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Letter to NASEMSD
08/10/2005
November 15, 2004

Ms. Amy Starchville
c/o NASEMSD
201 Park Washington Court
Falls Church, Virginia 22046-4527

Dear Ms. Starchville:

I am writing to comment on the National EMS Scope of Practice Model (Draft 1.0). I appreciate the efforts of your organization, NHTSA and HRSA in attempting to establish a national standard for EMS response personnel and systems and agree with the concept and need. I am concerned about contradicting the very basis of this project as stated in the Introduction Summary - 'It is important to preserve the best of what is working well within EMS practice…'

The description and proposed practice of the Advanced Practice Paramedic (APP) is something other than a paramedic. That appears to be the wrong title because it is describing a Physician's Assistant (PA) or Nurse Practitioner (NP) with an emphasis in Emergency Medicine. By its very definition (in this document), the APP will not be in the 'normal' EMS setting (pre-hospital EMS), yet it is restricting several life-saving airway management skills to that position and taking them out of the pre-hospital EMS setting. That is the most glaring example of not preserving what is working well within EMS practice.

Totally missed in this document is the Critical Care Transport segment of pre-hospital EMS. Critical Care trained (and in some cases certified) paramedics and existing APPs presently work on ground and air critical care transport units, usually teamed with a Critical Care trained and/or certified RN. The need for those specialty paramedics will not go away nor will the APP (as proposed) fill that need.

I've also noted that every level of EMS provider, with the exception of the APP, is '…not prepared to independently make decisions regarding the disposition of patients.' In practice, regardless of intentions, it is often necessary to make such a decision. Usually it is the result of an obviously ill or injured patient, who is of sound mind making an informed decision to refuse your services. In those cases, it would seem appropriate to have the ability to make suggestions or recommendations in the best interest of the patient.

Whatever the final definitions and number of paramedic levels may be, I would question the requirement of a Bachelors degree or higher education level for pre-hospital EMS personnel (may be appropriate for PA or NP). That thought is based on more than 25 years of observing the constant efforts, at local, state, and national levels, to require all RNs have a Bachelors degree education. Though it may happen in the future, it has not yet, and it apparently has not prevented high-quality nursing care from many, many non-Bachelors degreed RNs.

Thank you for the opportunity to comment on this draft, and please let me know if you need any clarification of these comments.

Sincerely,

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