(EMTALA), misapplication of the Health Insurance Portability and Accountability Act (HIPAA), and certificate of need policies. Strategies to create a more favorable regulatory landscape for innovation include the crafting of new legislation that: 1) ensures the provision of EMS as an “essential service” in all communities; 2) maintains flexibility of practice locations or transport destinations available to EMS providers; 3) delegates the process of defining practitioner levels and “scope of practice” to State EMS regulators rather than the legislature; 4) creates a process to enable rapid cycle innovation and conversion of successful pilots into permanent policy; and finally, 5) that provides comprehensive protection for the performance of quality assurance activities including those that cross organizational boundaries (e.g. hospital and EMS agency). Other strategies to promote innovation include using the state regulatory authority over health insurers to require reimbursement for innovative models of EMS care, addressing EMTALA concerns through hospital by-law amendments or regionalized protocols, enabling portability of licensure, and relaxing certificate of need policies. FINANCE Financial barriers include the requirement by most public and private payers of transportation in order for an EMS claim to be reimbursed, difficulty demonstrating value and patient outcomes, lack of business acumen amongst EMS managers and leaders, and the perceived prevalence of fraud and abuse within the medical transportation industry. Strategies to enable innovation include the decoupling of payment from transportation through the pursuit of pay for performance and bundled payment arrangements, engaging community stakeholders for whom EMS can provide value, creating and pursuing State Medicaid initiatives, focusing on reporting and improving
on emerging quality measures, and embracing telemedicine as an avenue to both improve care and obtain better reimbursement. Other strategies include investments in improving the business capabilities of EMS systems and EMS leaders, using grant opportunities to overcome start-up costs, and taking steps to combat fraud and abuse in order to boost the reputation of the industry and profession. EDUCATION Educational barriers to innovation include the relatively low entry requirements or educational requirements of the profession, the variability in quality of education and instructors, the difficulty in defining or measuring competence, and the lack of financial incentive for paramedics to pursue additional education. encouraging or rewarding paramedics who pursue higher education, developing career ladders and specialty practice opportunities, improving the quality of education through greater preparation of instructors and enhancing educational models and techniques, and increasing provider access to clinical feedback and patient outcomes. REGIONAL COORDINATION Barriers to regional coordination include the hyper-fragmentation of EMS systems and agencies, the high degree of variability from one agency or system to another, and the tension between standardization and local autonomy. Strategies for improving regional coordination include measuring and reporting on quality both by agency and across regions, collaborating on initiatives to improve outcomes across a region for acute life-threatening conditions, supporting regional preparedness, public or population health initiatives equally, regardless of agency type, pooling data to improve analytics or research across a region, exchanging data via a health Strategies to overcome these barriers include raising the bar on educational requirements,
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MOUNT SINAI HEALTH SYSTEM | UNIVERSITY OF CALIFORNIA, SAN DIEGO
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