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[Guest guest]

National Association of State EMS Directors

201 Park Washington Court

Falls Church, Virginia 22046-4527

Re: National EMS Scope of Practice Model Comments

Dear Amy,

On behalf of the Emergency Medical Services Association of Colorado

representing over 3,200 emergency medical services professionals and 59

organizations providing emergency medical services throughout Colorado we

appreciated the opportunity to review Draft 1.0 of the National EMS Scope of

Practice Model. We respectfully ask you forward the following comments to

the working group for consideration as the document is revised:

1. We strongly agree that occupational licensure of EMS professionals is the

appropriate way to credential our providers. As you may be aware, Colorado

has recently experienced scandals in both our EMT certification program at

the state level, and with professional misconduct allegations concerning one

of our state's most high profile EMS agencies. As such, we are in the

process of re-building our Credentialing and oversight processes statewide.

We strongly agree that protection of the public, and corresponding public

trust of EMS providers, is paramount. We agree that licensure is therefore

the best approach.

2. We agree with the proposed EMS provider naming convention as proposed. We

have no comments concerning the Emergency Medical Responder or Emergency

Medical Technician categories. While likely contentious, we also agree with

the standardization of the " paramedic " title at the upper two levels is a

good idea. Overall, we believe our historical desire to apply differing and

lengthy titles to minute differences in training serves only to make our

profession more obscure to the public. We should spend less time arguing

over titles and more time standardizing terminology that the public can

easily grasp. Paramedic is an excellent of example of a standardized term

reflective of our profession.

3. While we agree with the proposed naming conventions, we would ask the

committee consider that the current the EMT-Intermediate 1999 scope level is

currently the backbone of ALS care throughout much of our rural state, and

also reflects the most utilized skill set of urban first response and

transport providers. We would ask the committee strongly consider the 1999

DOT EMT-Intermediate curriculum, especially in terms of training length and

CE recommendations, to be considered the basis of the new Paramedic level.

Substantial increases in training requirements at this level could

substantially impact the availability of effective ALS care in rural areas,

and lead to the inclusion of skills at the paramedic level that would seldom

be utilized in the urban setting.

4. Finally, In regards to the Advanced Practice Paramedic, we believe there

is a substantial disconnect between the narrative description and the

permitted skill set as written in the draft. Primarily, the narrative speaks

almost exclusively of the Advanced Practice Paramedic's role in assisting

with disposition of EMS patients, while the permitted skills speaks almost

exclusively towards skills sets that would be essential in the transport of

critically-ill patients between facilities. We believe both of these

concepts have merit, and deserve to be reflected in both the narrative and

permitted skills table. In particular, our state, and a number of others,

are actively involved in creation of a " Critical Care Paramedic " level aimed

toward inter-facility transport that could easily be adapted to match the

proposed Advanced Practice Paramedic. We further believe this level must

also integrate well with current activities in the air medical community

related to the Certified Flight Paramedic, or FP-C certification, that is

becoming increasingly popular in our state. Finally, we would ask the group

consider both the permitted skills, and educational transition issues ,

related to the creation of this new level to insure uninterrupted and high

quality ground and air-medical transportation by existing paramedics and

programs.

We thank you for the consideration of these comments and would be happy to

provide any additional clarification if necessary. Please thank the group

for their excellent work so far and best of luck with future revisions.

Sincerely,

Caffrey, MBA, NREMT-P

President

Caffrey

Director

Summit County Ambulance Service

P.O. Box 4910

227 County Road 1003

Frisco, Colorado 80443-4910

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