CEMS and Flexible Staffing - Rule Writing 10o1

AUTHOR: Marc Cohen, WEMSA Executive Director

writingI am very fortunate to represent WEMSA (along with Amanda) on the DHS committees to help craft the administrative rule for both the Community EMS – WI 2017 ACT 96 and Flexible Staffing - WI 2017 ACT 97. The most interesting thing that I discovered is that the most challenging part of administrative rule writing is not actually writing the rules for the legislation. It is actually the process.

When those of you in services around the state are frustrated by the time things take to get done, Now, I can certainly empathize with you. What I discovered is that the entire process from having the governor open Administrative rule, the 90-day process of public comment all the way through the actual approval through the Department of Health Services can take upwards of 18 months. There is even a 52-page manual on how to write rules. All of that doesn’t account for the change in legislative leadership with the new governor. We have already begun working very seriously on both bills.

Flexible Staffing

What is very exciting about this particular committee is that we had an opportunity to take a first look at the new E-licensing system. Seventeen rural services throughout the state will be pilot testing it in the next few months in anticipation of a rollout to the entire state sometime later in 2019. This is exciting because it is very robust, intuitive, and allows for the Service Director to easily manage the process of licensing their service, themselves, the medical director, and their service roster. I’m confident that the services that are the pilot group will go through it thoroughly and be able to ultimately help DHS provide a great product that will help everyone.

Community EMS

This rule writing is both somewhat easier and more challenging for Community EMS. There are a number of services around the state that are already doing a version of community EMS or are authorized as a pilot for the program. There is no question that this is very important for improving patient outcomes and will be a tremendous asset throughout our state. Hopefully, it will also have the additional benefit of providing services with much-needed financial resources through either the hospital system, the insurance companies, or eventually state funding.

It is already clear that the protocol and curriculum developed by North-Central EMS, Hennepin County, and UW -Milwaukee (they’re all the same) is the gold standard for community EMS for paramedics. Sometime in early 2019, the curriculum for all other EMS licenses will be generated from North-Central and available to UW-Milwaukee and Hennepin County in Minnesota. The committee has reviewed the Paramedic protocol.  In advance of administrative rule being opened, we have already worked on draft administrative rules that DHS can begin to work on once the process has begun.

I will continue to update you from time to time on the progress and timing of the implementation of both of important opportunities and look forward to your input and comments.

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