The Executive Directors of Virginia’s eleven Regional EMS Councils submit the following comments and recommended changes to the proposed EMS Regulations Governing Regional EMS Councils and the Rescue Squad Assistance Fund:

12-VAC-5-31-2330, B, 1, ii: Add “consistent with these regulations” to the end of this section to clarify the source of future standards.

12-VAC-5-31-2330, B, 1, v: Change “plan” to “statement” to clarify that the Scope of Services is not a plan but rather a document describing the qualifications of the applicant.

12-VAC-5-31-2330, B, 1, viii: After “must show” add “revision date of” to clarify that the intent of this regulation is to have council policies and guidelines that include a modification page or other indication of when previous document revisions were made and not a collection comparing language of all past policies or guidelines.

12-VAC-5-31-2330, B, 1, x: The Virginia Regional Directors Group feel localities should have an opportunity to submit comments regarding an application for EMS Council designation, but not require them to do so.  Recommend substitute wording for this section as follows: “x. Locality Support - A copy of notification provided to each city and county in the applicant's proposed geographic area within 120 days of the date of the application that the organization or person is seeking a three-year regional EMS council designation and requesting optional local government comment regarding the applicant's abilities to the Office of EMS.”

12-VAC-5-31-2330, B, 2: Recommend to delete this item as it is duplicative of directory requested in 5-31-2330, B, 1, ix and otherwise insignificant in a region’s application to manage a region designated by the Board of Health.

12-VAC-5-31-2330, B, 4: Add to the end, “if applicable” to allow for an applicant which has not previously performed as a regional EMS council.

12-VAC-5-31-2680 through 5-31-2720: Recommend deletion. Specific plans, other than the regional EMS plan required by Code, may be required by OEMS through its performance based contract with a regional council (5-31-2790), but the need for specific plans may vary over time and should not be locked in regulation.

12-VAC-5-31-2780: After “monetary” add “and qualified in-kind services” as an allowable match, and add language that would allow OEMS to develop a list of qualified in-kind services of items that would normally be required to operate an office.

12-VAC-5-31-2795, D: Include “The OEMS may require” an independent audit upon change of Executive Director which would allow discretion by the state in cases where financial issues are a concern but would otherwise not obligate a council to incur expensive and duplicative auditing upon routine Executive Director changes.  Also consider that if the Office of EMS does require an audit when the Council’s Executive Director leaves, and the Executive Director has no access to Council funds during the course of execution of duties associated with her or her role in the council operations, then the Office of EMS will fund the additional audit.

12-VAC-5-31-2900, C: Amend to allow advance payment to awardees. Regional councils, as well as many other small rescue squads and other potential awardees, do not necessarily maintain surplus cash balances to advance funds on large grant projects. The ability for a full or partial advanced payment from grant funds would facilitate large project purchases and not unduly stress a small organization’s finances. Such advances could be reconciled based on actual costs demonstrated by invoices.