Committee Approved Recommendations
December 16, 1999
Regulation of Emergency Medical Services:
Phase Two
Recommendations
1. Rates currently filed and approved by the Department of Public Health would remain in effect. Effective July 1, 2000, regulations concerning rate filing (Sec. 19a-179-21(f)) shall be modified to require only charging providers who wish to increase rates to submit complete financial information currently required by regulation. Rate increase requests could be filed at any time, but no more than annually. Detailed financial and operational information supporting the request would have to be filed for the time period from the provider’s last rate review.
Charging providers willing to stay at current rates would be required to file, by July 15 of each year, an audited summary financial statement, including total revenue, total expenses, emergency and non-emergency call volume, and a written declaration that no change in the current maximum rates has occurred.
2. By January, 1, 2001, the financial summary forms and the full rate request filings shall be on forms issued by the Department of Public Health. Further, if the department needs additional information pursuant to Sec. 19a-179-21(f)(2) of EMS regulations, DPH must specify the additional the financial and operational information it wants.
The regulations review subcommittee established by DPH to examine the rate-setting process shall review the regulations concerning rates and issue its report to the Department of Public Health by July 1, 2000. The health department shall seek to have the regulations revised through the normal regulation review process.
3. The Medicaid rate for ambulance services should be raised.
4. The determination of need process shall be streamlined by allowing providers the opportunity to operate any number of vehicles (i.e., ambulances, invalid coaches, and non-transport emergency vehicles) and any number of branches they believe is necessary to render adequate ambulance or invalid coach service. New services (for ambulance and invalid coach) and services requesting to charge would still be required to go through an initial DON process to prove a need exists before operating.
Providers shall continue to notify DPH of the number of vehicles they have in service each year and receive a permit for each vehicle in use. The department may consider the appropriateness of the number of vehicles when analyzing any application for a rate increase. If, during the normal course of a rate review, the department finds an excessive number of vehicles and branch offices, it may revoke authorization for those vehicles and disallow the expenses related to those vehicles and branch operations for rate determination purposes.
5. By January 1, 2001, the Department of Public Health shall collect and maintain data from the ambulance run form. Data points required to be submitted to DPH shall be uniform by all EMS providers. Providers shall submit copies of the run form information monthly via a method that accommodates needs of both providers and the department. The trauma reporting requirements shall be consolidated on this run form to satisfy both general EMS and specific trauma data fields.
By March 2002, and annually thereafter, DPH shall report on the following information which shall include, but not limited to:
The report shall compile the information and report it in an aggregated format by town – with towns grouped according to urban, suburban, and rural categories – and make the information publicly available, including through DPH’s web site. The department shall notify the Public Health Committee of the report’s availability.
If a provider does not comply with the submission of required data for a period of six months, or if DPH has cause to believe the provider knowingly and intentionally submitted incomplete or false information, DPH shall notify the provider and the towns served by the provider that compliance is mandatory. If full compliance is not achieved within the following quarter, DPH shall hold a hearing at which the provider would be required to demonstrate why the PSA assignment should not be removed.
In addition to EMS providers, each public safety answering point (PSAP) shall, beginning January 1, 2001, submit quarterly aggregated data on its EMS calls to the Office of Statewide Emergency Telecommunications (OSET), within the Department of Public Safety. The data submitted from PSAPS shall include all 9-1-1 calls where a medical emergency is involved. The aggregated data shall report elapsed time for dispatch -- from the time the call was received to the time the call was dispatched or transferred -- and shall be reported in fractile response times.
6. Beginning July 1, 2000, an allocation of no more than $250,000 annually from the surcharge on phone lines that cover the 9-1-1 system be made to finance data collection, maintenance and reporting for the emergency medical system.
7. All Public Safety Answering Points (PSAPs) be required to provide emergency medical dispatch (EMD) or arrange for EMD services to be provided to all callers requiring emergency medical services. Each PSAP or other entity performing EMD functions shall maintain an EMD program. The Office of Statewide Emergency Telecommunications shall provide oversight of EMD implementation.
Each EMD program shall have, at a minimum, the following characteristics: 1) use only trained EMDs to provide medical interrogation, prioritization, and pre-arrival instructions; 2) use a medically approved emergency medical dispatch priority reference system; 3) provide a continuing medical dispatch education program; 4) implement a quality assurance program that, at a minimum, includes the monitoring of EMD time intervals, utilization of EMD program components, and appropriateness of EMD instructions and EMD dispatch protocols; 5) employ a mechanism to detect and correct discrepancies between established protocols and actual EMD practice; and 6) provide for EMS physician medical direction.
In recognition of the initial start-up costs in providing EMD, program review staff recommends OSET reimburse PSAPs for the costs related to the initial training of dispatchers and for purchasing an emergency medical dispatch priority reference system. Regional communication centers (i.e., Consolidated Medical Emergency Dispatch – CMEDs) shall also be reimbursed for the initial training and card sets for EMD if they are providing this service for a PSAP. OSET shall approve for use in Connecticut any national or locally developed EMD course that meets the requirements of NHTSA National Standard EMD Curriculum.
A four-year phase-in for this requirement is recommended. This will allow OSET at least one year to select appropriate training providers and establish an administrative mechanism to oversee the training. PSAPs would also decide whether to provide EMD themselves or establish a system where callers could be transferred to an EMD provider. In addition, committee staff recommends all PSAP dispatchers performing EMD be trained over a three-year period. PSAPs must provide an affirmative statement to OSET that they either have in place all the elements of an EMD program identified above or transfer to a provider who does within that four-year time frame. This affirmation must be received before any reimbursement from OSET takes place.
8. Department of Public Health leadership communicate to department employees and the regulated EMS community the department’s intention to discharge its regulatory and administrative responsibilities in the EMS area diligently and uniformly.