Public Policy / Public Affairs
Advocacy Principles (Adopted by the AAMS Board of Directors, March 2009)
January 10, 2012
Update on Medicare Extenders and FAA Reauthorization
Just prior to the New Year, Congress agreed to a two-month extension of the payroll tax holiday as well as a number of other program extensions. Of particular interest to AAMS members, the legislation provided a two-month extension for Medicare physician fee protection, the 2% urban/3% rural Medicare add-on payment for ground ambulance transports, and the rural zip code hold harmless protection for air ambulance transports (maintaining the rural reimbursement rates for those zip codes reclassified as urban in 2006). As part of the agreement for the two-month extension, a formal conference committee was organized to negotiate a long-term package between the House and Senate. Without a long-term package, these provisions will again expire at the end of February. While discussions have already begun on the staff level, the members of the conference committee are expected to convene formally sometime next week. The members named to the conference committee are as follows:
Republicans:
Sen. Jon Kyl (Arizona)
Sen. John Barrasso (Wyoming)
Sen. Mike Crapo (Idaho)
Rep. Dave Camp (Michigan)
Rep. Fred Upton (Michigan)
Rep. Tom Reed (New York)
Rep. Renee Ellmers (North Carolina)
Rep. Tom Price (Georgia)
Rep. Nan Hayworth (New York)
Rep. Kevin Brady (Texas)
Rep. Greg Walden (Oregon)
Democrats:
Sen. Max Baucus (Montana)
Sen. Ben Cardin (Maryland)
Sen. Bob Casey (Pennsylvania)
Sen. Jack Reed (Rhode Island)
Rep. Xavier Becerra (California)
Rep. Sander Levin (Michigan)
Rep. Allison Schwartz (Pennsylvania)
Rep. Chris Van Hollen (Maryland)
Rep. Henry Waxman (California)
In addition, the current extension for the FAA’s authorization is set to expire at the end of January. It is considered unlikely that Congress will be able to agree to a long-tern FAA reauthorization before that date. It is expected that yet another short-term extension will be enacted prior to the expiration date.
December 13, 2011
AAMS Member ACTION NEEDED!
Air Ambulances are in danger of losing rural zip code protections.
The House of Representatives is expected today to consider end-of-the-year legislation to address a number of outstanding issues. The Middle Class Tax Relief and Job Creation Act of 2011, just released this past Friday, includes provisions providing a two-year fix to the Medicare physician payments, and a one-year extension for ground ambulance rural add-on payments, including the Super Rural add-on payment.
However, unlike previous Medicare Extender bills, the current language does NOT extend rural payment hold harmless language for air ambulances.
In 2006, when CMS adopted a different methodology for designating rural vs. urban areas, over 2000 zip codes were reclassified from rural to urban (meaning that transports originating in these zip codes would receive the lower urban payment rate). In 2008, “hold harmless” language was enacted directing that areas considered rural in 2006 continue to be considered rural for the purposes of air ambulance Medicare reimbursement. The provision was extended last year through the end of 2011.
Without an extension, this provision will expire at the end of December and the affected areas will see an approximate 33% reduction to the Medicare reimbursement rate.
Since the legislation was publicly released on Friday, AAMS has been working diligently with allies in the House and Senate to ensure that the air ambulance hold harmless provision is included in the final legislation. But we need your help….
Representatives Mike Thompson (D-CA) and Cathy McMorris Rodgers (R-WA) have drafted a letter to House leadership asking that the legislation include ALL Medicare extenders, which would include the air ambulance language. They are circulating the letter among their House colleagues seeking additional signatories. AAMS would like to see as many members of the House sign this letter as possible.
Please immediately call, fax or e-mail your member of Congress to:
1. Express the critical need for the air ambulance rural zip code protections to be maintained.
2. Encourage your member to co-sign the Thompson-McMorris Rodgers Medicare Extender letter to the House leadership.
3. Demand that all steps be taken to ensure that air ambulance protections be extended in the final legislation.
Contact information for your Member of Congress can be accessed here.
Also, please immediately contact your state’s two Senators to:
1. Make them aware that the House legislation omits the air ambulance zip code hold harmless from the Medicare extender provisions.
2. Express the critical need for the air ambulance rural zip code protections to be maintained.
3. Demand that all steps be taken to ensure that the air ambulance protections be extended in the final legislation.
Contact information for your Senators can be accessed here.
You may access "template copy" for a letter you can use to communicate with your Representatives on this issue here. If you have any questions or receive any feedback from your calls, please feel free to contact AAMS’ Government Relations Manager Greg Lynskey at 703-836-8732 or glynskey@aams.org.
AAMS meets with EMS Stakeholders
Recently, AAMS was an invited participant in a EMS stakeholders meeting sponsored by the Emergency Care Coordination Center (ECCC), housed within the Office of the Assistant Secretary for Preparedness and Response at the Department of Health and Human Services. This day-long meeting brought together representatives from the full spectrum of the EMS system to provide input as to how the federal government could be a better partner with the EMS community and how we all could move closer to reaching an ideal EMS system. The ECCC will be preparing a proceedings document for public release. AAMS appreciates the opportunity to participate in this collaborative industry effort and looks forward to more opportunities to work with the ECCC in the future.
Recent law includes provisions creating tax credits for businesses that hire unemployed veterans
Recently, President Obama signed into law, legislation that included provisions creating new tax credits for businesses who hire unemployed veterans. The measure will provide businesses with a "Returning Heroes" tax credit for calendar years 2012 and 2013. Business would earn a $2,400 credit for hiring an unemployed veteran who has been unemployed for at least a month. That credit doubles to $4,800 for hiring a veteran who has been unemployed for six months or longer. In addition, the bill also includes a two-year extension of the "Wounded Warriors" tax credit. This program gives companies that hire veterans with service-related disabilities a $4,800 credit. If the veteran has been unemployed for six months or more, the tax credit increases to $9,600.
AAMS Statement regarding H.R. 1117
At its meeting at the Air Medical Transport Conference (AMTC), the AAMS Board of Directors approved the following statement regarding H.R. 1117, the Air Ambulance Patient Safety, Protection, and Coordination Act:
"The AAMS Board of Directors supports efforts to clarify state and federal regulatory authority over air medical transport. For this reason, AAMS has spearheaded the Model State Guidelines project, and continues to pursue this endeavor in the interest of clarification. The stated intent and a significant portion of HR 1117 is directed at the same goal of clarifying state versus federal oversight. However, HR 1117 also seeks to change the application of the Airline Deregulation Act to air medical transport. The AAMS Board is not in a position to support such a change, without further deliberate consideration of the impact on access to and the provision of safe, high-quality air medical services. The AAMS Board requests the opportunity to continue working with the authors and supporters of HR 1117 to find broadly acceptable non-legislative appropriate and effective solutions to the issues it seeks to address and then if still necessary, specific and limited legislation necessary to meet these goals."
The AAMS Government Relations Committee is now examining S. 1407, the Air Ambulance Medicare Accreditation and Accountability Act. A special task force has been formed to work in an expedited manner to examine the legislation. Any recommendations by the task force will be reviewed by the full Government Relations Committee before a briefing document is provided to the AAMS Board of Directors.
NTSB to host 2-day Public Aircraft Oversight Safety Forum
On Nov. 30 and Dec. 1, the National Transportation Safety Board will host a two-day Public Aircraft Oversight Safety Forum. The goals of the forum are to raise awareness of the importance of effective oversight in ensuring the safety of public aircraft operations, identify where responsibility lies for oversight of public aircraft operations, and facilitate the sharing of best practices and lessons learned across a number of parties involved in the oversight of public aircraft operations. The forum is open to the public and will be webcast here.
CMS issues new reporting requirements for air ambulance Medicare providers
On Nov. 29, The Centers for Medicare and Medicaid Services issued a final rule that affects reporting requirements of fixed-wing and helicopter air ambulance providers participating in the Medicare program. Under the new rule, effective Feb. 3, 2011, air ambulance providers must report any revocation or suspension of any federal or state license or certification, including FAA certifications, to the appropriate Medicare contractor within 30 days of the revocation or suspension of the license or certification.
The CMS transmittal regarding the new rule can be accessed here.
Nationwide Test of the Emergency Alert System TOMORROW
On Nov. 9 at 2 p.m. EDT, the Federal Emergency Management Agency (FEMA) and the Federal Communications Commission (FCC) will conduct the first ever nationwide test of the Emergency Alert System. Some TV and radio stations in some areas may not be able to appropriately identify the effort as a test so it is essential that we help spread the word throughout our communities as much as possible. Please view the short video message from FEMA Director Craig Fugate, http://www.fema.gov/medialibrary/media_records/6407 and help raise awareness of the upcoming test throughout the community.
You can also view more information regarding the test here.
Deficit Reduction Committee Begins Its Work
In Washington this week, all eyes were on the Joint Select Committee on Deficit Reduction (commonly known as the Super Committee). The Super Committee is the group of six House members and six Senators who were chosen to develop a proposal to achieve a minimum of $1.2 trillion in deficit reduction. If the committee does not agree on a plan, or if Congress and the President fail to enact the plan, automatic spending cuts will occur to achieve the $1.2 trillion in deficit reduction.
During this past week, the Super Committee held its first organizational meeting. The initial meeting primarily consisted of opening statements, rule adoption, and other administrative organization. On September 13, the committee will reconvene for a full committee hearing on The History and Drivers of our Nation’s Debt and Its Threats where Congressional Budget Office (CBO) director Doug Elmendorf will testify.
As the Super Committee continues its work, it is likely that a portion of the deficit reduction the committee proposes will come from some kind of health care related spending reductions, including Medicare and Medicaid reimbursements. AAMS will continue to closely monitor the Super Committee’s activities and will seek to protect the interests of the air medical and critical care ground communities.
FAA Extension Agreement Reached
Reports indicate that late Friday evening, the House and Senate leadership agreed to a deal that will extend FAA authority through the end of January. As you may recall, following a contentious negotiation and partial FAA shutdown, FAA authority was temporarily extended through September 15. The current agreement is expected to work its way through Congress this week and be enacted before the September 15 expiration of the current extension. The agreement also extends highway and transit assistance programs through the end of March. This will give Congress more time to work toward a long-term reauthorization for the FAA as well as the highway programs.
NEMSAC Meets in DC
Last week, the National Emergency Medical Services Advisory Council (NEMSAC) held a public meeting in Washington, DC. The NEMSAC was formed in April 2007 as a nationally recognized council of EMS representatives and consumers to provide advice and recommendations regarding EMS to the National Highway Traffic Safety Administration (NHTSA). The NEMSAC provides a forum for the development, consideration, and communication of information from a knowledgeable perspective of a strategy for advancing EMS systems nationwide.
During its meeting, the NEMSAC received activity updates from NHTSA’s Office of EMS, the Federal Interagency Committee on EMS (FICEMS), and several of its federal agency partners. In addition, the council viewed presentations from National Institutes of Occupational Safety and Health (NIOSH) and the Department of Health and Human Services Office of Women’s Health and was updated on the National EMS Culture of Safety Strategy Project being led by the American College of Emergency Physicians.
Lastly, the Council continued work toward developing draft advisories on the role of leadership in EMS workplace safety culture and emergency vehicle operator education, training, and safety, as well as a draft position statement on EMS system design. The next public meeting of the NEMSAC is scheduled for December 13-14, 2011.
Garmin Raises GPS Concerns at Joint Hearing of House Transportation Committee
On June 23, Phil Straub, vice president of aviation engineering for Garmin International, joined Craig Fuller, President of the Aircraft Owners and Pilots Association (AOPA), to testify at a joint hearing of the House Transportation and Infrastructure Committee’s subcommittees on aviation and Coast Guard and maritime transportation, regarding Garmin’s concerns that a proposed satellite-based wireless broadband network could disrupt the current GPS system.
At issue is a waiver granted by the Federal Communication Commission ((FCC) to Lighsquared to develop a wireless broadband network using satellites and a number of home bases on the ground. The original proposal would have allowed to Lightsquared to use frequencies along the broadband spectrum adjacent to those used by GPS. Although a revised plan would have Lightsquared use frequencies farther away from the GPS spectrum, Garmin and other GPS providers are concerned that such a network could interfere with GPS satellites, which could compromise the accuracy of GPS systems.
You an access more information on Garmin’s concerns here.
Air Ambulance Medicare Accreditation and Accountability Act Introduced in Congress
On July 26, Senator Maria Cantwell (D-WA) and Senator Olympia Snowe (R-ME) introduced S.1407, the Air Ambulance Medicare Accreditation and Accountability Act. The legislation seeks to require the Centers for Medicare & Medicaid Services (CMS) to develop an Air Ambulance accreditation system that would require certain safety standards to be met in order to participate in the Medicare and Medicaid programs. Furthermore, it would direct CMS to revise the reimbursement system for air ambulances to create a tiered-reimbursement system tied to safety enhancements.
The AAMS Government Relations Committee will be reviewing this legislation.
AAMS Joins Industry to Provide Input on Heliport Advisory Circular
AAMS participated in a two and a half day industry meeting, sponsored by the Helicopter Association International (HAI), to provide input to the Federal Aviation Administration (FAA) as it works to revise its Advisory Circular (AC) on Heliport design. The industry became concerned when what was originally intended to be minor updates morphed into major changes that would have had tremendous unintended consequences for many heliports. While the AC is not a regulatory requirement in itself, many state and local authorities require adherence to the provisions of the AC for licensure and approval of the helipad.
HAI sponsored the meeting to bring a wide section of the industry together with the FAA’s Airport Division to discuss our concerns with the proposed revisions. The FAA welcomed many of the industry’s thoughts, agreed to extend the public comment period by a month, and continue to work with the industry to revise the proposed revisions. Meeting participants also worked through the draft document in order to redline the changes the group felt were necessary. The redline draft will be provided back to the FAA in order to continue the dialog on this important revision effort.
AAMS Participates in National EMS Culture of Safety Conference
On June 27-28, several representatives of AAMS participated in the National EMS Culture of Safety Conference in Alexandria, Virginia. The conference was hosted by the American College of Emergency Physicians (ACEP), pursuant to a cooperative agreement grant administered by the National Highway Transportation Safety Administration (NHTSA). This national conference was a part of a three-year project to study and report upon effective ways to establish a culture of safety throughout the EMS disciplines.
AAMS was one of the organizations that were chosen to appoint a representative to attend the conference and to continue to provide input throughout the term of the project. AAMS’ representatives participating in the conference included AAMS President Dan Hankins, Board Member David Thomson, Executive Director/CEO Dawn Mancuso, and Government Relations Manager Greg Lynskey.
Speakers from a variety of safety and EMS disciplines provided attendees with information and case studies around such issues as just culture, effecting cultural change, and building change from the ground up. After each presentation, attendees broke into small groups to discuss the information presented, what an EMS culture of safety should look like and how best it could be implemented. Project leaders will use the input received to develop an EMS culture of safety outline that will be presented for stakeholder input at another national conference that will be scheduled for sometime next summer.
AAMS will share the results of this first EMS Culture of Safety event with all members once the report has been compiled and published.
AAMS PAC supports Aviation Subcommittee Chairman Tom Petri
Recently, through the AAMS Political Action Committee (PAC), Government Relations Manager Greg Lynskey attended a breakfast fundraiser for Representative Tom Petri, R-Wis. Representative Petri is the Chairman of the House Transportation & Infrastructure Committee's Aviation Subcommittee. Lynskey joined approximately ten other participants for an intimate sit-down breakfast with Rep. Petri. The Congressman's Chief of Staff was also in attendance. Throughout the hour-long event, participants were able to discuss a number of pressing issues, including the status of the FAA Reauthorization legislation, budget negotiations, and the emerging landscape for next year's Presidential election. Events such as these are an essential tool in AAMS' advocacy efforts as it allows us to reinforce AAMS' status as a standing resource to federal policymakers on any issues affecting our community. We thank all the AAMS members who have supported AAMS PAC.
AAMS GR Committee reviews H.R. 1117
The AAMS Government Relations Committee is in the process of reviewing H.R. 1117, the Air Ambulance Patient Safety, Protection, and Coordination Act (http://www.gpo.gov/fdsys/pkg/BILLS-112hr1117ih/pdf/BILLS-112hr1117ih.pdf) H.R. 1117 has been introduced in the House of Representatives by Rep. Candice Miller (R-MI) and Rep. Jason Altmire (D-PA). Its stated purpose is “To recognize and clarify the authority of the States to regulate the medical aspects of intrastate air ambulance services pursuant to their authority over health care services, patient safety and protection, emergency medical care, the quality and coordination of medical care, and the practice of medicine within their jurisdictions.”
The AAMS GR Committee has urged its members to carefully review the legislation and bring forward any comments, questions, or concerns they may have. Once discussion in the committee is completed, a summary of comments raised, along with any other supporting material, will be forwarded to the AAMS Board of Directors.
FAA Reauthorization Still Pending
The House and Senate continue to work towards an agreement on a final FAA Reauthorization package. Last week, Congress passed yet another short-term extension of the FAA’s legal authority through June 30. The previous short-term extension expires at the end of May. Congress is hopefully that this one-month extension will be sufficient to allow negotiations to continue and a final long-term reauthorization package to be agreed upon and enacted before it expires again at the end of June. AAMS continues to monitor the FAA reauthorization process and will continue to keep members updates on new developments.
Hearing Held on Allocation of D-block Spectrum
Last week, the House Energy and Commerce Subcommittee on Communications and Technology held a hearing to discuss how to use the D-block communications spectrum. As you may know, AAMS has been supporting efforts to allocate the D-block for public safety use, opposing the Federal Communication Commission’s (FCC) efforts to auction off the D-block to private telecommunication companies. The written statements of committee leaders and witness are available at http://energycommerce.house.gov/hearings/hearingdetail.aspx?NewsID=8615.
AAMS Participates in “EMS on the Hill Day”
On May 4th, AAMS was pleased to join the National Association of Emergency Medical Technicians (NAEMT) and other EMS partners for “EMS on the Hill Day”. The event, hosted by NAEMT, brought together EMS professionals from across the nation to converge on Capitol Hill to advocate for issues important to the EMS community. Among the issues raised in meeting with U.S. House and Senate members were:
- The Medicare Ambulance Access Preservation Act of 2011 (S. 424, H.R. 1005) - To provide extended Medicare reimbursement relief for ambulance services consistent with the 2007 GAO report that determined that they are paid significantly below cost. It would provide a 6 percent increase for ambulance transports originating in urban or rural areas and add a bonus payment for transports originating in super rural areas.
- The Dale Long Emergency Medical Service Providers Protection Act (S. 385) - This bill would extend the Public Safety Officers' Benefits (PSOB) program - which currently only applies to those employed by a federal, state or local government entity - to EMS professionals employed by private, non-profit EMS agencies.
- The Public Safety Spectrum and Wireless Innovation Act of 2011 (S. 28, H.R. 607) - To allocate the D-Block spectrum for public safety and fund the build-out of a nationwide public safety broadband network around the D Block and adjacent bandwidth already licensed by public safety.
AAMS was pleased to be able to join this effort an would like to thank NAEMT for their hard work in organizing this annual event.
House Passes FAA Reauthorization
On April 1, the House of Representatives passed H.R. 658, the FAA Reauthorization and Reform Act of 2011. In addition to the language in the base legislation, which as you will recall is nearly identical to the bill the House passed last year, there were a number of amendments of interest to AAMS that were adopted during floor debate on the measure. Following is a summary of the amendments of interest (as submitted by their sponsors):
Rep. Randy Neugebauer (TX): Would direct the Administrator of the Federal Aviation Administration to conduct a feasibility study on the development of an online public resource that would list the location and height of potential low-altitude aviation obstructions, such as guy-wire and free-standing towers. Would also give the Administrator one year to conduct the study and report to Congress.
Rep. Bill Shuster (PA): Would improve Federal Aviation Administration (FAA) rulemaking activities by requiring the Agency to recognize that the United States aviation industry is composed of a variety of different segments with different operating characteristics and requiring the FAA to tailor regulations to address the unique characteristics of each industry segment. The amendment also requires the FAA to conduct appropriate cost/benefit studies on all proposed regulations and only enact regulations upon a finding that the costs are justified by the benefits.
Rep. Rob Woodall (GA): Would prohibit implementation by the FAA of a new rule interpretation relating to 14 CFR 135, sections 263 and 267(d) so far as it relates to air ambulances and air cargo charter pilot rest requirements. Sets the interpretation of those sections at the state they were on January 1, 2011.
It is also worth noting that Rep. Doc Hastings (WA) and Rep. Cathy McMorris Rodgers (WA) attempted to include and amendment that would have permitted tax-exempt bonds to be used to finance the purchase of fixed-wing aircraft to provide air ambulance services. However, this amendment was struck down by a procedural Point of Order classifying the amendment as a tax policy change on a transportation measure. You might recall that Senator Maria Cantwell (WA) was successful in adding an identical provision to the Senate’s FAA Reauthorization legislation.
The House and Senate will now begin the process of reconciling the differences between their respective legislation. Be assured that AAMS will continue to monitor the FAA Reauthorization process.
Accountable Care Organizations (ACO) Rules Released
On March 31, 2011 as part of a cross-agency, coordinated effort, several Federal agencies issued documents addressing legal issues regarding Accountable Care Organizations participating in the Medicare Shared Savings Program.
- The Centers for Medicare & Medicaid Services (CMS) issued a proposed rule that would establish accountable care organizations (ACO) under the Shared Savings Program. The CMS proposed rule is available online at http://www.cms.gov/sharedsavingsprogram
- CMS and HHS Office of Inspector General (OIG) jointly issued a notice with comment period outlining proposals for waivers of certain Federal laws, i.e the physician self-referral law, the anti-kickback statute, and certain provisions of the civil monetary penalty law, in connection with the Shared Savings Program. CMS and OIG are also asking for comments on further waiver design considerations for the Shared Savings Program and for the separate waiver authority for the Center for Medicare and Medicaid Innovation under section 1115A of the Social Security Act. The joint notice with comment period is available online at http://www.ofr.gov/inspection.aspx?AspxAutoDetectCookieSupport=1
- The Federal Trade Commission and the Department of Justice jointly issued a "Proposed Statement of Enforcement Policy Regarding Accountable Care Organizations Participating in the Medicare Shared Savings Program" (Antitrust Policy Statement). The Antitrust Policy Statement is available online at: http://www.ftc.gov/opp/aco/
- The Internal Revenue Service (IRS) issued a notice requesting comments regarding the need for guidance on participation by tax-exempt organizations in the Shared Savings Program through ACOs. The IRS notice is available online at http://www.irs.gov/newsroom/article/0,,id=222814,00.html
AAMS is currently reviewing these submissions and will be working with the Government Relations Committee and other interested parties in preparing an appropriate response during the public comment periods.
Senate Passes FAA Reauthorization: Includes Notable Amendments:
Late Thursday evening the United States Senate passed its legislation to reauthorize the Federal Aviation Administration (FAA) for four years. The previous authorization expired in 2007. Since then the FAA has kept operating under a total of 17 temporary extensions. The base Senate bill was identical to the bill the Senate passed last year. However, during committee and floor consideration of the legislation, two amendments of notes were added to the legislation.
- During the Senate Finance Committee’s consideration of the bill, Senator Maria Cantwell (D-WA) was successful in adding a provision that would allow tax-exempt bonds to be used for the purchase of fixed-wing aircraft used as air ambulances. AAMS sent Senator Cantwell and every other member of the Senate Finance Committee a letter voicing support for this provision. Representative Doc Hastings (R-WA) is expected to introduce an identical measure in the House of Representatives. We have contacted Rep. Hastings’ office and expressed our willingness to assist in his efforts in hopes of seeing this provision eventually signed into law.
- As one of the last amendments considered during floor consideration of the bill, Senator Patrick Leahy (D-VT) successfully included the language of S. 385, the Dale Long Emergency Services Provider Protection Act. This provision would extend the Public Safety Officer Benefit (PSOB) program, administered to by the Department of Justice, to non-profit EMS providers. Currently, the PSOB program provides financial assistance to government-employed police, fire, and medical personnel, or their families, who are killed or disabled in the line of duty. AAMS supports this measure and appreciates its passage in the Senate. However, we also note our preference that the PSOB benefit is expanded even further to include ALL EMS providers, including those employed by for-profit entities. We will continue to support efforts to expand the PSOB benefit to EMS providers in the House of Representatives.
Also last week, the House Transportation & Infrastructure Committee passed out of the committee its FAA Reauthorization Legislation. Its bill is also very similar to the bill that passed the House last year. The House Ways & Means Committee will also consider the legislation before it is brought to the full House for consideration. Once the House passes its version of the legislation, it will head to a conference committee which will reconcile the differences between the two bills to create a final package that will go back to each congressional chamber.
FAA Issues Final CRM Rule
The Federal Aviation Administration (FAA) has published a final rule that will require Part 135 operators to develop an ongoing program to educate pilots and crews on Crew Resource Management (CRM). This training would examine such things as levels of authority, teamwork and communications, and managing time and workloads.
To view the FAA’s press release on the final rule, see http://www.faa.gov/news/press_releases/news_story.cfm?newsId=12299
The entire Rule is available at: http://www.gpo.gov/fdsys/pkg/FR-2011-01-21/pdf/2011-1211.pdf
AAMS Provide Comments on Duty Time Reinterpretation
AAMS has filed public comments with the FAA in response to its Notice of Revised Interpretation addressing duty time restrictions for Part 135 operators. Under the reinterpretation, flexibility would be removed from all previous interpretations and would prohibit Part 135 operators from departing on any leg that would knowingly take the pilot over their 14 hour duty time restrictions. Previously, if missions were reasonably planned to be completed within the 14 hour requirement, some flexibility was given to complete missions that were delayed by unforeseen circumstances beyond the control of the pilot or operator. This new interpretation has the potential to negatively impact air medical operations that are naturally susceptible to unpredictable scheduling and unforeseen delays relating to patient stabilization or accident scene extractions. View AAMS comments to the FAA here.
AAMS Files Comments with the FAA on the NPRM on Air Medical Safety posted to the Federal Register on October 12, 2010 - see full document here.
Field EMS Legislation Introduced in Congress
In the final days of the current Congress, Representatives Tim Walz (D-MN) and Sue Myrick (R-NC) introduced H.R. 6528, the Field EMS Quality, Innovation, and Cost-Effectiveness Improvement Act. This legislation was developed in conjunction with the Advocates for EMS to address a number of areas that will give field EMS a stronger and more unified voice in the public policy arena. While the legislation will have to be reintroduced into the new Congress that begins in January, by first introducing the legislation in the final days of the current Congress, sponsors were able to provide a public platform to begin the process of coalescing support around this initiative.
To view H.R. 6528 (pages 1-58) and a section-by-section summary (pages 59-63) and explanatory white paper provided by Advocates for EMS (pages 64-67), please click here.
AAMS Advocacy Principles (Adopted by the AAMS Board of Directors, March 2009)
Where there is general consensus, strongly advocate on a position. Where there is no consensus, try to find compromise or create alternative. If consensus is reached, advocate. Where no consensus and no agreement can be reached, options are:
1. Commit to represent (not advocate) the various interests
2. Preserve AAMS' position as a source of expert advice or insight.
3. Provide opportunities for all opinions (pro and con) to be heard.