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Virginia Regulatory Town Hall
Virginia Department of Health
State Board of Health
Virginia Emergency Medical Services Regulations [12 VAC 5 ‑ 31]
Action Amend current regulations to include new regulations as a result of legislative changes and changes in the practice of EMS.
Stage Final
Comment Period Ends 10/9/2012
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10/9/12  9:48 pm
Commenter: Doug Monaco, Chief Little Fork Volunteer Fire & Rescue Co., Inc.

12VAC5-31-610. Designated emergency response agency standards

It appears as if the intent of this section is to coerce EMS agencies into providing a plan for responses if they cannot staff a unit.  We support this effort.

However, requiring a local standard that requires an organization to develop fractal times is another unfunded state mandate that has not been thought through.  This time frame also includes the dispatch times.  Our dispatch center is not set up to calculate these times and developing the software to produce these numbers will cost our taxpayers thousands of dollars.

We can use “Image Trend” to produce the numbers but several issues arise when you look at the variables.

-          Based on the wording, it appears it is necessary to set up a time interval the EMS agency complies with on a 90% basis within its primary service area (as described in the wording, that is, a time frame in which the EMS agency can arrive at the scene of a medical emergency in 90% or greater of the calls).

-          First, I would assume the bottom of the interval would be 0 minutes or it would be possible to eliminate some response times at the bottom end of the interval and eat into your 90% quota.

-          Second, taking an average of the response times and setting that number as the upward bound of the time interval will not satisfy the requirement.  This interval would represent where you would anticipate 50% of the response times for an agency to be within, not 90%.

However, it is important to note that this will not be 100% accurate and it would still be possible to not meet that target based on variance in each year's data.  It may be more accurate to pick a higher percentile or set up a confidence interval around the 90% time response to determine a better estimate for the upper bound (this would be more advanced but not difficult). 

An EMS agency in a town/city and/or with the majority of their primary service area within a smaller distance will have a better response time interval than agencies in rural areas.

External factors such as weather, traffic, etc. would produce anomalies in the response times.  Depending on the time basis for which the 90% will be evaluated, this could greatly impact whether the agency is in compliance. For example, if you have to meet the 90% each month, a snow storm in February would greatly impact February's responses times but if you have to meet the 90% over the entire year, a snow storm in February would have less of an impact.

If this is going to be shown to the public, the upper bound of the 90% interval may not be what the public is used to seeing and may raise questions.  If the public is used to seeing averages, the upper bound of the interval is going to be much larger than normal. The public will be confused over these numbers, we have already seen the confusion that has started with some public officials who have quickly reviewed this and began using the term “average response times”—which (again) is not what is required by this standard.

Another item within this section is that an annual review documenting exceptions to the response capability.  This is unclear as to what defines an exception.  Are we required to review every call that we ran during a major natural or man-made event or every time that we had to stage for law enforcement for 10 to 20 minutes?   Our volunteer agencies spend more than enough time on QI/QA programs, incidents, training and all other administrative activities. Now we are expected to produce another annual report, review it with the OMD and the local government.  More time expended and for what? What will be accomplished?

The following part of this standard is all that is needed ……………………………..

12VAC5-31-610. Designated emergency response agency standards

A. A designated emergency response agency shall develop or participate in a written local EMS response plan that addresses the following items:

1. The designated emergency response agency shall develop and maintain, in coordination with their locality, a written plan to provide 24-hour coverage of the agency's primary service area with the available personnel to achieve the approved responding interval standard.


CommentID: 24277