Health, Health Systems Improvement, Emergency Medical Services

Rule R426-12

Emergency Medical Services Training and Certification Standards

Five-Year Notice of Review and Statement of Continuation

DAR File No.: 32855
Filed: 07/29/2009

NOTICE OF REVIEW AND STATEMENT OF CONTINUATION

Concise explanation of the particular statutory provisions under which the rule is enacted and how these provisions authorize or require the rule:

Section 26-8a-302 authorizes the Emergency Medical Services (EMS) Committee to establish initial and ongoing certification and training requirements for emergency medical services personnel and requires the Department to develop, conduct and authorize training and testing for emergency medical services personnel, and to certify EMS personnel.

Summary of written comments received during and since the last five-year review of the rule from interested persons supporting or opposing the rule:

In early 2007, a rule change was proposed and made effective on 07/16/2007. Comments were made during the public comment period by Hunter Finch, Governor's Office of Planning and Budget. He stated that it appeared that a citation was incorrect in the rules. This was later changed with a nonsubstantive rule change. Comments were made by Ernie Williams, EMT Coordinator, Snow College: He stated that the word "bieannually" is misspelled and should be "biennially". This was later changed in a nonsubstantive rule change. In September 2008, a proposed rule change received the following comments: Michelle Andersen, Summit County, stated that she thinks "EMTs should have experience before advancing to the next level. Experience is the best teacher, perfects skills on real people, and confidence builder." Dana Cox, Training Officer, Paramedic, stated "The changes that eliminate the required field time for advanced level of certifications is a mistake." Russ Malone, Course Coordinator, SLCC, stated "I have seen first hand the poor patient care given in the field by EMT-Is that have no experience. I know of agencies that have had trouble and had to fire paramedics that passed their paramedic course, but had no field experience. The lack of experience is a critical problem that needs to be addressed." Russ also stated: "To eliminate the one year requirement can only hurt the quality of our EMTs. Let's not shoot ourselves in the foot, lets leave the one year requirement in place." Kerry Dayley, Newton First Responders stated that he approves of the changes. Merilee Mecham, EMS Instructor, stated they sounded great to her. Chad Tucker, Ogden Fire stated that he supports the changes and hopes they pass. Von Johnson, Uintah Basin Medical Center (UBMC), stated he thinks the changes are good. "The only comment he has is regarding TB tests. The rule says that they must submit a statement from a physician confirming the applicant's results of a TB test within one year prior to completing the course. I think that it should just say that they submit results of a TB test. We do TB tests here at the hospital and they are never read by a physician usually by an RN." Karla Rickards, Unified Fire Agency stated: "The only problem I see at first reading is in R425-12-505(4) where it states that if a paramedic fails the recertification written or practical . . . there is no longer a requirement for recertification written, right? " A letter was also received signed by 61 people stating: "The undersigned persons are in support of the amendment to the rule by which the EMT-Basic may continue to the intermediate level without the one year field experience." Von Johnson, UBMC stated: He does not believe that TB tests need to be read by a physician, but could be read by an R.N. Chad Tucker, Ogden Fire Deputy Chief stated: "I support the changes and hope they pass. I am particularly concerned with the change in the internet recert hours. Changing this to 50 hours will greatly assist my department in staying within their districts for training". Merilee Mecham, EMT, Test Team -- Thanks for keeping us in the loop. Kerry Dayley, Newton First Responders, stated: I approve of the changes. Kim Jensen, K & B Training -- "I do think that it would be helpful for EMTs to be able to go right to Intermediate, as it is difficult to find work here in this state as a basic". Mike Snow -- "I have no issues with the changes". Jeff Grunow -- Weber State University -- "We agree with all changes. This change was not made effective. We are in the process of having new changes out for public comment".

Reasoned justification for continuation of the rule, including reasons why the agency disagrees with comments in opposition to the rule, if any:

The rule establishes the minimum certification and recertification requirements for EMS personnel and must be continued to protect the health and safety of the citizens of Utah who receive pre-hospital care. The Department does not agree with some of the comments that were made above, but has re-worked the rule and it is out for public comment at the present time. The 1-year requirement will also be deleted in the rule change, because it was felt that there are more people in favor of the 12-month deletion than opposed. It is also felt that the Intermediate training is needed in order for a person to get a job working as an EMT for an agency. Most agencies will not hire Basic EMTs, but will hire Intermediates. In the case of the IA and Paramedic levels, it would take a person approximately one year to complete these additional trainings, and people get experience while they are taking the courses.

The full text of this rule may be inspected, during regular business hours, at the Division of Administrative Rules, or at:

Direct questions regarding this rule to:

• Leslie Johnson at the above address, by phone at 801-273-6636, by FAX at 801-273-0744, or by Internet E-mail at lesliejjohnson@utah.gov

Effective:

07/29/2009

Authorized by:

David Sundwall, Executive Director