Carol Sevel, Contracting Officer
Centers for Medicare & Medicaid Services
Acquisition and Grants Group
7500 Security Blvd. C2-21-15, Central Building
Baltimore, MD 21244-1850
Dear Ms. Sevel:
The organizations listed below are jointly submitting these comments on the “8th Scope Quality Improvement Organization Framework.”
Over time QIOs have demonstrated their ability to serve both the government and providers with effective and efficient quality improvement tools. To date their scope of work has been limited to some specific provider types.
Ambulance services have relationships with all the provider types currently served by QIOs. Since most ambulance services are not hospital-based, it is difficult to determine patient outcome because data sets do not flow between organizations. QIOs are in a unique position to be able to assess outcomes based on community resources, because they already work with physicians and hospitals. Adding ambulance services to that mix would allow a QIO to assess the strengths and weaknesses inherent to treating the critically ill or injured. They could demonstrate, for example, if there is added value in having a paramedic (as opposed to basic) ambulance service in a rural community with a basic hospital emergency department.
We encourage you to specifically include ambulance services in the required scope ofwork. If that is not possible, we encourage you to include ambulance services as an eligible activity under selective contract content, which would allow a QIO with an interest to establish a demonstration project to determine the future worthiness of mandatory inclusion.
Advocates for EMS, Maine Ambulance Association, Minnesota Ambulance Association, National Association of State EMS Directors, National EMS Management Association, National Organization of State Offices of Rural Health, National Rural Health Association, New England Council for Emergency Medical Services, North Central EMS Institute, Vermont Ambulance Association
Advocates for EMS was founded as a not-for-profit organization by the National Association of EMS Physicians and the National Association of State EMS Directors to promote emergency medical services (EMS), educate elected and appointed officials and the public on issues of importance to EMS, monitor and influence EMS legislation and regulatory activity, and raise awareness among decision-makers on issues of importance to EMS.
The Maine Ambulance Association, representing 79 EMS services and related agencies in the State of Maine, is a non-profit corporation established to preserve the integrity and enhance the quality of the Maine Emergency Medical Services system; to ensure continued access to 9-1-1 systems for all citizens; to provide a unified voice to represent and support the broad interests and common positions of all EMS providers of the State of Maine.
The Minnesota Ambulance Association is a non-profit organization representing 252 ambulance services operated by local units of government, hospitals, non-profits and private companies.
The National Association of State EMS Directors is the lead national organization for EMS, a respected voice for national EMS policy with comprehensive concern and commitment for the development of effective, integrated, community-based, unive rsal and consistent EMS systems.
The National EMS Management Association’s mission is to catalyze improvements in the performance of EMS processes, organizations and systems.
The National Organization of State Offices of Rural Health is an association of 50 state offices of rural health.
The National Rural Health Association is a national membership organization, whose mission is to improve the health and health care of rural Americans and to provide leadership on rural issues through advocacy, communications, education and research.
The New England Council for EMS is a private, non-profit organization, whose membership consists of the directors and other personnel from the state EMS offices in New England plus representatives from other agencies with a role or interest in EMS on a large area, regional, interagency or interstate level. Since 1973, the council has served as a consortium of the New England states for EMS education, research, planning and development.
The North Central EMS Institute’s mission is to foster innovation, education, collaboration and benchmarking within the national EMS industry.
The Vermont Ambulance Association represents 60 ambulance services and was formed to promote the science and art of pre -hospital care, to afford members opportunities to interchange ideas and to establish a liaison with other associations and government agencies interested in EMS care.