----- Original Message -----
Sent: Friday, April 05, 2002 2:13
PM
Subject: Re: Higher Level (long)
Jim,
No offense taken and non intended to your
previsois note....
I agree many of the obstacles in place are
institutational.
All comments are intended to educate and not
offend.
I've not found any information on a SPECIFIC
hierarchy of medical positions
related to the EMT to RN discussion.
Much
of the information could only be described as the "Sprit" of
the
regulation.
What I have found exists under the Department of
Transportation (Illinois)
regulations. Under these regulations are
provisions that require EMS
agencies to maintain a relationship with a EMS
system as described in the
EMERGENCY MEDICAL SERVICES AND TRAUMA CENTER
CODE (77 ILL. ADM. CODE 515).
These regulations require the EMS system to
develop the medical protocols
that all members must function under From
EMT-B to EMT-P. These protocols
would also apply to Pre Hospital RNs* (see
below), functioning in a
prehospital setting. This regulation states
"A person currently licensed as
an EMT-B, EMT-I, or EMT-P may only practice
as an EMT or utilize his or her
EMT license in pre-hospital or
inter-hospital emergency care settings or
non-emergency medical transport
situations, under the written or verbal
direction of the EMS Medical
Director."
SECTION 515.550 SCOPE OF PRACTICE - LICENSED
EMT
Any person licensed as an EMT-B, EMT-I or EMT-P shall perform
emergency
and non-emergency medical services in accordance with his or her
level of
education, training and licensure, the standards of performance
and conduct
prescribed in this Part, and the requirements of the EMS System
in which he
or he practices, as contained in the approved Program Plan for
that System.
(Section 3.55 (a) of the Act)
A person currently
licensed as an EMT-B, EMT-I, or EMT-P may only practice
as an EMT or
utilize his or her EMT license in pre-hospital or
inter-hospital emergency
care settings or non-emergency medical transport
situations, under the
written or verbal direction of the EMS Medical
Director. For purposes of
this Section, a "pre-hospital emergency care
setting" may include a
location, that is not a health care facility, which
utilizes EMTs to render
pre-hospital emergency care prior to the arrival of
a transport vehicle.
The location shall include communication equipment and
all of the portable
equipment and drugs appropriate for the EMT's level of
care, and the
protocols of the EMS Systems, and shall operate only with the
approval and
under the direction of the EMS Medical Director. (Section
3.55(b) of the
Act) . This does not prohibit an EMT-B, EMT-I, or EMT-P from
practicing
within an emergency department or other health care setting for
the purpose
of receiving continuing education or training approved by the
EMS Medical
Director. This also does not prohibit an EMT-B, EMT-I, or EMT-P
from
seeking credentials other than his or her EMT license and utilizing
such
credentials to work in emergency departments or other health care
settings
under the jurisdiction of that employer. (Section 3.55(b)
of the
Act) A student enrolled in a Department-approved emergency
medical
technician program, while fulfilling the clinical training and
in-field
supervised experience requirements mandated for licensure or
approval by the
System and the Department, may perform prescribed
procedures under the
direct supervision of a physician licensed to practice
medicine in all of
its branches, a qualified registered professional nurse
or a qualified EMT,
only when authorized by the EMS Medical Director.
(Section 3.55(d) of the
Act)
Spelled out specifically are communications
procedures that state "
Protocols ensuring the voice orders via radio and
using telemetry shall be
given by or under the direction of the EMS Medical
Director or the EMS MD's
designee, who shall be either an ECRN, or
physician; and [contain] Protocols
defining when an ECRN should contact a
physician;"
These communications that include issuance of orders cannot be
handled by a
dispatcher or EMT-P.
It could be argued that a "ladder" of
responsibility does exist in this
situation.
Under these same regulations, flight programs are
regulated separately
under. SUBPART G: LICENSURE OF SPECIALIZED EMERGENCY
MEDICAL SERVICES
VEHICLE (SEMSV) PROGRAMS, SECTION 515.900 LICENSURE OF
SEMSV PROGRAMS
This section regulates medical direction, training, aircraft
and crew
requirements.Under these SEMSV Provisions it states
SECTION 515.940 AEROMEDICAL CREW MEMBER TRAINING
REQUIREMENTS
Except as provided for by subsection (b) of this
Section, each aeromedical
crew member assigned to a helicopter or
fixed-wing aircraft shall be
approved
by the Medical Director and
shall meet the following requirements:
Be an EMT-P, registered nurse
or a physician.
......
.....[requirements
truncated}
......
"For helicopter
programs:
There shall be at
least one single-engine
aircraft.
Each vehicle shall be
staffed with at least one EMS pilot and at
least
one
aeromedical crew member for
Basic Life Support missions. There shall
be
two
aeromedical crew members for
Advanced Life Support and critical
care
transports, one of which
shall be an R.N. or licensed physician."
The determinitation of ALS or critical care would
probably fall under EMTALA
regulations.
Through these statements it
appears the DOT has put in place a regulatory
statement for transport that
does place the RN at a higher level of
licensure for transport in relation
to ALS and critical care transports.
Also note under these provisions the transport RN
is functioning under the
supervision of a Physician and a SEMSV plan, much
the same as an EMT
functions in an EMS system.
It must be remembered that all transports are
further governed by HCFA, and
EMTALA regulations.
This is a
complex issue, governed by several diffrent sets of regulations
and
practice acts.
I hope this shed additional light on the
subject.
Again this is intended to educate... not
offend.
Tony Rehberg BSN, EMT-P
Additional information specific to Illinois can
be found at these sites.
The states of Illinois does provide a mechanism
for RNs to transition to the
pre hospital setting as noted
here.
*SECTION 515.730 PRE-HOSPITAL REGISTERED
NURSE
To be approved as a Pre-Hospital RN, an individual
shall:
Be a Registered Professional Nurse in accordance
with the Nursing and
Advanced Practice Nursing
Act;
Complete an education curriculum formulated by an
EMS System and
approved by
the Department, which
consists of at least 24 hours of classroom and
practical
training, including extrication, telecommunications, and
pre-hospital cardiac and trauma care of both the adult and
pediatric
population (Section 3.80(c)(1)(A) of the
Act);
Complete a minimum of 10 ALS runs supervised by a
licensed physician, an
approved Pre-Hospital RN or an
EMT, only as authorized by the EMS
Medical
Director;
and
Complete the Pre-Hospital RN application form as
prescribed by the
Department.
The EMS Medical
Director shall approve individuals meeting subsection (a)
of
this
Section as a Pre-Hospital RN for four years.
The EMS Medical
Director shall reapprove Pre-Hospital RNs every four years
if
the
Pre-Hospital RN:
Is a Registered Professional Nurse in
accordance with the Nursing and
Advanced Practice
Nursing Act; and
Has completed 120 hours of continuing
education, the content of which
shall
be consistent
with the System's continuing education requirements for
EMT-Ps; and
Has a current CPR completion card that
covers:
Adult one-rescuer
CPR,
Adult foreign body airway obstruction
management,
Pediatric one-rescuer
CPR,
Pediatric foreign body airway
obstruction management, and
Adult
two-rescuer CPR.
