HomeMy WebLinkAboutalameda-county-ems-redesign-accma-considerationsMarch 23, 2021
Lauri McFadden
Alameda County EMS Director
1000 San Leandro Blvd., Suite 200
San Leandro, CA 94577
Re: Alameda County EMS Redesign – ACCMA Considerations
Dear Ms. McFadden and Other Emergency Medical Service System Redesign Stakeholders:
I am writing on behalf of the Alameda-Contra Costa Medical Association (ACCMA), representing over
5,000 East Bay physicians, to provide input regarding Alameda County’s current efforts to redesign its
Emergency Medical Services (EMS), specifically addressing considerations related to Exclusive
Operating Area (EOAs), Joint Powers Authority (JPA) models, and community paramedicine/alternative
destination. Members of the ACCMA believe in the prioritization of patient safety and quality of care,
particularly when developing or improving care models, and would encourage the County EMS agency to
make patient care an overarching priority in their decision-making process.
First and foremost, as physicians, we understand and support the need to continuously evaluate and
improve the EMS system in Alameda County. We believe there are opportunities to better utilize
resources within our system to improve access to care and alleviate system burdens without reducing the
quality of care or compromising patient safety. The ACCMA has enjoyed a long, collaborative
relationship with County EMS officials and we have appreciated the degree of stakeholder collaboration
present in the current EMS system redesign process.
The ACCMA has steadfastly advocated for maintaining the EOA for emergency ambulance response and
transport within our counties when the discussion has come up in previous years. As the ACCMA has
continuously prioritized quality of, and access to, patient care, we believe that maintaining the EOA
ensures that all Alameda County residents receive access to emergency medical care in a rapid and
efficacious manner. The ACCMA is concerned that giving up the EOA will result in worse response
times for low-income Medi-Cal patients and the uninsured, who will be disproportionately impacted as
ambulance providers gravitate towards wealthier communities with a better payer mix. Maintaining the
EOA designation ensures that the County can continue to mandate a high level of service to all County
residents, regardless of their ability to pay. We believe that losing the County’s EOA designation could
make it much more challenging for the EMS system to function in a manner that ensures a high-level of
service across the community.
Historically, the ACCMA has focused on promoting a medically-driven EMS system with strong and
independent medical oversight. As previously mentioned, the function of EMS is to ensure that patients
receive access to emergency medical care in a rapid and efficacious manner when needed. As more
consideration is given to developing a Joint Powers Authority (JPA) model with local fire departments, it
is critical that EMS continue to have strong and independent medical oversight, driven by evidence-based
medical policies, to ensure that patient-centered care remains the focus. A JPA model, which closely
mirrors the alliance model currently in effect in Contra Costa County, diminishes the EMS agency’s
direct oversight over the ambulance provider and introduces the potential for political interference into the
EMS agency’s oversight function by engaging a transport provider that is also under the auspices of the
Board of Supervisors. While there are certainly benefits to a JPA model with local fire departments, the
ACCMA would like to ensure that there continues to be strong and independent medical oversight over
EMS services while avoiding potential conflicts of interest in order to promote true patient-centered care.
In regards to community paramedicine, we believe that AB 1544 (Gipson), the Community Paramedicine
or Triage to Alternate Destination Act, signed by Governor Gavin Newsom on September 25, 2020,
provides appropriate and effective guidelines that can be applied to the EMS redesign process in order to
ensure and protect patient safety. We believe that AB 1544 balances the need for creating some of these
new innovative programs while ensuring that patient safety and quality are top of mind through the
following provisions:
- The approved program must always be staffed by a health care professional with a higher scope
of practice, such as, at minimum, a registered nurse.
- The program must be delivered in a manner that promotes the continuity of both care and
providers.
- The program must reflect input from all practitioners of appropriate medical authorities,
including, but not limited to, medical directors, physicians, nurses, mental health professionals,
first responder paramedics, hospitals, and other entities within the emergency medical response
system.
- The program should not be used to replace or eliminate health care workers, reduce personnel
costs, harm the working conditions of emergency medical and health care workers, or otherwise
compromise the emergency medical response or health care system. The highest priority shall be
improving patient care.
- Triage paramedics must complete training relevant to the needs of the patient population,
including specific and extensive training requirements for evaluating patients prior to
transportation to alternate destination facilities. The training requirements outlined in Section
1814 and Section 1831 serve to protect patients and decrease the risk of improper triaging and
inappropriate transportation.
- Patients who specifically request to be transported to an emergency department (ED) rather than
an alternate destination must be immediately transported to the ED. Likewise, patients who are
transported to an alternate destination facility and, upon assessment, are found to no longer meet
the criteria for admission to the facility must be immediately transported to the ED of a general
acute care hospital.
AB 1544 also contains language aiming to ease and ensure the safety of patient transfers between EDs
and alternate destinations. Alternate destination facilities, which must be an authorized mental health
facility or an authorized sobering center, must send with each patient at the time of transfer, or as
promptly as possible in the case of an emergency, copies of all medical records related to the patient’s
transfer. AB1544 also ensures that the triage criteria used to evaluate a patient will be non-discriminatory
and that the ultimate destination cannot refuse to accept patients based on discriminatory criteria. Finally,
AB 1544 requires that the EMSA incorporate data collection, reporting, and public transparency into their
programs, including submission of an annual report to the Legislature which will be made public.
We hope these comments are helpful to the County’s efforts to prioritize patient safety and quality of
care, while improving the EMS system in a manner that continues to make patient care the central
priority.
If you have any questions, please contact Mr. Joe Greaves, ACCMA Executive Director, at
jgreaves@accma.org or by calling 510-654-5383.
Respectfully,
Suparna Dutta, MD
ACCMA President