement for EMS Educators? UNFUNDED MANDATE, HUGE EXPENSE, TRAVEL EXPENSE TO TEST TO RECERTIFY, TIME OFF FROM WORK TO DO SO, AN EXCESSIVE MANDATE THAT HAS NO RHYME OR REASON BEHIND IT.  Where is the data to show this is essential? If educators are not educating correctly now, there is a regulatory process available to OEMS/VDH to take proper enforcement actions against the specific instructor. Don't punish all for a few peoples mistakes.  If it's not broke, don't fix it.  Take swift action against the bad ones & keep the good instructors.  You're setting this up to be career-only instructor certification, shoving volunteer educators to the curb. UNFUNDED MANDATE.  UNACCEPTABLE, OVER THE TOP REQUIREMENT that is NOT NEEDED.

This section requires that educators attend 12 hours of instructor based education.  To the best of my knowledge there are no formal classes to complete this requirement.  Where do these classes come from and what quilifies?  Do we create our own classes and apply for CEUs through the same application process we have now?  ALso in this section is a reference to a recertification test to be completed each certification period.  Where does this test come from, who administers it and where do we take it?  The Virginia office of EMS has turned written testing over to the National Registry of EMTs since their test is validated.  Are we taking a test that is not validated?  NREMT does not have an instructor tes.  Who is going to pay for this testing, the taxpayer?  If so as a taxpayer I believe this is a waste of my money.

We will all agree that a drug and alcohol free workplace is worthy goal but the localities are struggling with layoffs and cutbacks so an UNFUNDED MANDATE like this will most certainly add to the already severe financial strain we are trying to cope with.

I would have to echo some of the previous comments that I have read regarding this proposed policy.  I for one, have no problem with the testing; randomized alcohol & drug testing is common place in the military and seems to work fairly well.   However, the military service branches are funded by a huge defense budget at the expense of the tax payers obviously.  So to get back on point, if each jurisdiction or locality is responsible for the funding of these test, I would have to vote against the testing.  Public Safety workers (specifically FIRE/EMS workers) are already getting by on the bare minimum, personnel in many cases are making less money than when they were hired due to inflation, health insurance increases, no cost of living raises etc.  Therefore I would have to disagree with this policy change due to the UNFUNDED MANDATE and pressure it would have on the localities that are already depressed due to our current economic situation.

Recommend the following underlined phrase be retained in 12VAC5-31-1140 (Provision of patient care documentation), paragraph B:

The signature of the prescriber . . . who assumes responsibility for the patient shall be included on the prehospital patient care report . . . , except when standing orders from the OMD allows the administration of the drug or procedure

The rationale for this recommendation is that in practice, the prescriber does not know or have the time to review what he is signing; he often never sees the patient associated with the report; he is almost always deeply engaged in other cases at the time.  Often, no prescriber is willing or able to make himself available to provide such signature, and waiting for such signature delays the EMS unit's availability for other cases.

It is well established that the barrage of constant interruptions sustained by such prescribers is strongly associated with increased medical error rates.  Deleting this critical exception actually represents a higher potential for patient harm than it does a potential for patient good.

In the specific case of interventions performed under standing orders, the signature provides no prescriptive value, since the standing orders already have the OMD's signature attached.

Please retain the above underlined phrase in 12VAC5-31-1140.

One thing I find missing (unless I overlooked it) from the existing and proposed regulations is the provision of care, specifically ALS care, from an ALS staffed and manned "zone car" when no ambulance is on scene, or even en route. The regulations address provision of care when an ambulance is not fully staffed, but fail to recognize that an independent ALS provider may be in the exact same situation where a "second attendant" may not be routinely present. In my current assignment, a rural County with four career/volunteer EMS agencies, I staff the "zone car" as a single ALS provider for part of my shift, and respond to meet a volunteer staffed ambulance IF THEY RESPOND. If they do not respond, then my partner from my Medic responds the Medic to meet me. This system design occasionally places the lone ALS provider on scene, possibly for an extended amount of time, acting without any EMS support personnel, yet not acting as defined in the regulations.

Thank you for removing the regulation that prohibits weapons in ambulances. Most EMS providers routinely carry a knife, many carry pepper gas or mace, and the decision to bar firearms should rest with the EMS Agency Director/employer, not unelected state workers.

I agree that the exception to obtaining a signature for standing orders should be retained.

Thank you for removing the regulation that prohibits weapons in ambulances. There is no reason for this regulation to be in place. Rather, it should be at the discretion of the local agency.

I support the removal of 12VAC5-31-700 #6

 Thank you for removing the regulation that prohibits weapons in ambulances.

 That is a decision that should be left up to the individual.

These comments reflect my personal opinion and are in no way to be construed as representative of the U.S. Navy or any other organization/institution with which I am affiliated.

1335 By having this section expire, it gives the appearance that there will be no enabling regulation remaining to maintain the state EMT-Intermediate level. Persons, providers, and organizations have been led to believe, at various public and provider forums, that the intermediate level will remain for the forseeable future. The EMT-I level is valuable; it is a method by which many volunteer and career organizations utilize to provide a higher level of care.

In the "Changes Made from Proposed Stage" of the Final Regulation Background Document:

Section 1565 Deletion of Inidividual Tuition Reimbursement. While perhaps 'rarely used' as described in the agency rationale, this portion of the EMSTF is a valuable enticement to encourage EMT's to begin training for a higher certification level. I have assisted numerous members of my career and volunteer affiliates in applying for and receiving these funds. On several occasions the reimbursement was denied because the individual reimbursement portion of ALSTF had already been exhausted for the current fiscal year, or we were told by OEMS staff that the fund had been exhausted and it was pointless to apply. This recruitment and retention tool should absolutely be retained in the regulations, and more emphasis and education regarding its availability provided to EMS providers and agencies. I'm sure individual applications are more administratively burdensome to process, but if the funds are consistently being utilized there is no justification to elminating the program.

Also, the section also seems to conflict with 1561 in the "All Changes in this Regulatory Action" section of the document, with the revised "EMS Training Fund" section which states, "a tuition reimbursement component has been established to help defray the costs associated with obtaining initial certification."

760 Consider updating frequencies to reflect narrow-banding pending requirements, or eliminate specific frequencies and reference the State Communications Plan.

These comments reflect my personal opinion and are in no way to be construed as representative of the U.S. Navy or any other organization/institution with which I am affiliated.

1552 Paragraph C, requirement for testing for EMS Education Coordinators. This is a new and potentially onerous requirement for active educators. While the Office's intent here is laudable and understood, successful conduct of multiple courses or C.E. programs demonstrates the Coordinator's familiarity with education program requirements and administrative processes. Suggest that in-person testing only be required for Coordinators with minimal teaching hours, Coordinators who have taught only C.E. versus initial certification programs, Coordinators with low certification pass rates, or some other screening criteria. Utilizing a screening criteria to identify Coordinators who are likely to have lapsed familiarity with program requirements will eliminate unnecessary testing costs for the state and unnecessary cost and inconvenience for active Coordinators.

The opportunity to comment is appreciated, and kudos to the OEMS and VDH on an overall very well done regulation update.

Please disregard the second paragraph in my comment titled "EMS Training Fund Individual Reimubursement".  The comment regarding the EMT Intermediate certification level is in error, and was based on my misreading of the draft and other comments/rationales.

Suggestion for the Town Hall Web site: a mechanism to edit one's own comments! 

I have several issues with this reg.  Who's paying for this unfunded mandate?  Who is paying for the time and expenses of the instructors who will be required to attain an additional 12-hours of "instructor training?"  As far as the additional instructor training, who is providing that, validating the material of it, and ensuring it's availability?  Oh, wait, AND we have to retest again every two years??  Seriously?  Lastly, why is OEMS considering mandating a requirement on instructors that exists nowhere else in VA's public safety community?  THIS REQUIREMENT IS NOT NEEDED!

Wrong execution of the right idea.  UNFUNDED MANDATE on agencies and localities.

I beleive that this section should be removed from the proposed regulations. This is an unfunded mandate passed down from the state once again. Localities are already working on tight operating budgets...why not throw more burden on them...

The following section should be unstricken from the proposed changes.

except when standing orders from the OMD allows the administration of the drug or procedure

This proposed change opens the door to requiring BLS reports to be signed by the attending physician. Furthermore, regulation regarding some treatments and procedures, Oxygen, oral glucose, even IV therapy (less drugs given), should not be regulated to the point requiring a physician signature. Isn't this what we are trained to do? 

As stated before consider updating the regulation to include narrow banding frequencies. 

Also consider moving VA to the Nation Wide EMS frequencies regarding HEAR radio communications. (155.340 - VMED28) 

The new EMS Educator requirements are excessive.  They require EMS Educators to obtain an additional 12 hours of educator specific education EVERY recert period, this is in addition to the 50 hours already required to teach in 2 years.  That is a BRAND NEW UNFUNDED MANDATE, the cost of such classes is a financial burden to already budget-poor EMS systems/governments & EMS educators who will likely have to pay for such classes on their own, out of pocket, taking time off of work, especially in the volunteer sector of EMS.  They will be difficult classes to find, as they are RARE at best at the present time.  The second portion of this specific section of the regulations which I am gravely concerned for is the REQUIREMENT that EMS educators MUST TEST every recert time in order to keep serving as such.  NO OTHER HEALTH OR ALLIIED HEALTH PROFESSION REQUIRES THEIR EDUCATORS TO TEST aka "sing for their supper" every 2 to 4 years.  This is also not a requirement for any of the other public safety sector (fire, law enforcement, etc) Instructors to do this so why is it now becoming a regulatory requirement for EMS Educators? UNFUNDED MANDATE, HUGE EXPENSE, TRAVEL EXPENSE TO TEST TO RECERTIFY, TIME OFF FROM WORK TO DO SO, AN EXCESSIVE MANDATE THAT HAS NO RHYME OR REASON BEHIND IT.  Where is the data to show this is essential? If educators are not educating correctly now, there is a regulatory process available to OEMS/VDH to take proper enforcement actions against the specific instructor. Don't punish all for a few peoples mistakes.  If it's not broke, don't fix it.  Take swift action against the bad ones & keep the good instructors.  You're setting this up to be career-only instructor certification, shoving volunteer educators to the curb. UNFUNDED MANDATE.  UNACCEPTABLE, OVER THE TOP REQUIREMENT that is NOT NEEDED.

Section 4 Staffing, Interfacility ALS staffing does not mention minimum level of provider be a paramedic, yet it is mentioned in Prehospital staffing. At a minimum the ALS staff attendant-in-charge should be certified at the paramedic level. These views are mine and do/may not represent those of my employer.

As President of the Virginia Citizens Defense League and its 5,000 members, we support REPEALING the ban on weapons in EMS vehicles

I support REPEALING the ban on weapons in EMS vehicles.

No one should be forced to give up a right just for empoyment, and to be disarmed and unable to protect yourself expecially when responding to a call is wrong.

The second ammendment should be respected.

As a concerned citizen and first responder, I support the repeal of weapons ban in EMS vehicles. I've personally been assaulted in an ambulance and had no means to defend myself. 

I support the repeal of the  weapons ban so that they can be carried by EMS personnel and be allowed in the EMS vehicles!!

I support REPEALING the ban on weapons in EMS vehicles

I support REPEALING the ban on weapons in EMS vehicles.  The right to protect yourself doesn't stop when you're on the clock.

I support REPEALING the ban on weapons in EMS vehicles

.

The men and women deserve the right to protect themselves in the sometimes dangerous situations they must face.  My son is a firefighter and EMS and I would certainly feel better if they have the ability to self protection. 

I support REPEALING the ban on weapons in EMS vehicles!

I support repealing the ban on weapons in EMS vehicles.  EMS personnel sometimes face uncertain and even dangerous situations, and they should not have any less access to their right to self-defense than any of the rest of us.

I support REPEALING the ban on weapons in EMS vehicles.

Thank you!

As a vounteer EMT in the State of VA I fully support the repeal of this ban, as it only protects us as emergency providers in hostile situations. This repeal will benefit rural EMS agencies tremendously as we arrive to violent scenes before law enforcement and it will avoid additional confrontations and difuse potential attacks on EMS personel. 

The life you may save by repealing this ban may be your local volunteer EMT who serves his/her community with unselfish dedication.

Thanks,

Alex Greene

I  SUPPORT THE RIGHT OF EMS PERSONNEL TO SELF DEFENSE.

I support repeal of the ban. First responders deserve the right to self defense . Their work is dangerous and often they arrive at crime scenes ahead of law enforcement. 

I support REPEALING the ban on weapons in EMS vehicles.  EMS personnel often reach a dangerous scene before the police and should be able to protect themselves and each other.

I support REPEALING the ban on weapons in EMS vehicles

I support REPEALING the ban on weapons in EMS vehicles

I support REPEALING the ban on weapons in EMS vehicles.

I support repealing the ban on weapons in EMS vehicles. First responders deserve better

Thank you for REPEALING the ban on weapons.

I support REPEALING the ban on weapons in EMS vehicles.

Thank you for REPEALING the ban on allowing weapons in EMS Vehicles. Our Medical Emergency Rescue personnel deserve the right to be able to protect themselves with the proper training. 

I support REPEALING the ban on weapons in EMS vehicles.

Brian Bresnan, Citizen

Sirs...with all due respect it seems illogical that somehow the current laws cannot trust emergency service personel to carry a firearm about their persons but we can entrust them to try to save our lives. It has been said that EMS folks may be the first ones on a crime scene. If I am the one laying in the middle of the street with a life threatening injury I would hope that the EMS would be available to prevent a subsequent attack by the bad guy trying to finish me off.

After 9-11 the big debate was whether or not it would be dangerous to arm our pilots. I remember wondering whether or not those opposed to arming pilots ever thought that if a pilot wanted to harm passengers in a commercial airliner, the pilot would not need a firearm. I believe we saw the answer to that question a year or so later on a commercial airline headed to the middle east.

The question is not whether or not EMS can be trusted with a firearm, the question is why aren't they being entrusted with a firearm?

I support repealing the ban on weapons in EMS vehicles. EMS work can be dangerous, especially when they arrive on the scene of a crime before the police do.  All innocent life is valuable and people should be able to protect themselves wherever they might go.