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."