Feedback Form for the Draft National Framework Document

The project team thanks those that have provided input through the public survey and the meetings in California, New York, and Washington, D.C. We also appreciate your continued participation and input on the recommendations for National Framework Document for Promoting Innovation in EMS. Please scroll down as you fill out the form and when you are finished, please click on the blue "DONE" button at the bottom.

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* 2.
EMS agencies should provide their medical director with dedicated time, sufficient resources, and well-delineated authority. Effective and innovative emergency medical services depend on meaningful integration of a well-trained medical director into all aspects of policy development and service delivery - including operations, finance, quality assurance, and training and education.

Rationale: The medical director is uniquely positioned to lead the transformation of pre-hospital emergency medical services from its limited role into a larger and more coherent framework from which to address the entire spectrum of out-of-hospital health care.  It is often the case that the medical director is inadequately resourced, lacks sufficient integration into the decision-making processes of the EMS agency, and that they are unable to meaningfully participate in policy development and strategic planning.  Thus, many medical directors find themselves not being at the table when an EMS agency might have the discussion about new models of care or while planning for the future. The decision-making team in any EMS agency needs to include the Medical Director.

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* 3.
Agencies and their medical director should encourage collaboration and coordination with expertise from a multidisciplinary team of specialists and experts in both indirect and direct oversight as well as protocol development.

Rationale:  Innovation in the age of an interconnected healthcare system with a focus on population health outcomes will require collaboration.  Every EMS agency should be encouraged to collaborate across a host of disciplines. A part of promoting innovation is allowing physicians not traditionally involved in ems to participate and to improve integration with the larger healthcare system.  This may add a layer of complexity to the oversight of an EMS system that the agency medical director must adapt to, and the EMS medical director should be a key advocate for collaboration with other parts of the healthcare system.  

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* 4.
Evidence-based consensus guidelines and best practices should be incorporated into EMS system protocols, so as to establish minimum acceptable standards of care. It is above that foundation at which agencies can and should seek to test innovative models of care.

Rationale:  While it is the clear and expressed purpose of this document to promote innovation at the local level, an agency should not prioritize the development of new modalities of providing care over the implementation of known best practices and evidence-based care in their system. In most communities, it will take as much or more of the same entrepreneurial spirit, leadership and collaboration to move current EMS practice to what has been proven more effective elsewhere than it will to test some new model that is as yet unproven. 

Today, there exists a significant amount of unjustified variation in the quality of care delivered in EMS.  This has been most well described in the cardiac arrest literature but is true across most clinical conditions.   Several evidence based consensus guidelines have been developed which help to establish basic standards that every EMS agency should seek to achieve.

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* 5.
State Medical Directors should both work to remove barriers and facilitate innovative processes among high performing EMS systems within the State.

Rationale:  There is significant variability between states in the relationship between the state and EMS physician leadership.  Although the advantages of a dedicated State EMS Medical Director are well described, and several national organizations have joined forces to emphasize both the role and importance of this position (“Role of the State EMS Medical Director” Position Statement, NASEMSO, ACEP, NAEMSP (Appendix xx)), there are still 13 states that do not have a State EMS Medical Director.  Some states have committees with a physician as a chair (WA) and others have no medical director because of lack of funding.  Among states that have a dedicated medical director, in 18 of 37 states, they serve in an advisory capacity.

Within a discussion about promoting innovation in EMS, it is not only important to have this position, but also to enable and empower the individual with appropriate support to perform clearly defined responsibilities.  He or she must have the independence, authority, and resources needed to engage not just EMS agencies, but also other governmental and non-governmental stakeholders.  It is of paramount importance that the individual be effective in the role, and therefore the selection process for appointment to such a position ought to be transparent and merit-based.

The role should not be limited to bureaucratic responsibilities or in any way serve as an impediment to innovation.  Rather, the State EMS Medical Director, much like the State Office of EMS, should embrace their role as a facilitator, helping to spur new collaborations and move the machinery of state government to authorize new programs and enable sustainability of successful ones.

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* 6.
Medical Director’s role in fostering innovative EMS should be patient-centered and not based on conflicting interest of a hospital, health plan, or an EMS agency.

Rationale:  EMS is an industry that lives at the intersection of many important societal and patient functions.  As such, it is an industry that is constantly balancing multiple competing interests, whether it be the interest of one patient against the interest of the community or population, or the interest of the hospital or health plan versus the interest of the EMS agency, or the interest of a public safety agency versus the interest of a private commercial agency. 

As is the standard in the rest of healthcare, decisions should be made in the best interest of the public community, and where that is unduly influenced by personal or professional conflicts of interest, these conflicts should be disclosed.  Wherever possible, the conflicted individual should recuse himself or herself. 

Potentially, good ideas and new innovations can be stifled in some jurisdictions because a medical director or other party in a leadership position are concerned about a potential adverse effect on their interest.  For example, the most common example in current trends are ED physicians or administrators being resistant to EMS transport to alternative destinations out of fear of loss of revenue.

§  ACTOR should also include: EMS providers, EMS management

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