record of high rates of utilization of emergency services, or caring for patients and providing support services within critical access hospitals. Rather than placing firm restrictions on the scope of EMS practice, legislative and regulatory bodies should ensure that EMS agencies have the freedom to work with other public health and public safety authorities to maximize the health of their communities, while maintaining appropriate guidance to protect patient and provider safety. In particular, laws and regulations should be drafted or amended to consider provision of care at and in transport to destinations other than emergency departments. Alternate transport could be considered in circumstances where typical transport resources are unavailable. The third principle is that “scope of practice” ought not be strictly defined in statute so as to preserve flexibility of regulatory entities responding to emerging needs of the population being served. By placing it in regulation, or tied to education, it becomes inherently more flexible and adaptive to changing community needs, changes in technology, or the availability of new medications and treatments. Where scope of practice is already strictly defined, legislative and regulatory bodies should examine and address obstacles to innovation or unmet societal needs that result from current policy. While establishing practitioner levels or delineating the services they provide, states should recognize the floors set by nationally recognized minimal standards for EMS. 37 However, state regulatory bodies may build upon that floor while considering the unique needs of their patient populations with respect to the burden of disease and access PRACTITIONER LEVELS & SCOPE OF PRACTICE
to health care and transportation, the degree of physician oversight available, patient safety considerations, and whether they wish to support a higher standard of care. ENABLING RAPID CYCLE INNOVATION The fourth principle is that states should adopt a regulatory model that also allows communities to approve and conduct pilots quickly and evaluate the success of innovations that stem from grassroots initiatives. States should empower their regulators with the appropriate flexibility to investigate promising innovations while balancing the need to protect the public’s safety and ensuring a viable EMS system. Useful examples can be provided by the recent experience of several states trying to pilot community paramedicine programs. In California, it was determined that community paramedicine programs were not authorized under existing statute. Fortunately, they were able to make use of an existing waiver provision to allow up to 12 pilot programs. Unfortunately, in order to become permanent, the California legislature will have to review the results of the pilot program and take action to either enable community paramedicine or somehow extend or make them permanent. In Maine, the legislature had to pass a bill in order to authorize up to 12 pilot programs. 38 While this should certainly be heralded as a success for the EMS community, the difficult task of passing legislation is too high a bar to merely test a new idea. The pace of innovation will be greatly improved if the process of launching a pilot program could be streamlined from a regulatory standpoint. Furthermore, a pathway to long-term authorization without legislative action should be established. One potential methodology for achieving this would be to place greater authority in the State Office of EMS.
37 “National EMS Scope of Practice Model.” National Highway Traffic Safety Administration. Last modified February 2007. https://www.ems.gov/education/EMSScope.pdf. 38 Karen Pearson, George Shaler “Community Paramedicine Pilot Programs: Lessons from Maine.” Journal of Health and Human Services Administration 40, no. 2 (2017).
MOUNT SINAI HEALTH SYSTEM | UNIVERSITY OF CALIFORNIA, SAN DIEGO
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