DEPARTMENT OF HEALTH AND HUMAN SERVICES

BUREAU OF EMS TRAUMA AND PREPAREDNESS

EMERGENCY MEDICAL SERVICES - LIFE SUPPORT AGENCIES AND

MEDICAL CONTROL

Filed with the secretary of state on

These rules take effect 7 days after filing with the secretary of state.

(By authority conferred on the director of the department of health and human services by

sections 2233, 20910, and 20975 of the public health code, 1978 PA 368, MCL 333.2233,

333.20910, and 333.20975, and section 2233 of 1978 PA 368, MCL333.2233. Executive

Reorganization Order No. 2015-1, MCL 400.227)

R 325.22101, R 325.22102, R 325.22103, R 325.22111, R 325.22112, R 325.22113,

R 325.22114, R 325.22115, R 325.22116, R 325.22117, R 325.22118, R 325.22120,

R 325.22122, R 325.22123, R 325.22124, R 325.22125, R 325.22126, R 325.22127,

R 325.22131, R 325.22132, R 325.22133, R 325.22134, R 325.22135, R 325.22136,

R 325.22137, R 325.22138, R 325.22165, R 325.22181, R 325.22182, R 325.22183,

R 325.22184, R 325.22186, R 325.22187, R 325.22189, R 325.22190, R 325.22191,

R 325.22193, R 325.22194, R 325.22201, R 325.22202, R 325.22203, R 325.22204,

R 325.22205, R 325.22206, R 325.22207, R 325.22208, R 325.22209, R 325.22210,

R 325.22211, R 325.22212, R 325.22213, R 325.22214, R 325.22215, R 325.22216,

and R 325.22217 of the Michigan Administrative Code are amended, and R 325.22139

and R 325.22218 are added, as follows:

PART 1. GENERAL PROVISIONS

R 325.22101 Definitions; A to D.

Rule 101. As used in these rules:

(a) "Accountable" means ensuring compliance on the part of each life support agency or

emergency medical services personnel in carrying out emergency medical services based

upon protocols established by the medical control authority and approved by the

department.

(b) “Air ambulance service” means providing at least advanced life support services

utilizing an air ambulance or ambulances that operate in conjunction with a base

hospital or hospitals. Air ambulance service may also include any of the following:

(i) Searches.

(ii) Emergency transportation of any of the following:

(A) Drugs.

(B) Organs.

July 21, 2022

(D) Equipment.

(E) Personnel.

ambulance services if the primary air ambulance is not available to provide air

ambulance services.

(bd) "Board certified in emergency medicine" means current certification by the

American board of emergency medicine Board of Emergency Medicine, the American

board of osteopathic emergency medicine Board of Osteopathic Emergency Medicine,

or other organization approved by the department that meets the standards of these

organizations.

(ce) "Code" means the public health code, 1978 PA 368, MCL 333.1101 to 333.25211.

et seq and known as the public health code.

(df) "Designated event” means a temporary event, such as an air show, of no more

than 7 days in duration that requires full-time, on-site availability of an air

ambulance.

(eg) Direct communication" means a communication methodology that ensures medical

control authority supervision of a life support agency when performing emergency medical

services through any of the following methods:

(i) Direct interpersonal communications at the scene of the emergency.

(ii) Direct verbal communication by means of an approved two-way telecommunications

system operating within the medcom requirements.

(iii) Protocols adopted by the medical control authority and approved by the department.

(iv) Other means approved by the department that are not in conflict with the medcom

requirements.

(fh) "Disciplinary action" means an action taken by the department against a medical

control authority, a life support agency, or individual, or an action taken by a medical

control authority against a life support agency or individual for failure to comply with the

code, rules, or protocols approved by the department. Action may include suspension,

limitation, or removal of medical control from a life support agency of a medical control

authority providing medical control, from an individual providing emergency medical

services care, or any other action authorized by the code.

R 325.22102 Definitions; E to OM.

Rule 102. As used in these rules:

(a) "Emergency medical services intercept" means an ambulance operation is transporting

an emergency patient from the scene of an emergency, and requests patient care

intervention from another transporting ambulance operation.

(b) "Emergency medical services telecommunications" means the reception and

transmission of voice or data, or both, information in the emergency medical services

system consistent with the medcom requirements prescribed by the department.

of the code, MCL 333.20910 and 333.20956.

(cd) "Fixed wing aircraft" means a non-rotary aircraft transport vehicle that is primarily

used or available to provide patient transportation between health facilities and is capable of

providing patient care according to orders issued by the patient's physician.

(de) "Ground ambulance" means a vehicle that complies with design and structural

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specifications, as that term is defined in these rules, and is licensed as an ambulance to

provide transportation and basic life support, limited advanced life support, or advanced life

support.

(ef) "Hold itself out" means the agency advertises, announces, or charges specifically for

providing emergency medical services, as that term is defined in the code.

(fg) "License" means written authorization issued by the department to a life support

agency and its life support vehicles to provide emergency medical services, as that term is

defined in the code.

(gh) "License expiration date" means the date of expiration indicated on the license issued

by the department.

(hi) "Licensure action" means probation, suspension, limitation, or removal by the

department of a license for a life support agency or a life support vehicle for violations of

the code or these rules.

(j) “Life support agency” means an ambulance operation, non-transport pre-

hospital life support operation, air transport operation, or medical first response

service.

(ik) "Life support vehicle" means an ambulance, a non-transport, prehospital life support

vehicle, or a medical first response vehicle, as that term is defined in the code.

(jl) "Medcom requirements" means medical communication requirements for an

emergency medical services communication system.

(km) "Medical control" means supervising and coordinating emergency medical services

through a medical control authority, as prescribed, adopted, and enforced through

department-approved protocols, within an emergency medical services system.

(ln) "Medical control authority" means an organization designated by the department to

provide medical control.

(o) "Medical control authority area" means the geographic area composed of a

county, group of counties, or parts of an individual county, as designated by the

department.

(mp) "Medical control authority board" means a board appointed by the participating

organizations to carry out the responsibilities and functions of the medical control authority.

(n) Medical control authority region" means the geographic area composed of a county,

group of counties, or parts of an individual county, as designated by the department.

(q) “Mutual aid” means a written agreement between 2 or more licensed life support

agencies for the provision of emergency medical services when an agency is unable to

respond to a request for emergency services, or an agreement according to the

direction of a medical control authority in accordance with department approved

protocols.

R 325.22103 Definitions; P to TS.

Rule 103. As used in these rules:

(a) "Physician" means a doctor of medicine or doctor of osteopathy who possesses a valid

license to practice medicine in this state.

(b) "Primary dispatch service area" means a service area.

life support agency or a medical control authority for the purpose of improving the

quality of medical care.

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(d) “Protocol” means a patient care standard, standing orders, policy, or procedure

for providing emergency medical services that is established by a medical control

authority and approved by the department under section 20919 of the code, MCL

333.20919.

(ce) "Quality improvement program" means actions taken by a life support agency,

medical control authority, or jointly between a life support agency and medical control

authority with a goal of continuous improvement of emergency medical services in

accordance with section 20919 of the code, MCL 333.20919.

(f) “Regional trauma network” means an organized group comprised of the local

medical control authorities within a region, which integrates into existing regional

emergency preparedness, and is responsible for appointing a regional trauma advisory

council and creating a regional trauma plan.

(dg) "Rotary aircraft" means a helicopter that is licensed under the code as an ambulance.

(eh) "Service area" means the geographic area in which a life support agency is licensed to

provide emergency medical services for responding to an emergency.

PART 2. LIFE SUPPORT AGENCIES-GENERAL

R 325.22111 Life support agencies; general provisions.

Rule 111. (1) A life support agency shall not operate unless it is licensed by the

department and operates under the direction of a medical control authority in accordance

with department-approved protocols. A life support agency shall not operate at a level

that exceeds its license or violates approved medical control authority protocols,

unless otherwise allowed by part 209 of the code, MCL 333.20901 to 333.20979.

(2) A life support agency license shall do both all of the following:

(a) State the level of life support the agency is licensed to provide. A life support agency

shall not operate at a level that exceeds its license or violates approved medical control

authority protocols.

(ba) Be responsible for communicating Communicate approved protocols to appropriate

emergency medical services personnel.

(cb) Provide emergency medical services in accordance with protocols established by the

medical control authority and approved by the department.

(3) A life support agency application shall may not be approved by the department unless

signed by the medical director of each medical control authority responsible for the service

area of the life support agency in accordance with R 325.22205(2). The medical director’s

signature shall serves as confirmation that the medical control authority intends to provide

medical control to the life support agency.

(4) A life support agency, except an fixed wing aircraft transport operation, shall provide

at least 1 life support vehicle for response to requests for emergency assistance on a 24-

hour-a-day, 7-day-a-week basis in accordance with its licensure level and medical control

authority protocols.

(5) A All life support agencies agency shall respond, or ensure a response is provided, to

each request for emergency assistance originating shall have a mutual aid agreement with

another life support agency to ensure a response within the bounds of its service area.

(6) A life support agency shall notify the jurisdictional medical control authority of

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any of the following:

(a) Any investigations, disciplinary actions, or exclusions against the life support

agency with the potential to impact service delivery.

(b) Action taken by an agency against emergency medical services personnel based

on a violation of section 20958 of the code, MCL 333.20958.

R 325.22112 Patient destination; transporting agencies.

Rule 112. (1) An ambulance operation, both ground and rotary, shall transport an

emergency patient only to an organized emergency department located in and operated by 1

of the following:

(a) A hospital licensed under part 215 of the code, MCL 333.21501 to 333.21571. or to

(b) A freestanding surgical outpatient facility licensed under part 208 of the code, MCL

333.20801 to 333.20821, that operates a service for treating emergency patients 24-hours-a-

day, 7-days-a-week, and complies with medical control authority protocols.

code, MCL 333.21501 to 333.21571, if the off-campus emergency department is available

for treating emergency patients 24-hours-a-day, 7-days-a-week, complies with medical

control authority protocols, and has obtained provider-based status under 42 CFR 413.65.

(2) An ambulance operation may transport to an alternate destination requested by

the medical control authority and approved by the department under field study

status.

R 325.22113 Patient transfers; ground, rotary, aircraft transport.

Rule 113. (1) A person shall may not transport a patient by stretcher, cot, litter, or isolette

unless it is done in a licensed ambulance or aircraft transport vehicle. The life support

agency transporting the patient shall require that any applicable department-approved

protocols of the medical control authority are followed in accordance with section 20921(4)

and (5) of the code, MCL 333.20921.

(2) An out-of-state service that is coming to this state to transfer a patient from a Michigan

facility to a facility in another state or country shall be licensed or certified within its own

jurisdiction.

R 325.22114 Professional standards review organization: data collection.

Rule 114. Each life support agency or medical control authority, or both, shall

establish a professional standards review organization for improving the quality of

emergency medical services. As part of the Professional Standards Review Organization,

each life support agency shall collect data to assess the need for and quality of emergency

medical services. The data shall must be submitted to the medical control authority as

determined by department-approved medical control authority protocol as required in R

325.22207(1)(h).

R 325.22115 Use of descriptive words, phrases, symbols, advertising.

Rule 115. A person shall not use words, phrases, signs, symbols, or insignia that advertise

or convey to the public that it provides emergency medical services or that it provides

emergency medical services at a particular level unless it is licensed to do so.

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R 325.22116 Inability to provide service.

Rule 116. (1) If a life support agency cannot operate or staff at least 1 vehicle for response

to an emergency within its service area in accordance with the code, these rules, or

applicable protocols, then the life support agency shall do all of the following:

(a) Immediately notify the department and medical control authority within its service

area when if it cannot provide at least 1 ambulance available for response to requests for

emergency assistance on a 24-hour-a-day, 7-day-a-week basis in accordance with medical

control authority protocols. This rule excludes air ambulance services and aircraft

transport operations when the weather does not meet weather minimums outlined by

a national accrediting body for air ambulance services.

(b) Immediately notify the department of a change that would alter the information

contained on its application.

public safety agencies if appropriate, that it is not available to respond. The notification

shall must advise the dispatch center of the period in which the agency will be out of

service and the name of the agency that will be covering its service area.

(d) Notify life support agencies providing secondary response capabilities mutual aid.

(2) The life support agency shall comply with R 325.22202(4).

(3) A life support agency that does not comply with section 20921(1)(a) of the code shall

be subject to disciplinary action by the department.

R 325.22117 Maintenance of medical records.

Rule 117. In accordance with section 20175(1) of the code, MCL 333.20175, Aa life

support agency shall maintain an accurate record of each case where care is rendered in a

form format approved by the medical control authority. Medical records shall must be

maintained for 57 years. However, records of minors shall must be maintained until they

reach 23 25 years of age.

R 325.22118 Removal of vehicle from service; licensure; interagency vehicle transfer,

lease, loan, from another life support agency.

Rule 118. (1) A life support agency shall notify the department when if it permanently

removes a vehicle from service. If a vehicle is permanently removed from service, then the

agency shall contact the department, in writing, within 30 days of after removal. The

Nnotification shall must include the make, model, year, and vehicle identification number

on a form an application prescribed by the department. The agency shall remove all

oscillating, rotating, or flashing lights, and words, phrases, signs, symbols, or insignia

that advertise or convey to the public that it provides emergency medical services

before transfer or sale of the vehicle.

(2) A life support vehicle license is nontransferable. A life support agency may

temporarily use a state licensed life support vehicle of another licensed life support agency

through a loan. Vehicle loans may occur if mechanical problems prevent an agency from

deploying its existing vehicles. The life support agency acquiring the vehicle shall do all of

the following:

(a) Notify the department of the loan within 3 business days on an form application

prescribed by the department.

(b) Replace an existing licensed vehicle with the loaned vehicle at the agency. The loaned

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vehicle shall must not increase the total number of vehicles the agency is licensed to use.

(d) Extend the loan 1 time for 60 additional calendar days if the agency notifies the

department on an form application prescribed by the department.

(3) A life support agency that obtains a vehicle through a gift, lease, transfer, or purchase

from another life support agency shall comply with both of the following:

(a) Submit an application for the vehicle in accordance with R 325.22190(2) or

(3).

(b) Comply with R 325.22181.

(4) A life support agency that gives, leases, transfers, or sells a vehicle to another

life support agency shall comply with subrule (1) of this rule.

R 325.22120 Life support agencies licensed in other states or dominion of Canada.

Rule 120. (1) A life support agency licensed in another state or the dominion of Canada

that responds to emergencies in this state shall be licensed by the department unless specific

intergovernmental agreements exist between the department, the dominion of Canada, or

the other state.

(2) A life support agency licensed in another state or in the dominion of Canada that

responds to emergencies shall be is accountable to the medical control authority in whose

geographical boundaries initial patient contact is made.

R 325.22122 Misleading information concerning emergency response.

Rule 122. A life support agency shall not knowingly provide a person with false or

misleading information concerning the time at which an emergency is will be initiated or

the location from which the response is being initiated. The department or medical control

authority may investigate any allegation of wrongdoing submitted under this rule. If a

violation of this rule occurs, the department or medical control authority may take any

corrective action authorized under the code and these rules.

R 325.22123 Spontaneous use of vehicle under exceptional circumstances; written

report.

Rule 123. (1) If an ambulance operation is unable to respond to an emergency patient

within a reasonable time, the ambulance operation may use a vehicle may be used under

exceptional circumstances, to provide, without charge or fee and as a humane service,

transportation for the emergency patient. Emergency medical personnel who transport, or

who make the decision to transport, an emergency patient shall file a written report

describing the incident with the medical control authority.

(2) A life support agency that transports Emergency medical personnel who transport,

or who make the decision to transport, an emergency patient under subrule (1) of this

rule shall file a written report within 7 days with the medical control authority describing

the incident within 7 days.

R 325.22124 Enforcement.

Rule 124. (1) The department may take any action authorized by sections 20162, 20165,

and 20168 of the code, MCL 333.20162, 333.20165, and 333.20168, or other provisions of

the code in response to a violation of the code or these rules. Enforcement actions include

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any of the following:

(a) Denial, suspension, limitation, or revocation of a life support agency license.

(b) The issuance of a nonrenewable conditional license effective for not more than 1 year.

actions the department determines to be necessary to obtain compliance with the code or to

protect the public health, safety, and welfare.

(d) Imposition of an administrative fine.

(e) The issuance of an emergency order limiting, suspending, or revoking license.

(2) A life support agency that is granted a 1-year nonrenewable conditional license by the

department shall comply with, at least a minimum, all of the following:

(a) Provide at least 1 vehicle for response to requests for emergency assistance on a 24-

hour-a-day, 7-day-a-week basis in accordance with its licensure level.

(b) Submit a statement of the reasons for the life support agency's inability to comply with

the code for licensure.

submitted to the medical control authority and the department.

(d) Submit a monthly report to the medical control authority that outlines the progress

made on the plan.

(e) Report all out-of-service time to each involved medical control authority.

(3) A life support agency that is granted a 1-year nonrenewable conditional license shall

comply with all licensure fee requirements in the code.

R 325.22125 Life support agency; licensure at higher level of care; requirements.

Rule 125. (1) A life support agency seeking licensure at a higher level shall qualify

qualifies for that license only if the life support agency meets the following requirements:

(a) Under the provisions of the code, a life support agency that is licensed to provide

medical first response life support may apply for licensure at the basic, limited advanced, or

advanced life support level. A life support agency that is licensed to provide basic life

support may apply for licensure at the limited advanced or advanced life support level. In

the same manner, a life support agency that is licensed to provide limited advanced life

support may apply for licensure at the advanced life support level.

(b) Each life support agency that meets the requirements of subdivision (a) of this subrule

shall apply for a higher level of licensure on forms applications provided by the

department and shall meet the requirements of the code and these rules. Included with the

application shall be the The application must include the required fee and identification

of level of life support of the operation.

(2) A life support agency that obtains licensure at a higher level shall provide that level of

care 24-hours-a-day, 7-days-a-week.

(3) If a life support agency applies to the department for licensure at a higher level than

that of its current level, then the department shall conduct an inspection of the agency and

its vehicles. Verification of compliance with this subrule shall must be included with the

application for licensure for each ground ambulance or non-transport, prehospital life

support vehicle by both of the following methods:

(a) Provide, as part of the application, the name and address of the medical control

authority or authorities under which the life support agency is operating. The agency shall

complete an application for licensure, as prescribed by the department, for each medical

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control authority under which it operates. The signature on the application of the

emergency medical services medical director, from each medical control authority, shall

must verify that the medical control authority agrees to provide medical control to the life

support agency.

(b) Attest, by signing the application, to all the following:

(i) Tthe radio communication system for each ambulance or non-transport, prehospital

life support vehicle complies with the medcom requirements.,

(ii) Eeach vehicle meets minimum equipment requirements.,

(iii) and that Mminimum staff requirements are being met in order to operate at least 1

vehicle on a 24 hour-a-day, 7 day-a-week basis.

(iv) In addition, the agency shall document that each Each ground ambulance licensed by

the department has a manufacturer certificate of compliance.

(4) Verification of compliance with this subrule shall must be available to the department

upon request.

R 325.22126 Life support agency; medical control; disciplinary action.

Rule 126. (1) A medical control authority may exercise disciplinary action against a life

support agency and its emergency medical services personnel that may result in the life

support agency, or its personnel not being permitted allowed to provide prehospital

emergency care. The basis for these actions shall must be for noncompliance with

protocols established by the medical control authority and approved by the department.

Disciplinary action may include the suspension, limitation, or removal of medical control

for the life support agency of a medical control authority providing medical control, or

its personnel to provide from an individual providing emergency medical services care,

or any other action authorized by the code.

(2) If disciplinary action against an agency or individual under subrule (1) of this rule

results in the suspension, limitation, or removal of medical control, then the medical

control authority shall advise the department, in writing, of such action within 1

business day of the removal.

(32) If a suspension or removal of medical control for a life support agency or individual

occurs, the life support agency or individual shall may not operate or practice in that

medical control authority region until medical control is restored by the medical control

authority.

(43) If a suspension or removal of medical control for a life support agency or individual

occurs, the life support agency or individual may appeal the decision to the medical control

authority. After appeals to the medical control authority have been exhausted, the life

support agency or individual may appeal the medical control authority's decision to the

statewide emergency medical services coordination committee. An appeal to the

emergency medical services coordination committee shall must be filed with the

department in writing not more than 30 calendar days following notification to the agency

or individual of the final determination of the medical control authority.

(54) The emergency medical services coordination committee shall review the appeal of a

life support agency or individual and make a recommendation to the department. The

department will shall consider the emergency medical services coordination committee

recommendation and conduct its own review of the appeal. If the department determines

that licensure action is required, the department shall provide for a hearing in accordance

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with the code and chapter 4 of Chapter 4 of the Administrative Procedures Act

administrative procedures act of 1969, 1969 PA 369, MCL 24.271 to 24.288. et seq. The

hearing officer shall issue a determination that constitutes a final disposition of the

proceedings to each party within 30 days after the conclusion of the haring. The

determination of the hearings officer shall become the final agency order upon receipt by

the parties.

R 325.22127 Life support agency; life support vehicle; inspection; contractor

requirements.

Rule 127. (1) The department shall, at least annually, inspect or provide for the

inspection of each life support agency. The department shall conduct random inspections of

life support vehicles during the agency licensure period.

(2) A life support agency that receives accreditation from the commission on accreditation

of ambulance services Commission on Accreditation of Ambulance Services or other

another department-approved national accrediting organizations approved by the

department as having equivalent expertise and competency in the accreditation of life

support agencies, may not be subject to an agency inspection by the department if the life

support agency meets both of the following requirements:

(a) Submits verification of accreditation described in this rule.

(b) Maintains accreditation as described in this rule.

(3) Accreditation of a life support agency does not prevent the department from

conducting a life support agency inspection.

(4) Pursuant to section 20910(2)(b) of the code, MCL 333.20910, if emergency medical

services activities apply to contracts with agencies or individuals for purposes of providing

life support agency and life support vehicle inspections, the department shall notify each

life support agency and medical control authority of the existence of the contracts,

including the roles and responsibilities of those agencies or individuals having been

awarded contracts.

PART 3. AMBULANCE OPERATIONS LIFE SUPPORT

AGENCIES

R 325.22131 Ambulance operation; Life support agency; initial application.; ground; rotary.

Rule 131. An ambulance operation life support agency and its ambulances life support

vehicles shall be licensed by the department in accordance with sections 20920, 20926,

20931, and 20941 of the code, MCL 333.20920, 333.20926, 333.20931, and 333.20941.

The application for initial licensureshall must include all of the following:

(a) Be on forms an application provided by the department and include the required fees

and identification of level of life support of the operation agency.

(b) Specify each ambulance life support vehicle to be operated, the level of life support

being provided by that ambulance life support vehicle, and include a certificate of

insurance covering each ambulance life support vehicle as identified in subrule (6e) this

rule.

authority under which the life support agency is operating. The agency shall complete an

application for licensure, as prescribed by the department, for each medical control

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authority under which it operates. A signature on the application by the emergency medical

services medical director, from each medical control authority, shall be is proof that the

medical control authority agrees to provide medical control to the life support agency.

(d) Provide an An attestation, as evidenced by signing the application, of all of the

following:

(i) Radio communications for each ambulance life support vehicle comply with the

medcom requirements.

(ii) Each vehicle meets minimum equipment requirements.

(iii) Minimum staff requirements must will be met in order to operate at least 1 vehicle on

a 24 hour-a-day, 7 day-a-week basis, consistent with section 20921(3) and (4), 20927(3),

20932(2), or 20941(6) of the code, MCL 333.20921, 333.20927, 333.20932, and

333.20941, as appropriate.

(iv) A manufacturer certificate of compliance for each ground ambulance licensed by the

department.

(e) Verification of compliance with subrules (3) and (4) of this rule is available to the

department upon request.

(fe) Include evidence that the operation possesses not less than $1,000,000.00 insurance

coverage or is under a self-insurance program authorized under 1951 PA 35, MCL 124.1 to

124.13 et seq. for property damage and personal injury, except for rotary winged aircraft.

An application for rotary winged aircraft shall must include evidence that the operation

possesses not less than $5,000,000.00 insurance coverage or is under a self-insurance

program authorized under 1951 PA 35, MCL 124.1 to 124.13, et seq. for property damage

and personal injury, except under section 20934(6) of the code, MCL 333.20934.

(gf) Include full disclosure of the operation ownership, including all of the following:

(i) Copies of documents relating to the official type of legal organization of the operation,

stating whether it is an individual proprietorship, partnership, corporation, or subsidiary

of any other another corporation or unit of government. These documents shall must be

maintained by the operation and made available to the department upon request.

(ii) Copies of registration of the operation with the secretary of state or other designated

official in each state that the agency is chartered, incorporated, or authorized to do business.

These documents shall must be maintained by the operation and made available to the

department upon request.

(iii) Disclose all legally responsible individuals, owners, or officers of the ambulance

operation life support agency the time of license application when submitting an

application, including any trade names under which the organization operates. These shall

must include, but are not limited to, the name or names by which the ambulance operation

life support agency is known to the public.

(iv) Disclose all parent organizations and any person, as that term is defined in section

20908 of the code, MCL 333.20908, that have at least not less than a 10% interest in the

applicant operation life support agency.

(hg) Identify 1 individual who will serve as the primary contact person for the operation

agency licensure administrator for the life support agency. The agency licensure

administrator is the point of contact for licensing and inspection activities.

R 325.22132 Ambulance operation Life support agency; operating requirements.

Rule 132. In addition to requirements prescribed in the code and these rules, an

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ambulance operation shall life support agency shall do all of the following:

(a) Establish and maintain a written procedure that explains the steps that will must be

followed when a complaint is received by the operation agency. This procedure shall must

be maintained by the operation agency and shallmade available to the department upon

request.

(b) Maintain evidence of participation in the county, local, or regional disaster plan.

Approved protocols may be used to meet this requirement. These documents shall must be

maintained by the operation and shall be made available to the department upon request.

325.22117.

(d) Maintain written policies and procedures that address safety and accident reduction

and comply with all applicable state and federal health and safety laws as prescribed on

the department-approved agency inspection form. These procedures shall must be

maintained by the operation and shall be available to the department upon request.

(e) Require that each individual staffing an ambulance a licensed life support agency is

in compliance complies with the code and complies with applicable medical control

authority protocols.

(f) Require that an ambulance life support vehicle is not operated while transporting a

patient unless the ambulance is staffed in accordance with section 20921(3), (4), and (5) of

the code, MCL 333.20921.

(g) Require that a non-transport prehospital life support vehicle is not operated

unless it is staffed in accordance with sections 20927(3) and 20941(6) of the code, MCL

333.20927 and 333.20941.

(h) Require that an aircraft transport vehicle is not operated unless it is staffed in

accordance with section 20932(2) of the code, MCL 333.20932.

(gi) Maintain evidence of an orientation process of emergency medical services personnel

that familiarizes them with the agency's policies and procedures and are trained trains

them in the use and application of all the equipment carried in the ambulance licensed life

support vehicle. Included, Aat a minimum, the orientation process must shall be include

an introduction to personnel duties and responsibilities, in addition to medical control

authority protocols.

(hj) Maintain access to the current version a copy of all applicable protocols for each

medical control authority under which the agency operates.

(k) Complete and submit patient care records according to department-approved

medical control authority protocols.

(il) Participate in data collection and quality improvement activities authorized under

medical control authority protocols.

(jm) Ensure that each licensed ambulance life support vehicle meets all applicable

vehicle standards and state minimum equipment requirements prescribed by the

department and department-approved medical control authority protocols.

(kn) Require compliance with medcom requirements.

(lo) Not knowingly respond to, or advertise its services for, prehospital emergency patients

from outside its service area, except for mutual aide requests.

(mp) Require that each individual operating a licensed ground life support vehicle during

an emergency response or patient transport has completed a department-approved vehicle

operation education and competency assessment.

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R 325.22133 Ambulance operation Life support agency; ground; rotary licensure

requirements.

Rule 133. An ambulance operation shall comply with all of the following:

(a) Provide not less than 1 staffed ambulance as defined in section 20921(3) of the

code, at the agency level of licensure, available for response to requests for emergency

assistance 24-hours-a-day, 7-days-a-week.

(b) Respond or ensure a response is provided to each request for emergency assistance

originating from within the bounds of its service area.

(ca) Ensure compliance with the code and these rules.

(db) Advise the department immediately of any changes that would alter the information

contained on its licensure application, including any of the following:

(i) Change of ownership.

(ii) Change of facility name.

(iii) Change in vehicle status.

(iv) Circumstances which preclude the ambulance operation from complying with

subrule (1) of this rule or minimum equipment requirements. Change in agency licensure

administrator contact information.

(v) Circumstances that preclude the life support agency from complying with

staffing or minimum equipment requirements.

(vi) Change in communication ability to comply with medcom requirements.

(vii) Change in service area.

(e) While transporting a patient, require compliance with minimum staffing requirements

prescribed in section 20921 (3)(4) and (5) of the code.

(cf) Require that an individual whose An ambulance operation shall require that an

individual whose license is at least equal to the level of vehicle license is in the patient

compartment when transporting an emergency patient, or consistent with department-

approved medical control authority protocols.

(g) Ensure that patient care and safety equipment carried on an ambulance meet the

minimum requirements prescribed by the department and approved medical control

authority protocols.

(h) Ensure that each ambulance is equipped with a communications system consistent with

the medcom requirements developed by the department.

R 325.22134 Additional licensure requirements for limited advanced life support

agencies and advanced life support ambulance operations approved to administer

medications.

Rule 134. In addition to meeting the other licensure requirements of the code and these

rules, an ambulance operation life support agency licensed at the limited advanced and

advanced life support level shall do approved to administer medications by their local

medical control authority shall do both of the following: all of the following:

(a) Comply with the procedures of drug acquisition, storage, security, dispensing, and

accountability in accordance with the criteria established by the medical control authority,

in compliance with federal and state law and approved by the department and R

325.22207(1)(k) and R 325.22207(3) department-approved medical control authority

protocols and federal and state law.

(b) If licensed at the limited advanced or advanced life support level, Ccomply with

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the acquisition, storage, security, dispensing, and accountability procedures for intravenous

solutions, tubing, and related apparatus in accordance with department-approved medical

control authority protocols and in compliance with the federal and state law.

R 325.22135 Rotary aircraft ambulance operations; additional licensure requirements.

Rule 135. (1) In addition to meeting other licensure requirements of the code and these

rules, an ambulance operation providing rotary aircraft transport shall do all of the

following:

(a) Meet all equipment requirements of the Federal Aviation Administration for the

specific type of aircraft and flying conditions under which the aircraft will operate, as

specified by the air taxi certificate of operation of the aircraft transport provider.

(b) Maintain accurate medical flight records concerning the transportation of each

emergency patient in intrastate flights or interstate flights originating in this state. The

records shall must be available to the department and the medical control authority of the

originating scene, when requested.

department-approved medical control authority protocols when providing on-scene

emergency care.

(d) Meet department licensure requirements and certificate of need requirements when

providing interfacility transfers.

(e) Provide verification of Medicaid participation. A new provider not currently

enrolled in Medicaid shall certify that proof of Medicaid participation is provided to

the department within 6 months after the new provider begins offering services.

(2) An ambulance operation licensed in Michigan that provides rotary aircraft services and

has entered into a mutual aid agreement with a rotary aircraft service outside of Michigan

shall meet both of the following requirements.

(a) A rotary aircraft service outside of Michigan that has an agreement to assist with scene

emergency care is not required to have a certificate of need.

(b) A rotary aircraft service outside of Michigan that has an agreement to assist with

patient transfers from 1 in-state health facility to another in-state health facility is

required to have a certificate of need

(32) An ambulance operation licensed in this state that provides rotary aircraft services or

fixed wing ambulance service shall be accredited by a department-approved national

accrediting organization within 2 years after beginning operation. During the provisional

period between licensing and accreditation, the air ambulance operation must provide all the

following:

(a) Written policies and procedures specifying the levels of patient care to be provided. The

level of patient care provided must be commensurate with the education and experience of

the staff and the capabilities of the base hospitals.

(b) Written patient care protocols including provisions for continuity of care.

members.

(d) Written policies and procedures addressing the appropriate use of air

ambulance’services in accordance with section 20932a of the code, MCL 333.20932a.

(e) A written communicable disease and infection control program.

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(f) A written plan for dealing with situations involving hazardous materials.

(g) A planned and structured program for initial and continuing education and training,

including didactic, clinical, and in-flight, for all scheduled staff members appropriate for the

respective duties and responsibilities.

(h) Written policies and procedures addressing the integration of the air ambulance service

with public safety agencies governing the base hospitals including, but not limited to, the federal

aviation administration, medical control authorities, life support vehicles and disaster planning.

(i) A quality management program.

(j) A clinical database for utilization review and professional standards review organization.

(k) Procedures to screen patients to ensure appropriate utilization of the air ambulance

service.

R 325.22136 Ambulance operation; issuance of ground and rotary ambulance license; life

support agency; issuance of license.

Rule 136. Receipt of the completed application by the department serves as attestation by

the operation life support agency that the operation and ambulances agency and life support

vehicles being licensed are in compliance comply with the minimum standards required by

the department. Upon approval of the application, the department shall issue a license to the

ambulance operation life support agency. The license shall identify each ambulance being

licensed.

R 325.22137 Ambulance operation; false advertising; conflict of interest.

Rule 137. An ambulance operation shall may not do any of the following:

(a) Induce or seek to induce any person engaging an ambulance to patronize a long-term care

facility, mortuary, or hospital.

(b) Advertise, or allow permit advertising of, within or on the premises of the ambulance

operation or within or on an ambulance, the name or the services of an attorney, accident

investigator, nurse, physician, long-term care facility, mortuary, or hospital. If 1 of those

persons or facilities owns or operates an ambulance operation, then the person or facility may

use its business name in the name of the ambulance operation and may display the name of

the ambulance operation within or on the premises of the ambulance operation or within or on

an ambulance.

other than the name of the person holding an ambulance operation license, or the trade, or

assumed name of the ambulance operation.

(d) Use the terms "ambulance" or "ambulance operation" or a similar term to describe or

refer to the person unless the department licenses the person under section 20920 of the

code, MCL 333.20920, licenses the person.

(e) Advertise or disseminate information leading the public to believe that the person

provides an ambulance operation, unless that person does in fact provide that service and is

licensed by the department.

R 325.22138 Ambulance operation; relicensure Life support agency; renewal.

Rule 138. (1) An ambulance operation life support agency shall complete an application

for relicensure renewal and shall return the completed application to the department before

the date of license expiration. Failure to receive a notice for relicensure renewal from the

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department does not relieve the licensee of the responsibility to apply for relicensure renewal.

(2) The license of an ambulance operation life support agency and its ambulances life

support vehicles shallexpire on the same date.

(3) An application for licensure renewal received by the department after the license

expiration date, but within 60 calendar days after the expiration date of the license, shall

requires the ambulance operation life support agency to comply with section 20936 of the

code, MCL 333.20936.

(4) An ambulance operation life support agency may provide emergency medical services

during the 60 days following its license expiration date, whether or not the department has

received an application for renewal.

(5) An application for licensure renewal not received by the department within 60 calendar

days after the license shall expires must be considered revoked,

(6) Reinstatement of the ambulance operation life support agency and life support vehicle

licenses shall require completion of a new application for licensure, including all fees

prescribed in section 20936 (1) and (2) of the code, MCL 333.20936.

R 325.22139 Aircraft transport operations; additional licensure requirements.

Rule 139. (1) In addition to meeting other licensure requirements of the code and these

rules, an aircraft transport operation shall do all the following:

(a) Meet all equipment requirements of the Federal Aviation Administration for the

specific type of aircraft and flying conditions under which the aircraft will operate, as

specified by the air taxi certificate of operation of the aircraft transport provider.

(b) Maintain accurate medical flight records concerning the transportation of each

emergency patient in intrastate flights or interstate flights originating in this state. The

records must be available to the department and the medical control authority of the

originating scene, when requested.

(d) Provide verification of Medicaid participation. A new provider not currently enrolled

in Medicaid shall certify that proof of Medicaid participation is provided to the

department within 6 months after the new provider begins offering services.

(2) An aircraft transport operation licensed in this state shall be accredited by a

department-approved national accrediting organization within 2 years of beginning

operation. During the provisional period between licensing and accreditation, the aircraft

transport operation shall provide all the following:

(a) Written policies and procedures specifying the levels of patient care to be provided.

The level of patient care provided must be commensurate with the education and

experience of the staff and the capabilities of the base hospitals.

(b) Written patient care protocols including provisions for continuity of care.

members.

(d) Written policies and procedures addressing the appropriate use of aircraft transport

in accordance with section 20932a of the code, MCL 333.20932a.

(e) A written communicable disease and infection control program.

(f) A written plan for dealing with situations involving hazardous materials.

(g) A planned and structured program for initial and continuing education and training,

including didactic, clinical, and in-flight, for all scheduled staff members appropriate for

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the respective duties and responsibilities.

(h) Written policies and procedures addressing the integration of the air ambulance

service with public safety agencies governing the base hospitals including, but not limited

to, the Federal Aviation Administration, medical control authorities, life support vehicles

and disaster planning.

(i) A quality management program.

(j) A clinical data base for utilization review and professional standards review

organization.

(k) Procedures to screen patients to ensure appropriate utilization of the aircraft

transport operation.

(3) An air ambulance service may operate a back-up air ambulance the primary air

ambulance or ambulances are not available or for a designated event with prior

notification and approval from the local medical control authority.

(4) A back-up air ambulance must not be operated at the same time as the primary aircraft for

the provision of air ambulance services except for a designated event or disaster.

PART 6. MEDICAL FIRST RESPONSE SERVICES

R 325.22165 Medical first response service; law enforcement; fire suppression agency.

Rule 165. (1) A medical first response service means a person licensed by the department to

respond under medical control to an emergency scene with a medical first responder and

equipment required by the department before the arrival of the ambulance. This includes a fire

suppression agency only if it is dispatched for medical first response life support.

(2) A fire suppression agency shall be licensed as a medical first response service life

support agency, in accordance with R 325.221631, and provide medical first response life

support as described in the code and these rules if it is dispatched to provide any care a

medical first responder is qualified to provide under section 20906(8) of the code, MCL

333.20906.

(3) A law enforcement agency shall be licensed as a medical first response service life

support agency, in accordance with R 325.221631, and provide medical first response life

support as described in the code and these rules if both of the following conditions are met:

(a) “Holds itself out" as a medical first response service.

(b) Be Is dispatched to provide medical first response life support.

(4) A law enforcement agency holds itself out as a medical first response service if it

advertises or announces that it will provide patient care that may include any care a medical

first responder is qualified to provide under section 20906(8) of the code, MCL 333.20906, or

charges for those services.

PART 8. LIFE SUPPORT VEHICLES

R 325.22181 Ground ambulance; requirements.

Rule 181. (1) An ambulance operation shall maintain the manufacturer's certificate of

compliance on file at the time of application to the department for licensure of each ground

ambulance. The certificate of compliance shall must be executed by the final manufacturer of

each ground ambulance and be on a form prescribed by the department.

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(2) The manufacturer of a ground ambulance executing a certificate of compliance shall

comply with the ambulance structural and mechanical specifications with one 1 of the

following standards that was in effect at the time of manufacture:

(a) Federal KKK-A-1822 standards, excluding the paint scheme.

(b) The Commission on Accreditation of Ambulance Services (CAAS) Ground Vehicle

Standard for Ambulances (GVSA) in its entirety.

Ambulances in its entirety.

(3) The manufacturer shall maintain test data demonstrating compliance.

(4) Once licensed for service, an ambulance shall must not be required to meet later modified

state vehicle standards during its use by the ambulance operation that obtained the license.

(5) A ground ambulance referred to in subrule (2) of this rule shall must not be modified to

alter its original design upon which the certificate of compliance was based, unless a new

certificate is issued verifying that the modifications have not altered the integrity of the

vehicle.

(6) The patient compartment of a ground ambulance that has met applicable standards at the

time of manufacture may be remounted on to a different chassis. by a qualified vehicle

modifier as designated by the chassis manufacturer. The remounter may be a member of 1

or more of the following: Ford Qualified Vehicle Modifier, Mercedes Benz Sprinter

Preferred Upfitter, Ram Q Pro Programs, or the National Truck Equipment Association

Member Verification Program. A new manufacturer’s certificate of compliance must be

issued that identifies the new vehicle identification number and demonstrates compliance

with either KKK, GVSA, or NFPA standards in accordance with subrule (2) of this rule.

(7) A new manufacturer’s certificate of compliance must be issued that identifies the

new vehicle identification number and demonstrates compliance with either KKK,

GVSA, or NFPA standards in accordance with subrule (2) of this rule.

R 325.22182 Non-qualifying vehicles for licensure.

Rule 182. (1) A ground ambulance that was originally manufactured before January 1, 1982

shall may not qualify for licensure by the department and shall must not be sold or donated in

this state for use as a ground ambulance. This subrule shall does not apply to a ground

ambulance that has been licensed and is currently licensed by the department and has been in

continuous service before January 1, 1982.

(2) A ground ambulance manufactured after January 1, 1982, whose age from the date of

manufacture exceeds 2 years, shall must have a safety inspection by a certified mechanic

being sold to provide ground ambulance services. The inspection shall must be documented

on a form developed by the department and shall include a notarized statement by the

previous owner attesting that the ground ambulance has not been involved in a vehicular

accident altering its safety. The documents required by this subrule shall must be submitted to

the department by the purchaser as part of the application for licensure by the new owner.

R 325.22183 Ground ambulance sanitation.

Rule 183. A ground ambulance operation shall require that equipment, linen, and supplies

shall be cleaned or exchanged following each patient care use.

R 325.22184 Life support vehicles; displaying of name.

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Rule 184. (1) A life support agency name shall must be prominently displayed on the left

and right side of all licensed life support vehicles.

(2) If the life support agency is operated by or advertised with a name different than the

company life support agency name, then the name may be displayed on the left and right

side of the life support vehicle below the name of the company life support agency. The

advertised name must be smaller than the life support agency name.

(3) A life support agency that identifies a level of licensure in its name or brand that is

higher than the level of life support provided by a specific licensed vehicle, shall

prominently display the actual level of licensure of the vehicle on the sides of the vehicle.

R 325.22186 Life support vehicles; patient care and safety equipment; review.

Rule 186. (1) The department shall, with the advice of the emergency medical services

coordination committee, annually review and modify, as necessary, the patient care and safety

minimum equipment standards for life support vehicles.

(2) The department shall, with the advice of the emergency medical services coordination

committee, review and modify, as necessary, the patient care critical equipment items.

R 325.22187 Rotary ambulance; requirements.

Rule 187. A rotary ambulance shall must meet all of the following standards:

(a) Be capable of on-scene response and transportation of emergency patients.

(b) Be staffed in accordance with section 20921(3), (4), and (5) of the code, MCL

333.20921.

(d) Possess access that allows for safe loading and unloading of a patient without excessive

maneuvering of the patient.

(e) Be temperature controlled for the comfort of the patient.

(f) Have adequate lighting for patient care and observation.

(g) Be equipped with communication capability with hospitals, ground units life support

vehicles, and medical control in accordance with the medcom requirements.

(h) Be capable of carrying a minimum of 1 patient in a horizontal position. on a litter

located so as not to obstruct the pilot's vision or interfere with the performance of any

member of the flight crew or required air medical personnel.

(i) Securely store equipment and make the equipment readily accessible.

(j) Operate under the medical control authority. for the geographic area where on-scene

patient care is being provided.

R 325.22189 Fixed wing vehicle Aircraft transport vehicle; requirements.

Rule 189. An fixed wing aircraft transport vehicle shall must comply with all of the

following:

(a) Be authorized as part of a licensed aircraft transport operation.

(b) Be capable of carrying a minimum of 1 patient in a horizontal position. on a litter

located so as not to obstruct the pilot's vision or interfere with the performance of any

member of the flight crew or air medical personnel.

specific litter rack, or any combination thereof.

(d) If transporting more than 1 patient, there shall be a minimum vertical spacing of 30

June

inches between each patient's litter.

(e) Ensure that the upper surface of the single or upper litter is not less than 30 inches from

the ceiling of the aircraft.

(f) Ensure that the head and thorax of a patient secured to a litter is accessible to air medical

personnel from at least 1 side of the litter without obstruction.

(gd) Ensure that the patient compartment has adequate lighting available for patient

observation.

(he) Require that equipment is secured to the aircraft, readily accessible, and when not in

use, securely stored.

(if) Ensure that the interior of each vehicle affords an adequate patient care and treatment

area.

(jg) Ensure that each vehicle is equipped with a cargo door or other entry that allows for

loading and unloading of the patient without excessive maneuvering of the patient.

(kh) Ensure that the interior of each vehicle is equipped with temperature control for the

comfort of the patient.

R 325.22190 Life support vehicles; licensure and relicensure inspections; new and

replacement vehicles; licensure at higher level of care.

Rule 190. Life support vehicles shall must be inspected as follows:

(a) The department may conduct random renewal inspections of life support vehicles,

including medical first response vehicles. Inspections shall be are unannounced unless

circumstances warrant notifying a life support agency in advance that an inspection of its life

support vehicles will be conducted. The department shall determine if prior notification of an

inspection is warranted. A vehicle license may be renewed without an inspection.

(b) Submission of a licensure renewal application shall be is considered an attestation by the

life support agency that the vehicle meets all licensure requirements.

vehicle shall submit an application, on forms provided by the department, and include the

required fee. New and higher level of care vehicles shall must be inspected before being

placed into service. Upon receipt of the application and required fee, the department shall

inspect new or upgrade vehicles within 15 days after of receipt of the application.

(d) A life support agency that is replacing a life support vehicle shall submit an application,

on forms provided by the department, and include the required fee. A replacement vehicle

means a life support agency has removed a vehicle from service and has replaced the vehicle

with another.

(e) Replacement vehicles may be placed into service upon submission of an application and

the required fee to the department. Upon receipt of the application and required fee, the

department shall inspect the replacement vehicle within 15 days after of receipt of the

application.

(f) With written notification in a format specified by the department, a rotary

ambulance back-up vehicle may be put into service for 30 days before it must comply

with subdivisions (a) to (e) of this rule.

R 325.22191 Life support vehicles inspected; non-compliance; corrective measures.

Rule 191. If the department determines that a life support vehicle is does not in compliance

comply with the requirements of the code and these rules, then the following shall apply

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applies:

(a) If an agency has a vehicle determined to be noncompliant on critical with minimum

equipment items as identified on the inspection form, the agency shall have has 24 hours to

bring the vehicle into compliance and to notify the department in writing of the corrections

made. The vehicle may be returned to service before a reinspection with approval of the

department. A reinspection shall must occur within 15 days after of notification by the life

support agency.

(b) If an agency fails to bring a vehicle into compliance within An agency has 24 hours,

to bring a vehicle into compliance from the time it is determined to be out of compliance due

to missing critical equipment items. Tthe agency shall remove the vehicle from service until

the life support agency submits a written explanation of corrective action to the department

and the department reinspects the vehicle. A vehicle taken out of service shall may not

function as an ambulance or life support vehicle until the vehicle passes the department

reinspection.

inspection, then its license shall be is automatically revoked. Reinstatement of the life support

vehicle license shall requires reapplication for licensure, payment of the licensure fee

prescribed in the code, and a reinspection of the vehicle.

(d) If an agency has a vehicle determined to be noncompliant, but not missing critical

equipment items, the agency shall be allowed 15 calendar days from the date of inspection to

provide the department with a written explanation of corrective action. The life support

vehicle may remain in service during the 15-day period unless the department has ord

ered that the vehicle be taken out of service pursuant to subdivision of this rule.

(ed)The department may immediately order a life support vehicle out of service if it

determines that the health and welfare of a patient may be in jeopardy due to noncompliance

with critical minimum equipment standards or defective and nonfunctional critical

minimum equipment. A notice of such that action shall must be immediately provided to the

life support agency by the department based upon the deficiencies found.

(fe) A life support agency that takes corrective measures to bring a life support vehicle into

compliance during the time of a department inspection shall will not receive notice of

noncompliance. The inspection report shall must reflect that the corrective action and

compliance have been met.

PART 9. COMMUNICATIONS REQUIREMENT

R 325.22193 Medcom requirements.

Rule 193. Medcom requirements shall must be reviewed annually and updated, if necessary,

with the advice and recommendations of the emergency medical services coordination

committee.

R 325.22194 Illegal interception of radio communications.

Rule 194. A person that receives any radio communication not intended for the general public

shall may not use the contents of the communication for initiating an emergency medical

service response as described in section 20963(2) of the code, MCL 333.20963.

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PART 10. MEDICAL CONTROL AUTHORITY

R 325.22201 Medical control authorities; designation.

Rule 201. (1) The department shall designated a medical control authority to provide

medical control for emergency medical services for a particular geographic area. The Medical

Control Authority medical control authority shall operate in accordance with the code. terms

and level of its designation within its medical control authority region.

(2) Level of designation shall be basic life support, limited advanced life support, or

advanced life support. Basic designation includes medical first responder. Limited advanced

life support designation includes medical first responder and basic life support. Advanced life

support designation includes medical first responder, basic and limited life support.

(3) The department shall designate medical control authorities to cover a county or part of a

county, except that the department may designate a medical control authority to cover 2

or more counties if the department determines that the available resources would be

better utilized under a multiple county medical control authority. In designating a medical

control authority, the department shall assure that there is a reasonable relationship

between the existing emergency medical services capacity in the geographical area to be

served by the medical control authority and the estimated demand for emergency medical

services in that area.

(2) A medical control authority shall be administered by the following: the participating

hospitals of the designated medical control authority region.

(5a) Each hospital licensed under part 215 of the code, MCL 333.21501 to 333.21571, that

operates a service for treating emergency patients 24-hours-a-day, 7-days-a-week, may

participate and serve on the medical control authority board in the ongoing planning and

development activities of the medical control authority designated by the department.

(6b) Each freestanding surgical outpatient facility licensed under part 208 of the code, MCL

333.20801 to 333.20821, that operates a service for treating emergency patients 24-hours-a-

day, 7-days-a-week and meets standards established by the medical control authority may

participate and serve on the medical control authority board in the ongoing planning and

development activities of the medical control authority designated by the department. If a

freestanding surgical outpatient facility participates in the medical control authority as

described in this rule, the facility shall meet all applicable standards established by the medical

control authority.

(73) Each hospital, off-campus emergency department with provider-based status, as

described in R 325.22112(1)(c), and freestanding surgical outpatient facility shall comply

with protocols for providing services to a patient before care of the patient is transferred to

hospital personnel.

R 325.22202 Medical control authorities; authority board; advisory body; medical director;

responsibilities; approval.

Rule 202. (1) A medical control authority, as defined in the code, shall be approved by the

department and do all of the following:

(a) Develop bylaws that define the medical control authority organizational structure.

(b) Appoint a medical control authority board to administer the medical control authority.

The majority of the board shall be comprised, at a minimum, of members of the hospitals and,

June

when applicable, freestanding surgical outpatient facilities and off-campus emergency

department with provider-based status, as described in R 325.22112(1)(c) . The board may

include representation of life support agencies other entities as determined by the medical

control authority bylaws.

described in this rule, then the board shall include a representative of each type of life

support agency and emergency medical services personnel functioning within the medical

control authority's region.

(d) Appoint an advisory body, as that term is defined in section 20918(2) and (4) of the

code, MCL 333.20918. The advisory body shall meet at least quarterly.

(e) Appoint a medical director, with the advice of the advisory body, in accordance with

section 20918(3) of the code, MCL 333.20918. The medical director is responsible for

medical control for the emergency medical services system served by the medical control

authority. The medical control authority, with the advice of the advisory body, may appoint

more than 1 physician to serve as medical director provided the individual meets all applicable

criteria, and or is approved by the department.

(f) Appoint a professional standards review organization to monitor and improve the

quality of medical care.

(g) Make Hold each licensed life support agency and individual accountable to the medical

control authority in the provision of emergency medical services, as that term is defined in

department-approved protocols.

(h) Establish written Provide protocols for the practice of life support agencies and

emergency medical services personnel as prescribed or approved by the department.

Protocols shall be provided to all affected life support agencies.

(i) Collect data as necessary to assess the quality and needs of emergency medical services

throughout its medical control authority region area.

(2) Each participating and nonparticipating hospital, off-campus emergency department

with provider-based status, as described in R 325.22112(1)(c), and freestanding

surgical outpatient facility within a medical control authority region shall follow all

standards, policies, procedures, and protocols established by the medical control authority as

approved by the department.

(3) Each medical control authority shall submit to the department current protocols for

department review and approval. Department approval shall be on a 3-year cycle, or as

defined by the department.

(4) The medical control authority shall notify the department if a life support agency is

consistently unable to provide at least 1 life support vehicle 24-hours-a-day, 7-days-a-week.

R 325.22203 Medical control authority; denial, revocation, or suspension of designation.

Rule 203. (1) The department may deny, revoke, limit, or suspend designation of a medical

control authority upon finding that the medical control authority meets 1 or more of the

following:

(a) Is guilty of fraud or deceit in securing its medical control designation.

(b) Has failed to perform in accordance with the terms of its designation and its department-

approved protocols.

the department.

June

(d) Has failed to develop protocols as identified in the code to protect the public health.

(2) If the department denies, revokes, limits, or suspends a medical control authority

designation, then the department shall designate a medical control authority to serve that

medical control authority region area.

(3) The department shall provide notice of intent to deny, revoke, limit, or suspend medical

control authority designation and shall provide for a hearing in accordance with the code and

Chapter 4 of the Administrative Procedures Act administrative procedures act of 1969, 1969

PA 306, MCL 24.201 to 24.328. et seq. The hearing officer shall issue a determination

that constitutes a final disposition of the proceedings to each party within 30 days after the

conclusion of the hearing. The determination of the hearings officer shall become the final

agency order upon receipt by the parties.

R 325.22204 Medical control authority; advisory body.

Rule 204. A medical control authority shall appoint an advisory body, as that term is

defined in section 20918(2) and (4) of the code, MCL 333.20918. The advisory body shall, at

a minimum, do all of the following:

(a) Advise the medical control authority on the appointment of a medical director.

(b) Advise the medical control authority on the development of protocols.

R 325.22205 Medical control authority; medical director; responsibilities.

Rule 205. (1) The medical director is an agent of the medical control authority and is

responsible for medical control for the emergency medical services system.

(2) The medical director shall ensure the provision of medical control. The medical director's

signature on a life support agency's application for licensure or relicensure affirms that the

medical control authority intends to provide medical control to the life support agency. If the

medical director refuses to sign the life support agency application for licensure or relicensure,

then the medical director shall notify the department in writing, within 5 business days,

providing justification for denial based on a department-approved protocol. Refusal of a

medical director to sign a life support agency application shall will result in denial justification

review by the department.

(3) The medical director shall do all of the following:

(a) Participate every 2 years in not less than 1 department-approved educational program

relating to medical control issues.

(b) Be responsible for the supervision, coordination, implementation, and compliance with

protocols of the medical control authority.

(d) Complete, within 1 year of initial appointment, a medical director's educational program

provided by the department.

R 325.22206 Medical control authority; region.

Rule 206. (1) Not more than 1 medical control authority shall may be approved in each

designated region.

(2) A medical control authority shall obtain approval from the department to change or

combine medical control authority regions areas, or to assume a temporary contractual

responsibility for a portion of another medical control authority's region.

June

R 325.22207 Medical control authority; protocol development; promulgation of protocols;

emergency protocol.

Rule 207. (1) Each medical control authority shall establish written protocols, as that term

is defined in section 20919 of the code, MCL 333.20919, which shall must include, but are

not be limited to, all the following:

(a) The acts, tasks, or functions that may be performed by each level of emergency medical

services personnel licensed under this part. Emergency medical services personnel shall not

provide life support at a level that exceeds the life support agency license and approved

medical control authority protocols.

(b) Procedures to assure ensure that life support agencies are providing clinical competency

assessments to emergency medical services personnel before the individual provides

emergency medical services within the medical control authority region area.

upon medical need and the capability of the emergency medical services system.

(d) A do-not-resuscitate protocol consistent with section 20919(1)(c) of the code, MCL

333.20919.

(e) A protocol consistent with part 56B of the code, MCL 333.5671 to 333.5685.

(ef) Protocols defining the process, actions, and sanctions a medical control authority may

use in holding life support agency or personnel accountable. This shall must include

disciplinary action against a life support agency or emergency medical services personnel.

(fg) Protocols defining the process to immediately remove medical control if the medical

control authority determines that an immediate threat to the public health, safety, or welfare

exists. These protocols shall must specify that a medical control authority has 3 business days

to hold a hearing and make a determination.

(gh) Protocols that ensure establishing that if medical control has been removed or

suspended from a participant, that the participant shall not provide prehospital services in

that within their medical control authority area_,then the participant shall not provide

prehospital care until medical control is reinstated. If medical control is removed or

suspended from a participant in the medical control authority, then the department and life

support agency shall be notified within 1 business day of the removal.Medical control shall

inform the department when medical control is reinstated.

(hi) Protocols that ensure a quality improvement program is in place as follows:.

(i) The quality improvement program shall must include a requirement that each life

support agency collects and submits data to the medical control authority.

(ii) Data shall must be reviewed by the medical control authority professional standards

review organization.

(iii) Data shall must be protected in accordance with section 20919(1)(g) of the code, MCL

333.20919.

(ij) Protocols that ensure an appeals process of a medical control decision is in effect.

(jk) Protocols that delineate specify that if life support agencies routinely transport

prehospital patients to hospitals outside of their originating medical control authority region

area, they will comply with their own medical control authority protocols.

(k) Written procedures for the security, control, dispensing, and exchange of

pharmaceuticals, intravenous solutions, tubing, and related apparatus. Life support agency

medication exchange shall only take place with a participating hospital or freestanding

June

surgical outpatient facility.

(2) Each medical control authority shall develop standards for the withdrawal or restoration

of a hospital or free-standing surgical outpatient facility, or off-campus emergency

department with provider-based status, as described in R 325.22112(1)(c), from to a

medical control authority. Or the restoration of a hospital or free standing surgical outpatient

facility to a medical control authority The protocol must include a provision to notify the

regional trauma network of the withdrawal or restoration of a facility.

(3) Each medical control authority shall develop specific protocols applicable to the

acquisition, storage, and use of drugs, intravenous fluids, and medical devices. Protocols

must include all of the following:

(a) All drugs and intravenous fluids shall must be under the control of a pharmacist licensed

in this state affiliated with a participating medical control authority hospital, or free-standing

surgical outpatient facility, or off-campus emergency department with provider-based

status, as described in R 325.22112(1)(c).

(b) The medical control authority participating pharmacy shall provide medication and

intravenous fluid exchange services in accordance with the protocols developed by the

individual medical control authority and approved by the medical control authority

medical control director and the department.

pharmacy supplied medications or devices, the pharmacy shall notify the medical control

authorities.

(d) All medication storage containers must be numbered. Each medication storage

container must be inspected and inventoried by a medical control authority-approved

pharmacy at least annually.

(e) All medication storage containers must have at least the following information

affixed to the outside of the container:

(i) The name of the medical control approved pharmacy that most recently restocked

the container.

(ii) The date of the most recent restock.

(iii) The name and date of the medications with the earliest expiration dates.

(iv) Notation of the licensed pharmacy personnel who completed and sealed the

medication container.

(f) The medical control authority participating facility or agency in possession of

intravenous fluids, tubing, and supplies shall have a method for verifying and tracking

that the supplies are within their expiration date and do not have any active recall

notices.

(g) The medication containers must be stored in a method that maintains the stability,

integrity, and effectiveness of the medication contained therein.

(4) Each medical control authority considering the adoption of protocols shall comply with

section 20919 (3) (a) of the code.

(4) Each medical control authority may establish an emergency protocol necessary to

preserve the health or safety of individuals within its region in response to a present

medical emergency or disaster in accordance with section 20919 (3)(a) of the code.

Emergency protocols developed in accordance with section 20919(3)(e) of the code, MCL

333.20919, shall must be submitted to the department, within 5 business days, for review and

shall must remain in effect for not more than 60 days unless approved by the department.

June

R 325.22208 Medical control authority protocols; department review; approval; adoption by

medical control authority.

Rule 208. (1) A medical control authority shall circulate, not less than at least 60 days

before adoption, a draft of proposed protocols to all affected life support agencies within the

emergency medical services system under the medical control authority.

(2) A medical control authority shall submit a written draft of proposed protocols to the

department for review by the quality assurance task force not later than the tenth day of any

given month. A protocol received not later than the tenth day of a given month will must be

reviewed that month. A protocol received after the tenth day of a given month will must be

reviewed the next month following the date of receipt by the department.

(3) The department shall consider any written comments received from persons within the

medical control authority when reviewing a protocol.

(4) The department shall provide written recommendations to the medical control authority

within 60 days of after receipt of a protocol in compliance with this rule, and comments,

suggested changes, deletions, denial, or approval on the proposed protocol. Protocols

resubmitted with changes or modifications by the medical control authority fall under the 60-

day response deadline as prescribed in this rule.

(5) Following department approval of a protocol, the medical control authority may formally

adopt the protocol.

R 325.22209 Medical control authority; additional standards.

Rule 209. A medical control authority may adopt protocols that require additional or more

stringent standards for life support agencies, equipment, and personnel than those already

required by the department to enhance its system in the interest of prehospital emergency care.

If a life support agency or emergency medical services personnel within the medical control

authority disagree with the proposed protocol, then the medical control authority shall provide

the department with the medical and economic considerations such enhancements may have

on the local community. The quality assurance task force shall review and make

recommendations to the department before department approval.

R 325.22210 Medical control authority; life support agencies and personnel; compliance

with protocols.

Rule 210. (1) Each life support agency and emergency medical services personnel licensed

under this part is accountable to the medical control authority in the provision of emergency

medical services within the medical control authority region, as defined in department-

approved protocols.

(21) A medical control authority shall establish written procedures protocols for the process,

actions, and sanctions a medical control authority may use in holding a life support agency or

personnel accountable. These procedures protocols shall must include disciplinary action

against a life support agency or emergency medical services personnel to assure ensure

compliance with standards of medical care, all protocols, and operational procedures or to

protect the public health, safety, or welfare.

(32) A medical control authority may exercise disciplinary action against a life support

agency and its emergency medical services personnel that may result in the life support agency

or its personnel not being permitted allowed to provide emergency medical services care. The

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basis for these actions shall must be for noncompliance with policies, procedures, or protocols

established by the medical control authority. The Such disciplinary action may include the

suspension, limitation, or removal of a life support agency or its personnel to provide

emergency medical services within the medical control authority region area.

(43) If disciplinary action against an agency or individual under subrule (1) of this rule

results in the suspension, limitation, or removal of medical control, the medical control

authority shall advise the department, in writing, of the such action within 1 business day.

(54) If a suspension or removal of medical control to a life support agency or individual

occurs by the medical control authority, the life support agency or individual shall may not

operate or practice in that medical control authority region until medical control is restored by

the medical control authority.

(65) If a suspension or removal of medical control to a life support agency or individual

occurs, then the by the medical control authority, the life support agency or individual

shall not operate or practice in that medical control authority area until medical control

is restored by the medical control authority. life support agency or individual may appeal

the decision to the medical control authority. After appeals to the medical control authority

have been exhausted, the life support agency or individual may appeal the medical control

authority's decision to the statewide emergency medical services coordination committee. An

appeal to the emergency medical services coordination committee shall be filed with the

department in writing not more than 30 calendar days following notification to the

agency or individual of the final determination of the medical control authority.

(76) In cases of malfeasance, misfeasance, or nonfeasance on the part of the medical control

authority, the department shall implement take action that to preserve medical control in a

medical control authority region.

R 325.22211 Medical control authority; quality improvement.

Rule 211. (1) A medical control authority shall establish a quality improvement protocol to

ensure a quality improvement program is in place and functional.

(2) Data submitted by the life support agencies within the medical control authority region

area shall must be reviewed by the medical control authority professional standards review

organization for the purpose of improving the quality of medical care within the medical

control authority region area.

(3) A quality improvement program shall comply with section 20919(1)(g) of the code.

R 325.22212 Medical control authority; appeals.

Rule 212. (1) A medical control authority shall incorporate procedures for the appeal of

decisions made by the authority against a life support agency and emergency medical services

personnel. Once appeals to the medical control authority have been exhausted, the decision

made by the medical control authority may be appealed to the statewide emergency medical

services coordination committee. An appeal to the emergency medical services coordination

committee shall must be filed with the department in writing not more than 30 calendar days

following notification to the agency or individual of the final determination of the medical

control authority. The emergency medical services coordination committee shall issue an

opinion on whether the actions or decisions of the medical control authority are in accordance

comply with the department-approved protocols of the medical control authority and the code.

(2) If a decision of the medical control authority is appealed to the emergency medical

June

services coordination committee, then the medical control authority shall document their

decision to the statewide emergency medical services coordination committee for their review.

(3) If the statewide emergency medical services coordination committee determines that the

actions or decisions of the medical control authority are not in accordance with department-

approved protocols or the code, then the emergency medical services coordination

committee shall recommend to the department that it not take enforcement action under the

code.

(4) If the statewide emergency medical services coordination committee determines that the

actions or decisions of the medical control authority are in accordance with department

approved protocols or the code, then the emergency medical services coordination committee

shall recommend to the department that it take enforcement action a under the code.

R 325.22213 Medical control authority; data collection; data confidentiality.

Rule 213. (1) A medical control authority shall collect data under the department-approved

quality improvement protocol from each life support agency within the medical control

authority region area. Data collected shall must be reviewed by the medical control authority

professional standards review organization to improve the quality of medical care within the

medical control authority region and shall comply with section 20919(1)(g) of the code, MCL

333.20919. All data collected under section20919(1)(g) of the code, MCL 333.20919, are

confidential, not public record, not discoverable, and shall may not be used as evidence in a

civil action or administrative proceeding.

(2) A medical control authority shall submit data to the department as prescribed by the

department and approved by the emergency medical services coordination committee.

(3) Medical control authorities shall have access to quality data residing within the

Michigan Emergency Medical System Information System for incidents that occur

within the medical control authority’s geographic area.

R 325.22214 Medical control authority; special studies.

Rule 214. (1) A medical control authority that intends to establish a protocol involving skills,

techniques, procedures, or equipment that is not included in this or national state's approved

curriculum, but are consistent with the emergency medical services personnel licensure is

not may need to establish the practice as a special study. This skill, technique, procedure, or

equipment is not a special study if it complies with the following: Determination that a

proposed protocol is acceptable under current practice or requires a special study is

decided by the quality assurance task force. A protocol may be approved as a medical

control authority protocol under the following conditions:

(a) The medical control authority Pprovides documentation that the skill, technique,

procedure, or equipment complies with either 1 of the following:

(i) The practice Iis recognized by a national organization as an acceptable. guideline.

(ii) Published studies that support the safety and efficacy in its application within the

emergency setting. The practice has existing precedent in Emergency Medical System

outside of this state.

(iii) There are Ppublished studies that support the safety and efficacy in its application

of the practice within the emergency setting.

(b) The medical authority Pprovides the educational outline that will be implemented to

instruct the emergency medical services personnel in the new skill, technique, procedure, or

June

equipment, as well as the verification of competency that will be utilized.

director for the medical control authority participating in the practice implementation.

(d) The medical control authority submits protocols that will be used for the practice.

(e) The quality assurance task force may require data submission to this state for

approval of the practice. If data is required for approval, the approval must be indicated

as approval of the practice as a special study.

(2) A medical control authority that intends to establish a protocol involving skills,

techniques, procedures, or equipment that is not included in this state's approved curriculum,

and is not consistent with its level of licensure shall requires a special study and must comply

with all of the following:

(a) The department shall support the study. Provide any available studies or supporting

documentation indicating the practice has been studied. Published studies supporting

the safety and efficacy of its applications within the emergency setting must also be

submitted.

(b) Submit endorsements by the medical control authority and medical director. The medical

control authority provides an educational outline that will be implemented to instruct the

emergency medical services personnel in the new skill, technique, procedure, or

equipment, as well as the verification of competency that will be utilized and the plan for

continued competency assurance, such as a continuing education plan.

have an institutional review board, then all of the following are acceptable alternatives:

(i) Hospital risk management or equivalent.

(ii) Hospital quality review committee or equivalent.

(iii) A clinical department involved with emergency medical services that has an ongoing

quality review process.

medical director for the medical control authority participating in the special study.

(d) Submit a time line clarifying the duration of study. The timeline shall include the

number of cases to reach conclusion of the study with an estimated date to reach requirement.

The medical control authority shall submit protocols that will be used for the practice.

(e) Submit initial and refresher education requirements. Refresher education requirements

shall include frequency and content of refresher to maintain proficiency in skill, technique,

procedure, or equipment. Education requirements shall include minimum proficiency

requirements.

(e) Identify life support agencies involved in the special study, their licensure level, the

number of emergency medical services personnel to be trained, and their respective

licensure levels.

(gf) If providing mutual aid outside its medical control authority region, the medical control

authority shall have a written agreement with another medical control authority to continue to

utilize its protocols. Submit a timeline indicating the proposed duration of the study.

(hg) Identify a special study coordinator. Describe the proposed data to be submitted to

this state during the study. Generally, data submission is required quarterly.

(ih) Identify data parameters to be collected and the quality review process that shall be

implemented. The medical control authority shall submit quarterly reports, and upon

completion of a special study, submit a final report to the department. If the medical control

June

authority intends to publish the results of the study, they shall also submit Institutional

Review Board approval or the letter of exemption status for the study.

(j) Submit protocols that shall be included in the special study.

(3) A medical control authority that intends to establish a protocol involving skills,

techniques, procedures, or equipment that is not included in this state's approved curriculum,

but is consistent with generally accepted practices at their level of licensure shall not require

a special study. Those skills, techniques, procedures, or types of equipment shall and is not

consistent with either the level of licensure or scope of practice, involves human subject

research under 45 CFR part 46, or intends the human subject research to be published,

shall not require a special study if it complies with all of the following:

(a) The department shall support the protocol. Provide any available studies or supporting

documentation indicating the practice has been studied. Published studies supporting

the safety or efficacy of its application within the emergency setting must also be

submitted.

(b) Submit endorsements by the medical control authority and medical director.

(cb) Submit initial and refresher education requirements and provide an educational

outline to be implemented to instruct the emergency medical services personnel in the

new skill, technique, procedure, or equipment, as well as verification of competency that

will be utilized. Refresher education requirements shall must include frequency and content

of refresher to maintain proficiency in skill, technique, procedure, or equipment. Education

requirements shall include minimum proficiency requirements.

(dc) Identify life support agencies involved, their licensure level, the number of emergency

medical services personnel to be trained, and their respective licensure levels.

(ed) If providing mutual aid outside its medical control authority region, the medical control

authority shall have a written agreement with another medical control authority to continue to

utilize its protocols.

(fe) Identify the quality review process that will be implemented.

(gf) Submit protocols that will be included in the special study.

(g) Identify data parameters to be collected and the quality review process that will be

implemented. The medical control authority shall submit quarterly reports, and upon

completion of the study, submit a final report to the department.

(h) Obtain and submit an institutional review board approval or an institutional review

board official exemption. If the medical control authority used a randomized study,

include the consent form, method of institutional review board approval, and

institutional review board approval letter.

(4) A special study may be terminated by the department, with the advice of the emergency

medical services coordination committee quality assurance task force, for any of the following

reasons:

(a) The special study jeopardizes the health, safety, or welfare of the citizens of this state.

(b) There is evidence of failure to follow study parameters.

(d) The medical control authority or medical director requests termination.

(e) There is not sufficient data to support continuation.

(5) A special study may be considered complete when outcomes have been met, the

timeline has been completed, or the study has been terminated by the department with

the advice of the quality assurance task force. A final report must be submitted to the

June

department by the medical control authority when the study is complete, unless the study

is terminated by the department. The medical control authority may request any of the

following for the protocol being studied:

(a) That it become a standard protocol for the requesting medical control authority.

(b) That it become a standard protocol for this state.

(d) That it be terminated.

(6) Disposition of the protocol is determined by the quality assurance task force.

R 325.22215 Medical control authority; communication requirements.

Rule 215. (1) A medical control authority shall comply with the ambulance-to-hospital radio

communications system approval process, as prescribed by the medcom requirements., under

any of the following conditions:

(a) A medical control authority upgrades to provide limited advanced or advanced life

support oversight.

(b) An existing medical control authority changes the infrastructure of its communication

system affecting ambulance-to-hospital communications.

agency or hospital to communicate with each other.

(2) Each medical control authority shall designate an individual or organization to be

responsible for maintaining records of the telecommunications activities in support of medical

control. The records shall must be in the form of electronic recordings and shall be kept

maintained for 60 days.

(3) The department may add additional frequencies or other methods of communications to

the medcom requirements. The department, before implementation, shall approve new

requirements and technologies for ambulance-to-hospital communication.

(4) A medical control authority shall comply with all of the following:

(a) Operate under a department-approved radio communications system plan applicable to

each level of care proposed by each life support agency and its geographic service area. The

plan shall be consistent with the medcom requirements, established by the department, for

radio conservation, regional compatibility, channel utilization, and medical control.

(b) Utilize medcom channel assignments and operating procedures as established by the

department under the code.

medcom requirements.

R 325.22216 Medical control authority; interface with public safety agencies; authority for

management of patient.

Rule 216. A medical control authority shall establish protocols that do all of the following:

(a) Clarify that the authority for the management of a patient in an emergency is vested in the

licensed health professional or licensed emergency medical services personnel at the scene of

the emergency who has the most training specific to the provision of emergency medical care.

(b) Identify that when a life support agency is present at the scene of an emergency, authority

for the management of an emergency patient in an emergency is vested in the physician

responsible for medical control, until that physician relinquishes management of the patient to

a licensed physician at the scene of an emergency.

June

(d) Specify that if an emergency is declared, the declaration that an emergency no longer

exists shall may be made only by an individual licensed under the code or a health

professional licensed under the code who has training specific to the provision of emergency

medical services in accordance with department-approved protocols.

R 325.22217 Medical control authority; interfacility transfers.

Rule 217. (1) A medical control authority may adopt a protocol that governs the transport of

a patient from 1 health facility to another. If a medical control authority has not established

department-approved protocols for the interfacility transport of a patient, then patient care

shall must be determined according to written orders of the transferring physician within the

scope of practice of the emergency medical services personnel.

(2) A life support agency shall be is accountable to a medical control authority in which it has

been approved to operate.

R 325.22218 Medical control authority; stretcher transport of nonemergency patients.

Rule 218. With department approval, a medical control authority may implement a

protocol that governs the treatment and stretcher transport of nonemergency patients.

June

From:

Kerr, Sabrina (DHHS)

To:

Subject:

Date:

Attachments:

Importance:

Brennan, Mary (DHHS); Bergquist, Emily (DHHS)

FW: Reules comments from DEMCA

Friday, August 19, 2022 3:03:35 PM

image001.png

High

Please see comments below and attached. I have not reviewed these yet and will go through and

provide a response

Sabrina Kerr, BA, MPA, EMS Section Manager

Bureau of EMS, Trauma, & Preparedness

Michigan Department of Health & Human Services

1001 Terminal Road

P.O. Box 30207

Lansing, Michigan 48909-0207

Cell Phone: 517-243-9976

Fax: 517-335-9434

Website: www.michigan.gov/ems

Due to the COVID-19 response there may be a delay in responding to emails and phone

calls. We ask for your patience as we make every effort to reply as soon as we possibly

can. Updates about the response can be found at:

https://www.michigan.gov/coronavirus. More specific information as it pertains to EMS

can be found at: https://www.michigan.gov/EMSCOVID

Division of EMS and Trauma Mission Statement:

To support the Michigan EMS System in protecting the public health and providing safe and

effective patient care.

Confidentiality Statement: This message, including any attachments, is intended

solely for the use of the above named recipient(s) and may contain confidential

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contact the sender by reply e-mail and destroy any and all copies of the original

message.

From: Robert Dunne <rkdunne@wayne.edu>

Sent: Friday, August 19, 2022 2:41 PM

To: Babb, Nicole (DHHS) <BabbN@michigan.gov>; Kerr, Sabrina (DHHS) <KerrS3@michigan.gov>

Subject: Reules comments from DEMCA

CAUTION: This is an External email. Please send suspicious emails to abuse@michigan.gov

Comments Below and in the attachment as MS word comments (some are just our

agreement and emphasis, some are not clear and should be proof read, some are

concerns).

Thanks.

Rob Dunne on Behalf or DEMCA.

The part where they get rid of requiring X number of ambulance available to the 911

system 24/7/365 is a problem if implemented. I could see agencies (particularly

private) financially justifying not providing ambulance service on certain days/times as

not cost effective.

pg 13 sec A and B are covered twice already in the code and should be removed.

pg 23 sec E- "provided the individual meets all applicable criteria, and or is approved

by the department." Has this come up before (no qualified individuals available to

serve as medical director, unqualified individual approved by the department)? If it

isn't a huge problem somewhere, is it wise to change the "and" to an "or"?

pg 29 sec "Published studies supporting the safety and efficacy of its applications

within the emergency setting must also be submitted." This could potentially

prevent an MCA from studying an established intervention commonly performed

outside of the emergency setting if there are no previous data. It might be

worthwhile to add teh caveat that these should be provided if available, as with the

previous sentence in the section.

As far as removing the IRB section on pg 29, with the addition of section H, it looks

like they are trying to exempt nonpublished special studies from IRB requirements

such as unpublished QA/QI or investigation of a new established intervention

outside of research. It is a bit weird that publishing or not is the standard for IRB

approval or not- in general the standard for IRB approval is whether or not human

subject research is taking place. This could be modified to "If the study amounts

to human subjects resarch as defined by the common rule, Institutional Review

Board approval or the letter of exemption status shall be submitted for the

study."

On page 21, the last sentence of the highlighted causes confusion and no one can

really explain what it means.

On page 27 the appeals section being removed is covered on page 28.

On page 28 the appeals sections that they want to remove are covered in the

paragraph above.

Section d on page 20 needs to be removed. This caused massive issues with an

agency that was found to be non-compliant and had major compliance issues. The

state had to wait 15 days before acting, knowing the agency was a risk to the welfare

of the public.

On page 19, the section about aircraft litter layout, I do not know enough about why

it is there or why people want it removed to have an opinion either way. Same thing

with sections on page 14. On page 12, the two sections being removed are part of the

public health code. I do not see why they need to be part of the rules as well.

EMS LIFE CONTROL PUBLIC COMMENT

NAME

ORGANIZATION

RULE NUMBER

COMMENT

DHHS' RESPONSE

Robert Olkowski

Detroit Fire Department- General Comment

EMS

Administrative Rules and Statutes

should never include the word may.

Why codify into law that possibility

that something maybe done

DHHS opposes this comment. Statutes and rules

are either mandatory or permissive. "May" is used

frequently in many statutes and rule sets

depending on the intent of the statute or rule and

subject matter. However, there were some

instances in this rule set that have been identified

as incorrect and will be reflected in the JCAR report

as changed.

Robert Olkowski

Detroit Fire Department- General Comment

EMS

Language needs to be consistent

throughout the document. In several

instances ambulance operation is

DHHS partially agrees/opposes this comment.

There were some instances in this rule set where

"ambulance operation" should have been "life

used even though life support agency is support agency". Those have been identified and

the new terminology.

changed. Section 20902(5)of the Public Health Code

defines "Ambulance Operation" as a person

licensed under this part to provide EMS and patient

transport, for profit or otherwise. Section 20906(1)

of the Public Health Code defines "Life Support

Agency" as an ambulance operation, nontransport

prehospital life support operation, aircraft

transport operation, or medical first response

service.

Robert Olkowski

Detroit Fire Department- General Comment

EMS

All MCL citations throughout the

document should be in parenthesis.

DHHS opposes this comment. The rules have been

vetted and approved by both the LARA-

Administrative Rules Division and the Legislative

Service Bureau. The statute citations are not

required to be in parantheses. See LSB and Admin

Rule style guides.E8

Yes. Section 20902(4) of the Public Health Code

defines "Ambulance" as a motor vehicle or rotary

aircraft that is primarily used or designated as

available to provide transportation and basic life

support, limited advanced life support, or

advanced life support. The definiton in this rule

also includes ambulance - which I do not think was

the intent of this rule. The definition has been

amended for further clarity.

Detroit Fire Department- R 325.22101(b)

EMS

Does this definition include

helicopters?

Robert Olkowski

Detroit Fire Department- R 325.22111(3)

EMS

If I am reading this right it means the

DHHS agrees with this comment. This should say

state may override the MCA and allow "shall" instead of "may". "shall' reinstated and

an agency to be licenses even if they do "may" deleted.

not meet a;; MCA requirements. Should

be changed to will not.

Detroit Fire Department- R 325.22111(5)

EMS

Needs to specify the same MCA.

According to what I read as long as I

have a MA agreement with any

licensed agency I am good.

DHHS agrees. Section 5 has been rewritten with an

additional subrule 6 to end confusion: (5) All

life support agencies shall have a mutual aid

agreement with another life support agency to

ensure a response within the bounds of its service

area.

(6) If no other life support agency is licensed in the

medical control authority that meets this criteria, a

mutual aid agreement may be with a life support

agency in an adjacent medical control authority.

This does not preclude a life support agency from

entering into additional mutual aid agreements

with other life support agencies that is at a level of

licensure that is less than their level of licensure.

Robert Olkowski

Detroit Fire Department- R 325.22111(6)(a)

EMS

Wouldn’t this be done by the State,

since they are the ones taking actions accountable to their respected MCA and therefore

against agencies?

DHHS response: Each life support agency is

the MCA has the authority to take action to

suspend, limit, or remove privileges of a life

support agency within their MCA. The MCA is

required to notify the department if the MCA takes

any such action as outlined in Rule 325.22210(3).

Detroit Fire Department- R 325.22112(2)

EMS

Why codify something in law that is not DHHS opposes this comment. Rules are guidelines

permanent. The name field study

implies an end.

for the laws, which are codified in the Public Health

Code. This rule specifically allows MCAs the ability

to do a field study for an alternate destination if

they choose to do so, based on local needs of its

citizens. Special studies is covered in more depth

under Rule 214.

Robert Olkowski

Detroit Fire Department- R 325.22113(1)

EMS

Detroit Fire Department- R 325.22114 Title

EMS

Once again should be will not

DHHS agrees. "Shall" reinstated in document and

"may" deleted.

DHHS opposes this comment. A PSRO is a group of

The use of organization implies it is a

separate entity should be changed to healthcare professionals that monitor the quality

committee, section or division

of medical care that is provided in a particular

geographical area.

Robert Olkowski

Detroit Fire Department- R 325.22114

EMS

The use of organization implies it is a

DHHS opposes this comment. A PSRO is a group of

separate entity should be changed to healthcare professionals that monitor the quality

committee, section or division

of medical care that is provided in a particular

geographical area.

Robert Olkowski

Detroit Fire Department- R 325.22117

EMS

A minimum of

DHHS agrees. "A minimum of…" has been added to

the rule language for those facilities keeping

records longer.

Detroit Fire Department- R 325.22118(1)

EMS

Should read via the application

prescribed by the department no later already included in this rule.

than 30 days after removal.

DHHS opposes this comment. This statement is

Robert Olkowski

Detroit Fire Department- R 325.22118(1)

EMS

Detroit Fire Department- R 325.22123(1)

EMS

Is responsible for the removal of

DHHS opposes this comment. This statement is

already included in this rule.

DHHS agrees. "exceptional circumstances" will be

defined by DHHS in policy. "within a reasonable

time" has been reinstated due to error.

Define

Robert Olkowski

Detroit Fire Department- R 325.22123(2)

EMS

Provider

DHHS opposes this comment. The definition of

emergency medical servies personnel is in Section

20904(5) of PA 368 of 1968

Robert Olkowski

Detroit Fire Department- R 325.22123(2)

EMS

Detroit Fire Department- R 325.22123(2)

EMS

Detroit Fire Department- R. 325.22126(1)

EMS

Detroit Fire Department- R. 325.22126(1)

EMS

Detroit Fire Department- R. 325.22126(1)

EMS

Detroit Fire Department- R 325.22126(2) (STRIKE)

EMS

Detroit Fire Department- R 325.22126(2)

EMS

Detroit Fire Department- R 325.22126(2)

EMS

Detroit Fire Department- R 325.22126(3)

EMS

Detroit Fire Department- R 325.22126(3)

EMS

Detroit Fire Department- R 325.22126(4)

EMS

Detroit Fire Department- R 325.22126(4)

EMS

transports

DHHS opposes this comment. The Rule is clear and

this is a preference of wording.

DHHS opposes this comment.

makes

/or

DHHS opposed this comment. The current

proposed rule has "or" in the rule.

DHHS opposes this comment. This is an "or"

statement.

DHHS opposes this comment. The Rule is clear and

this is a preference of wording.

DHHS opposes this comment. This language was

moved to R 325.22210(4)

DHHS opposes this comment. This is an "or"

statement.

DHHS agrees with this comment. "Shall" has been

reinstated and "must" deleted.

DHHS opposes this comment. This is an "or"

statement.

DHHS opposes this comment. This is an "or"

statement.

And/

Actions taken

Why is this removed?

And

must

and/

DHHS opposes this comment. This is an "or"

statement.

language should be consistent

throughout the rules it should either

be will or shall when discussing

actions, not both.

DHHS opposes this comment. The rules have been

vetted and approved by both the LARA-

Administrative Rules Division and the Legislative

Service Bureau. See LSB and Admin Rule style

guides.

Robert Olkowski

Detroit Fire Department- R 325.22127(2)

EMS

other

DHHS opposes this comment. The rules have been

vetted and approved by both the LARA-

Administrative Rules Division and the Legislative

Service Bureau. See LSB and Admin Rule style

guides.

Robert Olkowski

Detroit Fire Department- R 325.22127(3)

EMS

Detroit Fire Department- R 325.22131(a)

EMS

Detroit Fire Department- R 325.22131(d)(i)

EMS

Detroit Fire Department- R 325.22132(a)

EMS

exercising its rights to conduct a

the

DHHS opposes this comment. This is a wording

preference.

DHHS opposes this comment. This is a wording

preference.

DHHS opposes this comment. See Section 3 of the

State EMS MEDCOM plan.

MFR’s not required to have hospital

communication

Once again need consistent language DHHS opposes this comment. "will" is the correct

throughout the document.

Needs to remain consistent

throughout document.

phrase.

Detroit Fire Department- R 325.22133

EMS

DHHS agrees with this comment. "ambulance

operation" should be "life support agency"

Replaced "life support agency" for "ambulance

operation" twice in the subrule.

Robert Olkowski

Detroit Fire Department- R 325.22133(a) STRIKE

EMS

Looks like this was added to

R325.22132(G)

DHHS opposes this comment. 22133(a) was

duplicate language from Section 20921(1)(a) of the

public health code.

DHHS opposes this comment. 22133(b) was

duplicate language from Section 20921(1(b) of the

public health code.

DHHS opposes this comment. All mention of "shall"

was replaced with "must" or "may" depending on

usage throughout the document.

DHHS opposes this comment. This was duplicate

language from Section 20923(6) of the public health

code.

Detroit Fire Department- R 325.22133(b) STRIKE

EMS

Why was this removed

Consistency

Detroit Fire Department- R 325.22133(c)

EMS

Detroit Fire Department- R 325.22133(g) STRIKE

EMS

Why was this removed

Change criteria to protocol

Detroit Fire Department- R 325.22134(a)

EMS

DHHS points out that in the public hearing

document, "criteria" was already removed and

replaced with "protocol".

Detroit Fire Department- R 325.22134(a)

EMS

Need to retain original language. New DHHS opposes this comment. It is the

language appears to put the

responsibility on agency to follow all

three. Previous language states that

protocols need to be in compliance

with the law.

responsibility of the life support agency to comply

with approved MCA protocols. MCA protocols are

vetted and approved through the emergency

medical services coordination committee quality

assurance task force.

Robert Olkowski

Detroit Fire Department- R 325.22134(b)

EMS

Detroit Fire Department- R 325.22135 Title

EMS

Detroit Fire Department- R 325.22135 Title

EMS

Detroit Fire Department- R 325.22135(1)

EMS

Detroit Fire Department- R 325.22135(1)(e)

EMS

Detroit Fire Department- R 325.22135(2) STRIKE

EMS

Detroit Fire Department- R 325.22135(2)

EMS

Detroit Fire Department- R 325.22136 TITLE

EMS

Why wasn’t this changed to reflect the DHHS opposes this comment. Both 134a and 134b

language in previous point.

Should be for all air ambulances not

just rotary

have simliar language now.

DHHS opposes this comment. Aircraft transport

operations is covered under R 325.22139.

DHHS opposes this comment. Rotary aircraft can be

a part of an ambulance operation.

Consistency

DHHS opposes this comment. Rotary aircraft can be

a part of an ambulance operation.

Is this legal?

DHHS opposes this comment. Was a requirement of

certificate of need in the past.

Why was this section removed

consistency

DHHS opposes this comment. Certificate of need

not in existance anymore

DHHS opposes this comment. Language is correct in

the rule.

consistency

No change needed. Life support agency and vehicle

in LSB edits before public hearing.

Detroit Fire Department- R 325.22137 TITLE

EMS

Detroit Fire Department- R 325.22137(a)

EMS

consistency

DHHS opposes. Language is correct in the title.

Will not

DHHS opposes this comment. The rules have been

vetted and approved by both the LARA-

Administrative Rules Division and the Legislative

Service Bureau. See LSB and Admin Rule style

guides.

Robert Olkowski

Detroit Fire Department- R 325.22137(e)

EMS

consistency

DHHS opposes this comment. The rules have been

vetted and approved by both the LARA-

Administrative Rules Division and the Legislative

Service Bureau. See LSB and Admin Rule style

guides.

Robert Olkowski

Detroit Fire Department- R 325.22139

EMS

Detroit Fire Department- R 325.22181(1)

EMS

Most covered in R325.22135. Why is it DHHS opposes this comment. This section is

needed twice

The initial

specifically for aircraft transport operations

DHHS opposes this comment. The certificate of

compliance can change when the vehicle is

remounted.

Robert Olkowski

Detroit Fire Department- R 325.22181(4)

EMS

will

DHHS opposes this comment. The rules have been

vetted and approved by both the LARA-

Administrative Rules Division and the Legislative

Service Bureau. See LSB and Admin Rule style

guides.

Detroit Fire Department- R 325.22181(6)

EMS

Why codify something in law that may DHHS opposes this coment. Some patient

only occur. What is remounter is not

part of these organization or an

organization that may not be

“approved” by the state yet.

created

compartments are remounted multiple times.

These organizatizations recognize eligible

companies in the work truck industry for quality

business practices and standards.

Robert Olkowski

Detroit Fire Department- R 325.22182(2)

EMS

DHHS opposes this comment. Word preference.

Detroit Fire Department- R 325.22183

EMS

Language would be better suited in

Agency requirements through a written

policy. A separate rule is not

necessary.

DHHS opposes this comment.

Robert Olkowski

Detroit Fire Department- R 325.22184(2)

EMS

Detroit Fire Department- R 325.22184(3)

EMS

must

DHHS agrees. Replaced with "shall".

Need to define

both

DHHS opposes this comment. The word

"prominently" is defined in the dictionary. No

further clarification needed.

Robert Olkowski

Detroit Fire Department- R 325.22184(3)

EMS

DHHS agrees. "Both" added to rule language.

Robert Olkowski

Detroit Fire Department- R 325.22189 TITLE

EMS

Detroit Fire Department- R 325.22191(b)

EMS

Detroit Fire Department- R 325.22191(b)

EMS

Helicopters are also aircraft does this This is for fixed wing only. Helicopters are not fixed

mean them as well?

must

wing.

DHHS agrees. "Shall" reinstated and "may" deleted.

will

DHHS opposes this comment. The rules have been

vetted and approved by both the LARA-

Administrative Rules Division and the Legislative

Service Bureau. See LSB and Admin Rule style

guides.

Robert Olkowski

Detroit Fire Department- R 325.22191(c)

EMS

will be

DHHS opposes this comment. The rules have been

vetted and approved by both the LARA-

Administrative Rules Division and the Legislative

Service Bureau. See LSB and Admin Rule style

guides.

Robert Olkowski

Detroit Fire Department- R 325.22191(d)

EMS

Detroit Fire Department- R 325.22194

EMS

Detroit Fire Department- R 325.22201(1)

EMS

Medical Control Authority

DHHS opposes this comment. DHHS provides for

inspections of life support vehicles, not MCA's.

DHHS agrees. "Shall" reinstated in rule and "may"

deleted.

DHHS opposes this comment. The word "Code" is

definedin Rule 101.

may

What code is being referred to PHC,

Code of Ethics. Ambiguous language

does not belong in law.

Robert Olkowski

Detroit Fire Department- R 325.22207(f)

EMS

Detroit Fire Department- R 325.22210(1) STRIKE

EMS

DHHS opposes this comment. This is an "or"

statement.

DHHS opposes this comment. This is duplicate of

language already in Section 20918(6) of the public

health code.

And/

Why is this removed

Robert Olkowski

Detroit Fire Department- R 325.22210(1)

EMS

Detroit Fire Department- R 325.22210(1)

EMS

Detroit Fire Department- R 325.22210(2)

EMS

Detroit Fire Department- R 325.22210(3)

EMS

Detroit Fire Department- R 325.22210(4)

EMS

Detroit Fire Department- R 325.22210(5)

EMS

Detroit Fire Department- R 325.22210(5)

EMS

And/

and

DHHS opposes this comment. This is an "or"

statement.

DHHS opposes this comment. This is an "or"

statement.

DHHS opposes this comment. This is an "or"

statement.

DHHS opposes this comment. This is an "or"

statement.

DHHS opposes this comment. This is an "or"

statement.

DHHS opposes this comment. This is an "or"

statement.

and

and/

Need an appeals process why was this DHHS opposes this comment. This is a duplicate.

removed.

The MCA appeals process is covered under R

325.22126.

Robert Olkowski

Detroit Fire Department- R 325.22213(3)

EMS

improvement

DHHS opposes this comment. The intent is to

ensure that "quality data" is available to the MCA's.

Having access to that data, will allow them to seek

improvements to the EMS system.

Robert Olkowski

Detroit Fire Department- R 325.22214(1)

EMS

Detroit Fire Department- R 325.22214(1)(e)

EMS

Detroit Fire Department- R 325.22214(1)(e)

EMS

Detroit Fire Department- R 325.22214(2)(b)

EMS

the

DHHS agrees to replace "this" with "the".

will

DHHS opposes this comment. This is a "may"

statement.

DHHS opposes this comment. "Study" is the correct

word usage.

DHHS opposes this comment. The rules have been

vetted and approved by both the LARA-

Administrative Rules Division and the Legislative

Service Bureau. See LSB and Admin Rule style

guides.

remove

Remove not necessary based upon

location of duty under paragraph 2

Robert Olkowski

Detroit Fire Department- R 325.22214(2)(d)

EMS

Remove not necessary based upon

location of duty under paragraph 2

DHHS opposes this comment. The rules have been

vetted and approved by both the LARA-

Administrative Rules Division and the Legislative

Service Bureau. See LSB and Admin Rule style

guides.

DHHS opposes this comment. The rules have been

vetted and approved by both the LARA-

Administrative Rules Division and the Legislative

Service Bureau. See LSB and Admin Rule style

guides.

Detroit Fire Department- R 325.22214(2)(h)

EMS

Remove not necessary based upon

location of duty under paragraph 2

Robert Olkowski

Robert Dunne

Detroit Fire Department- R 325.22216(c)

EMS

Non medical care related aspects

DHHS opposes this comment. The MCA protocol

outlines who is responsible for the particular type

of scene. Also located in Section 333.209967 of the

Public Health Code.

Detroit Fire Department- R 325.22218

EMS

Why is this necessary? The word may DHHS opposes this comment. This Rule gives the

makes it sound optional.

MCA the ability to implement a protocol for non-

emergent patients. Currently, MCA's do not

currently have this authority.

Medical Director for

R 325.22111(4)

The part where they get rid of requiring DHHA opposes this comment. This was not part of

Detroit East MCA (DEMCA)

X number of ambulance available to

the 911 system 24/7/365 is a problem

if implemented. I could see agencies

(particularly private) financially

justifying not providing ambulance

service on certain days/times as not

cost effective.

the rule change

Robert Dunne

Medical Director for

Detroit East MCA (DEMCA)

325.22133

pg 13 sec A and B are covered twice

already in the code and should be

removed.

DHHS opposes this comment. No duplication.

DHHS opposes this rule. In rural areas, some

Medical Director for

R 325.22202(1)(e)

pg 23 sec E- "provided the individual

Detroit East MCA (DEMCA)

meets all applicable criteria, and or is Medical Directors are retired from practice and an

approved by the department." Has this exception may need to be made by the

come up before (no qualified

individuals available to serve as

medical director, unqualified

individual approved by the

Department.

department)? If it isn't a huge problem

somewhere, is it wise to change the

"and" to an "or"?

Robert Dunne

Medical Director for

R 325.22214(1)(a)(iii)

pg 29 sec "Published studies

DHHS opposes this comment. The MCA only needs

Detroit East MCA (DEMCA)

supporting the safety and efficacy of its to provide 1 of the 3 criteria listed in I, ii, and iii.

applications within the emergency

setting must also be submitted." This

could potentially prevent an MCA from

studying an established intervention

commonly performed outside of the

emergency setting if there are no

previous data. It might be worthwhile

to add teh caveat that these should be

provided if available, as with the

previous sentence in the section.

Robert Dunne

Medical Director for

Detroit East MCA (DEMCA)

R 325.22214

As far as removing the IRB section on DHHS Agrees. After reviewing the language with

pg 29, with the addition of section H, it DHHS Institutional Review Board staff, the language

looks like they are trying to exempt

has been changed to the following: (2) A medical

nonpublished special studies from IRB control authority that intends to establish a

requirements such as unpublished

QA/QI or investigation of a new

established intervention outside of

research. It is a bit weird that

protocol involving skills, techniques, procedures, or

equipment that is not included in this state’s

approved curriculum, and is not consistent with its

level of licensure requires a special study and must

publishing or not is the standard for IRB comply with all of the following:

approval or not- in general the

(a) Provide any available studies or supporting

standard for IRB approval is whether or documentation indicating the practice has been

not human subject research is taking studied. Published studies supporting the safety

place. This could be modified to "If the and efficacy of its applications within the

study amounts to human subjects

resarch as defined by the common

rule, Institutional Review Board

approval or the letter of exemption

status shall be submitted for the

study."

emergency setting must also be submitted.

(b) The medical control authority provides an

educational outline that will be implemented to

instruct the emergency medical services personnel

in the new skill, technique, procedure, or

equipment, as well as the verification of

competency that will be utilized and the plan for

continued competency assurance, such as a

continuing education plan.

for the practice, signed by the medical director for

the medical control authority participating in the

special study.

(d) The medical control authority shall submit

protocols that will be used for the practice.

(e) Identify life support agencies involved in the

Robert Dunne

Medical Director for

Detroit East MCA (DEMCA)

R 325.22210(5)

R 325.22212

On page 27 the appeals section being Response to Robert Olkowski's comment. No

removed is covered on page 28.

changes needed.

Medical Director for

Detroit East MCA (DEMCA)

On page 28 the appeals sections that Response to Robert Olkowski's comment. No

they want to remove are covered in the changes needed.

paragraph above.

Medical Director for

Detroit East MCA (DEMCA)

R 325.22191(d)

Section d on page 20 needs to be

removed. This caused massive issues

with an agency that was found to be

non-compliant and had major

compliance issues. The state had to

wait 15 days before acting, knowing

the agency was a risk to the welfare of

the public.

This was already removed in the draft rules

Robert Dunne

Medical Director for

R 325.22189?

On page 19, the section about aircraft Response to Robert Olkowski's comment. No

Detroit East MCA (DEMCA)

litter layout, I do not know enough

about why it is there or why people

want it removed to have an opinion

either way. Same thing with sections

on page 14. On page 12, the two

sections being removed are part of the

public health code. I do not see why

they need to be part of the rules as

well.

changes needed.

;