Special Funding to Multi-County EMS Agencies

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							Special Funding to Multi-County EMS
             Agencies
     Which Serve Rural Areas


   A Position Paper of the Regional EMS Agency
            Administrators of California




                   August 2010
       Special Funding to Multi-County EMS Agencies
                  Which Serve Rural Areas

                   A Position Paper of the Regional EMS Agency
                             Administrators of California




EXECUTIVE SUMMARY

We appreciate the opportunity to provide input to the EMS Authority on proposed
changes to the EMS #104 document, “Draft EMSA Policy for Funding Regional and
Multi-County EMS Agencies with State General Funds”. Funding for regional EMS
agencies is an incredibly important issue and we look forward to working collaboratively
towards a reasonable and effective resolution.

As the State and local areas are doing their best to deal with difficult economic times,
many decisions are being made to assure that essential services are being maintained
as much as possible. As such, it is imperative that the state, counties, and regional EMS
agencies work cooperatively to insure that the current fiscal challenges do not result in a
complete reversal of the years of progress made in bringing basic emergency medical
services to the residents and visitors to the largest geographical portion of the State of
California . . . our rural counties.

The EMS Authority has taken the position that the changes that have occurred in
regional affiliation over the past two years are a sign that the system is in chaos and that
a potentially costly redesign of the entire system is necessary. We would argue that
nothing has been presented by the EMS Authority to justify such a radical response and
we are very concerned that the hastily crafted proposals being forwarded by the EMSA
could destabilize EMS regions.

The current publication,”Funding of Regional EMS Agencies with State General Funds”
(EMS 104), has, for nearly three decades, provided the rules for regional EMS system
configured and funding. We feel strongly that If the EMS Authority had simply chosen to
follow the EMS 104 guidelines, counties would have made their decisions to change
regional affiliations, the funding would have been adjusted based upon those new
affiliations, and the regional EMS Agencies assuming responsibility for those new
counties would have created the most efficient EMS delivery system for the incoming
county(s).




                                                                                           2
HISTORY OF RURAL EMS REGIONS


Wedsworth Townsend Act – 1970

During the 1970s, a number of California counties established paramedic programs
under the Wedsworth Townsend Act (1971-SB772). However, due to the high cost and
resources needed to implement and maintain these new programs, they were generally
limited to the more densely populated urban areas of the state which had adequate
financial, and local medical resources to support them.

A lack of resources to support system design, implementation and oversight meant the
vast majority of rural counties across the state were unable to take advantage of the
provisions of Wedsworth Townsend. Ambulance services in most rural areas during this
period were provided by small, often volunteer ambulance providers at a first aid level
(with as little as 8 hours of training), or occasionally, at a basic life support level.
Ambulance services were often a sideline of local mortuaries, service stations, or local
community organizations.

While the rural counties generally produce a much smaller EMS call volume than the
larger urban counties, unique problems faced the less populated areas which,
geographically, covered nearly 80% of the state. The impact of local tourism, long
response times, inadequate training and equipment availability, limited time availability of
local volunteers, and long transport times to local hospitals (many of which did not have
the necessary resource to care for high acuity patients) all emphasized a special need
for major system improvements in these areas.

In 1973, Congress passed the Federal Emergency Medical Services Systems Act
(PL93-154) which provided funds for the establishment of regional EMS systems and
training across the country. Utilizing these federal funds, the first four EMS regions were
established in California; Nor Cal, Sierra-Sacramento Valley, North Coast, and Inland
Counties EMS Agencies. These funds were a first step in bringing the newly introduced
federal prehospital and EMS system standards to some of the rural areas of the state.
However, for reasons stated previously, the challenge of implementing Advanced Life
Support (ALS) or paramedic services to the rural areas remained. Generally speaking,
most of the new regions focused their initial efforts on establishing stable Basic Life
Support (BLS) systems in their rural areas, and implementing ALS services only in the
larger urban areas of the regions. As a result, the rural areas of most of these regions
still maintained, at best, a basic life support service level.

To address the problem of the rural areas, the Office of Statewide Health Planning and
Development (OSHPD) under the Health Manpower Pilot Project established a pilot
project in 1976 which allowed for the training, certification, and utilization of Limited
Advanced Life Support (LALS) or EMT-IIs in underserved areas of the state. During the
first years of the project the target areas of Sacramento, South Lake Tahoe, Redding,
and Merced began the development and implementation of EMT-II programs. In
subsequent years, some counties in the North Coast area also began basic EMT, and
EMT-II training in areas that had resources to support these programs.


                                                                                          3
By the end of the 1970s, EMS service levels and practices varied from one community to
next. Only small pockets of the state were serviced by paramedic or EMT II providers.
While urban paramedic programs collectively covered a significant portion of the static
population base, geographically, the majority of the state remained underserved in terms
of the federal target standards established under the federal EMS Act of 1973. A family
traveling across California, or even across any given county, could repeatedly drive
through areas of exceptional prehospital coverage, to areas with virtually no coverage
simply by crossing over an invisible line. If an accident did occur, it was only the luck of
the draw that determined the care they could expect to receive.


EMS Act - 1980

In 1980 the California State Legislatures adopted the EMS Act in order, in part, to
establish for the first time a standardized “statewide” EMS system to serve the entire
population of California. This intent is evidenced in the following sections of the Health
and Safety Code:

       1797.5. It is the intent of the Legislature to promote the development,
       accessibility, and provision of emergency medical services to the people of the
       State of California.

       1797.2. It is the intent of the Legislature to maintain and promote the
       development of EMT-P paramedic programs where appropriate throughout the
       state and to initiate EMT-II limited advanced life support (LALS) programs only
       where geography, population density, and resources would not make the
       establishment of a paramedic program feasible. . .(Emphasis added)

       1797.1. The Legislature finds and declares that it is the intent of this act to
       provide the state with a statewide system for emergency medical services . . .
       (Emphasis added)

In order to ensure the expansion of ALS or EMT-II services to all areas of California
meant that a mechanism was needed to fund these programs since federal funding for
EMS Regions had been eliminated by1981. As a result, the legislature earmarked a
portion of State general funds specifically for the development and maintenance of these
programs to be disbursed by the State EMS Authority (EMS Authority)

Section 1797,108 allowed for the EMS Authority to consider two levels of funding based
upon the availability of state dollars. The EMS Authority was authorized to 1) provide
funding assistance for all Local EMS Agencies (LEMSAs) and /or 2) provide funding to
multi-county LEMSAs (Regions) serving rural areas with high levels of tourism.


         1797.108. Subject to the availability of funds appropriated therefore, the
       authority may contract with local EMS agencies to provide funding assistance to
       those agencies for planning, organizing, implementing, and maintaining regional
       emergency medical services systems. In addition, the authority may provide
       special funding to multi-county EMS agencies which serve rural areas with
       extensive tourism, as determined by the authority, to reduce the burden on the


                                                                                             4
       rural EMS agency of providing the increased emergency medical services
       required due to that tourism.

Consistent with the intent of the legislature, the limited funding available for LEMSAs
was made available only to the rural regions which were identified by the EMS Authority
as the areas of greatest need. State general funding replaced federal funding in the four
initial regions of the state. Three additional regions were formed between 1981 and 1997
including: Mountain-Valley EMS, Central California EMS, and Coastal Valleys EMS.
These three regions also became recipients of State General funding which was
allocated by a formula outlined in EMSA’s publication EMS 104 which was based upon;
1) a standard base amount per region, 2) number of member counties and, 3) regional
population. Up to fifty percent (50%) of the cost of providing EMS administration in the
various regions was allowed to be provided by the state.

In the last thirty years, as a direct result of state funding, regional EMS agencies across
California have made giant strides in most rural areas of the state to form cohesive,
effective, and efficient EMS delivery systems. Almost all rural counties are now served
by paramedic level response services, ensure rapid transport of critically injured patients
directly by helicopter or through inter-facility transports (IFT) to designated trauma
centers. Policies have been developed, or are being developed, that integrate direct
transport of STEMI , stroke, major burns, and pediatrics to appropriate specialty care
centers. Effective EMS data and quality improvement systems have also been enacted.
Generally speaking, the standards for training, provider performance standards,
equipment requirements, treatment standards, medical control, and quality improvement
in the rural areas now match that of the urban areas. While some system deficiencies
still remain, these advancements for the most part have made the intent of the
legislature to develop a standardized, statewide EMS system a reality.



THE PROBLEM - 2010

Since state funding for rural regions was established in the early 1980s, the lack of
regular augmentation and subsequent reductions in these funds has created a growing
challenge for regional agencies to keep up with the rising cost of maintaining EMS
services in the rural areas. As a result of these reductions, rural counties began taking
on more and more fiscal responsibility for administering local EMS systems by
increasing member county contributions and local fees. By 2008, a study by the regional
administrators showed that the state general funds supporting regional systems had
been reduced from a maximum of 50% of total cost, to only 27%. Local matching funds
at that point accounted for 73% of the total funding for these programs. While it is
certainly a reasonable goal for rural counties to eventually assume full financial
responsibility for their EMS programs, several factors need to be taken into
consideration.

Even prior to the current economic crisis, most small rural counties had not financially
grown to the point that they could fully support the local administration of EMS systems
on their own. The current economic recession in California has made it extremely
difficult for these small counties to continue to maintain their current level of support for
EMS systems, and virtually impossible to assume any greater financial responsibility.
Counties across the state are making unprecedented cuts in local programs, eliminating


                                                                                            5
many other important programs altogether, and reducing staff size dramatically.
Regional EMS Agencies have followed suit and have reduced program, staff, travel, and
overhead costs to a bare minimum.

The necessity for increases in local funding has also had another unintended
consequence. Larger counties in EMS regions which often have had the medical
response resources (e.g. air ambulances) and medical facilities necessary for a
complete EMS system design, have less incentive to remain in a rural region. These
counties which may have the ability to exist as a single county LEMSA have been put
into a situation in which they have to weigh the reduced financial benefit of continued
membership in a regional system with the lack of autonomy in administering there own
EMS programs. While the loss of these counties may free up some state funds to be
returned to the collective state regional funding pot, the reduction in key resources in
these rural EMS systems adds to the complexity of administering these programs. The
recent decision by Napa County to leave Coastal Valleys, and the potential decision of
Stanislaus County to leave Mountain-Valley can at least partially be attributed to this
phenomenon.

Finally, rising local costs to smaller regional counties has led some counties to
reevaluate their affiliation with their regional agency. The current economic conditions
have forced these counties to hunt for a “better deal” in terms of county cost and service
levels which has created an unprecedented atmosphere of LEMSA shopping. Some of
the recent changes, and proposed changes in the northern section of the state, may
certainly have been effected by this problem.

While changes in county membership create challenges for regional LEMSAs, these
challenges are not insurmountable. Movement of counties from one region to another,
and the loss of a member county that decides to establish their own LEMSA, are
inevitable in the healthy evolution of EMS systems in the state. These changes have
been occurring since the regions were initially formed, and will continue as the member
counties grow and local needs change. Regional LEMSAs have adjusted to these
changes and will continue to adjust.

However, there is a potential challenge on the horizon that may be insurmountable.

Unfortunately, the current economic recession is also having a dramatic effect on state
finances which in turn poses a significant threat to the state support of regional LEMSAs.
If these funds were to be significantly reduced (and any reduction at this point would be
significant), or eliminated, rural counties across the state would be left with few choices.
They could, 1) choose to eliminate all ALS programs and revert back to a BLS service
level for prehospital care, or 2) attempt to maintain an EMS system either alone, or with
adjacent counties without adequate funding. Unfortunately, the end result of option #2
would probably not be much different than option #1 because if a LEMSA does not
maintain adequate funding to maintain all provisions of the EMS 101 system
requirements, the EMS Authority would be forced to disapprove their EMS Plan.

The challenge facing the EMS Authority and their regional partners in this depressed
economic environment is, 1) to ensure that limited state general fund resources are used
effectively and efficiently, and 2) to ensure we have a reasonable plan in place to be
able to justify to the state decision makers that regional funding must continue.



                                                                                           6
THE STATE EMSA AUTHORITY’S ANALYSIS OF THE PROBLEM AND
PROPOSED SOLUTIONS

In an attempt to address the issues listed above, the EMS Authority has presented two
proposals; 1) “FY2011 Regional EMS Agency Funding Grant Program Fact Sheet,”
dated July 21, 2010, and 2) “Draft EMSA Policy for Funding Regional and Multi-County
EMS Agencies with State General Funds’ released in early August but dated
September 2010.

In the July document, the EMS Authority provides a very brief and questionable analysis
of the current regional issues and, based upon that analysis, proposes major changes in
the configuration and funding requirements for EMS regions. The rational used by the
EMS Authority for the proposed changes are presented in the July 21st document and,
even thought the EMS Authority had abandoned many of there original changes in the
September proposal, much of the rationale for creating “EMS System Groupings”
continues into that proposal.

The regional administrators strongly question the basic assumptions used by the EMS
Authority in formulating their rational for major system change including the concept of
“area groupings” and the proposal to allow limited state funds be used to support non-
rural LEMSAs. We not only believe that the EMS Authority’s analysis of the current
situation is flawed, but that the direction proposed by the Authority based upon those
faulty assumptions could result in a significant degradation of EMS services in rural
communities throughout the state of California.

Under the section entitled “Background,” the July document states;

     “California’s regional EMS agencies have undergone significant change
     during the past two years and more change is expected. These changes
     have moved the state away from regional areas that are based on logical
     patient flow and resulted in fragmentation in the local EMS system,
     geographically noncontiguous regions, and diminished efficiencies. Half of
     California’s EMS regions as they exist now are non-contiguous and/or are
     bisected by geographical barriers.”

In the section entitled “Purpose,” the document goes on to say;

     “Therefore, it is proposed that we move away from the current process which
     provides funding based primarily on ad hoc county groupings and
     population to a process that is developed to support logical, effective
     geographic regions. “

While the regional administrators recognize that there have been “significant changes”
over the past year in regional configuration, and that there may be more in the future, we
do not agree with the assumption that has been made that these changes will
necessarily resulted in illogical flow patterns, fragmentation, or diminished efficiencies.




                                                                                           7
The EMS Authority has placed, what we believe may be an overemphasis of on two
concepts in the Background and Purpose of their July document; 1) the importance of
contiguous county membership in a region, and 2) an oversimplification of how patient
flow patterns effect regional administration.


Contiguous Counties

The EMS Authority has suggested that if there are counties in a region that are non-
contiguous, this will automatically result in system “fragmentation” (a term that is
undefined in the document), and diminished efficiencies.

EMSA staff has stated on numerous occasions that they want to guard against the
possibility of the irresponsible “Ad Hoc” grouping of counties forming a region and
expecting state general funding support. The example that has been given to emphasize
this concern has included the formation of a region by a county from Southern, Central
and Northern California.

We agree that in terms of logistics, this model would be unnecessarily costly to
administer and, therefore, should probably not be supported with state funding.
However, this concern is probably unfounded. Counties have the statutory responsibility
to decide the make-up of their LEMSA and to suggest that such an illogical decision
would be made by local elected officials does not give them the credit that they deserve.

The recent, and proposed changes in county affiliations that have occurred do not come
close to the scenario described above. At worst, there would be no more than a single
county separating member counties. While this may pose a logistical issue in terms of
things like travel for meetings, the designated LEMSA would still have the full
responsibility to ensure all EMS system standards as established by the EMS Authority
are met for each of their member counties. The policies, procedures, contracts and
agreements established by a LEMSA are specific to their member counties, regardless
of whether they are contiguous or not. Triage and patient destination protocols, which
will be discussed further below, are also specific to the member counties whether or not
they are adjacent. North Coast EMS has had a non-contiguous region for twenty-five
years and as far as we understand, the EMS Authority has not identified any problems
associated with that configuration.

In their proposals, the Authority has suggested the formation of seven new EMS
groupings. Because EMSA cannot compel counties to join a region, they have no means
to ensure the hoped-for results of reducing “fragmentation” will in fact be realized.
Arguably there is equal likelihood that the implementation of their proposal will increase
the fragmentation EMSA finds troublesome.

Under the proposed model, the grouping areas contain many counties which have little
or no affiliation whatsoever. The possibility, and more likely the probability, of counties
affiliating in these larger regions being non-contiguous is very real because these
regions are much larger in size and contain many more county jurisdictions. For
example, if San Bernardino County elected to withdraw from ICEMA, a non-contiguous
affiliation of Mono, Inyo, and Imperial would be a real possibility since these are the most
rural and remote counties in that region.



                                                                                          8
While we believe that it may be reasonable to encourage that regions be formed by
contiguous counties, there does not seem to be any compelling reason to mandate such
a structure especially if the configuration of regions best meets the needs of the member
counties.



Patient Flow Patterns

The second assumption made by the EMS Authority is that counties can be somehow
grouped together based upon an over-simplified analysis of local patient flow patterns.

In a perfect world, the state would be divided into predesigned regions which contain a
centrally located county or counties which house all of the region’s trauma and specialty
care centers. This central “hub” would be surrounded by a number of adjacent rural
counties which would feed their critical patients directly, or via Inter-facility transport
(IFT) to the central hub. If this was the case, it could make sense to have a single
LEMSA oversee that system and the boundary lines of these regions would be obvious.
Unfortunately, this is not the case, and probably never will be.

In reality, counties and regions across the state often send trauma patients one
direction, STEMI patients another, and burns or pediatric patients yet another. The
tertiary care centers that receive these patients may be in the sending region or within
the county under another LEMSA jurisdiction, or in some cases, in another state.
Further complicating the issue is that the location of specialty care centers change as
new ones are designated, and others close. LEMSAs across the state, whether they
are regions or single county entities, live with the reality that on-going cooperative
coordination of patient destination and patient flow across jurisdictional lines is part of
the job. Changing the configuration of regions every time a new trauma center is
designated or closed, thereby effecting the patient flow pattern is probably unrealistic
and unnecessary. Patient flow patterns are based upon closest appropriate facility
regardless of the LEMSA designation. Therefore, establishing and maintaining regional
borders that are based upon patient flow patterns is probably not realistic or practical.



EMSA PROPOSED GOALS

In their July 21st document, the Authority proposes seven goals to drive the distribution
of regional funding. Those goals are:

      Enhance patient care
      Ensure that regions are logically based on patient flow
      Ensure the best utilization of resources,
      Alleviate fragmentation,
      Encourage coordination among counties
      Provide stability within the regions
      Ensure efficient use of limited state funding




                                                                                              9
While we embrace the spirit of EMSA’s stated goals, we disagree that either of the
state’s proposals would achieve any of them. In fact we believe many of the proposed
changes will actually create greater instability, fragmentation, and additional cost.

The following are our concerns with each of the Authority’s changes specific to each of
the stated goals.


Enhance patient care

Enhancing patient care is obviously the goal of everyone concerned. However,
appropriate patient care cannot be assured unless there is a reasonable and stable
organization structure in place to implant and monitor EMS programs. Our concern is
that the proposals submitted by the State EMS Authority are going to dramatically
reduce system efficiency and stability, negatively impacting patient care statewide. The
specifics of our concerns are outlined below.


Ensure that regions are logically based on patient flow

In addition to the arguments made previously in terms of how patient flow patterns effect
regions, the following point should also be considered.

With the exception of one or two counties where no hospital exists, the vast majority of
prehospital transports from the scene to a hospital are made to hospitals located within
the county of origin. Only a small percentage of these patients are routinely transported
to a hospital located within another county or region. Of the prehospital patients that are
transported outside of the county, the majority are critical care patients being transported
to trauma centers, or other critical care centers and they have already been addressed
above.

To assume that any change in regional configuration will change patient flow patterns is
unrealistic. Again, patient flow patterns are based upon closest appropriate facility and
these patterns will not change regardless of LEMSA affiliation unless there is a change
in location, or medical capabilities of these facilities.


Ensure the best utilization of resources

This goal of ensuring the best utilization of resources is assumedly aimed at
strengthening the affiliation between rural areas with fewer medical resources, and
urban areas with more medical resources. However, simply creating an area grouping
does not create any more of an affiliation between counties than exists today. Each
County Board of Supervisors will decide whether to join the new EMS agency created
region or not, and no outside entity will be able to ensure that the resource rich counties
will chose to join or even stay in that region. As was stated earlier, LEMSAs, whether
single or multi-county, have for years addressed this issue of coordination through local
cooperation, MOUs and agreements, and it is highly improbable that any forced
affiliation is going to ensure better utilization of resources than the cooperative efforts
used today.



                                                                                         10
Alleviate fragmentation

Since the term ”fragmentation” is not clearly defined in the EMS Authority’s proposal, we
have to assume that it refers to the issues of contiguousness of regional counties and
patient flow patterns. These issues have already been addressed; however, the
following points on this subject need also be considered.

Once again, Section 1797.200 of the H&S Code clearly gives the sole authority of
establishing or designating a local EMS agency to the counties.

       1797.200. Each county may develop an emergency medical services program.
       Each county developing such a program shall designate a local EMS agency
       which shall be the county health department, an agency established and
       operated by the county, an entity with which the county contracts for the
       purposes of local emergency medical services administration, or a joint powers
       agency created for the administration of emergency medical services by
       agreement between counties

Several factors must be considered by local Boards of Supervisors in selecting a
LEMSA.
    Cost: Fixed and variable; current and future
    Resources available in the models being considered
    Commonality among counties
    Pros and cons of various governance models
    Opportunities for representation on the regional governing board
    Level and quality of services provided by LEMSAs being considered
    Historical affiliations and levels of cooperation
    Size of potential region and its effect on customer service
    Location of offices and meeting sights
    Geographic factors
    Political factors
    OES Regional affiliations
    Existing public health department affiliation with neighboring counties
    Etc.

These decisions are specifically granted to the county to ensure they receive the best
services possible as cost effectively as possible. While, from the outside, a county
decision may not always seem to be the most logical in terms of EMS system design, it
is the county’s decision. Very often these factors at the local level can outweigh
questionable, and arguably weak concerns such as contiguousness and patient flow
patterns. To scrutinize a county’s decision to join one region or another without
considering the reasoning behind these decisions, in terms of meeting local needs could
be considered shortsighted and presumptuous.


Encourage coordination among counties

The existing regional agencies have worked for decades with their member counties to
ensure continuity, collaboration and coordination among diverse and sometimes distant


                                                                                        11
affiliated counties. Regional LEMSAs also work closely with their immediate neighbors
whether they are a region or not, to coordinate cross border responses, mutual aid,
patient flow, quality improvement issues, etc. It is not clear what issues that the EMS
Authority feels are occurring that are not being addressed.

If the EMS Authority’s concern is referring to the need for coordination among counties
at the time that they are choosing their LEMSA affiliation, we would consider this an
encroachment on county autonomy and exceeding the state’s authority. As stated
previously, these decisions are statutorily granted to the counties and, by their very
nature may become political and are out of the EMS Authority’s, and LEMSA’s control.
Our focus collectively needs to be on encouraging coordination among counties and
neighboring system once the final decision by the counties are made.


Provide stability within the regions

One of the stated goals of the new EMS Authority’s regional proposals is to “stabilize”
the EMS System. While the current regional reconfigurations will result in changes
within the counties that join a different region, the regional agency that accepts those
counties will work together with EMS partners as they have done in the past to minimize
disruption and maintain existing patient care services. The proposed creation by the
EMS Authority of seven almost entirely new EMS regions, however, is likely to be vastly
more disruptive and destabilizing to the existing stable EMS regions and potentially
every county in the state.

At a minimum, substantial EMS Authority and LEMSA time, money, and energy will have
to be spent to assess and implement this new plan, and each county will be offered the
opportunity to decide whether or not to play in the new governance arena. Even larger
counties that have historically not wanted to join a region could now, with today’s ever
tightening budgets, join up. This would further dilute the limited State dollars and funnel
them to larger counties with less chronic financial need.

The new proposals will also potentially delay critical life saving programs across
California, which includes implementation of the new State RTCCs objectives, the State
Trauma Plan, trauma center designations, STEMI center designations, EMT 2010
changes, and CEMSIS data transmission to the EMS Authority, etc. This newly
proposed regional EMS landscape is likely to be far more costly to taxpayers and
disruptive to patient care than all of the current regional changes combined. It certainly
will create confusion and potentially awake substantial opposition as counties assess the
potential threat to their autonomy.

Finally, regional EMS Agencies require a dependable and consistent annual funding
source in order to survive from year to year. The EMS Authority’s proposal to
open access to state funding for “Regional LEMSAs” (as opposed to multicounty
LEMSAs) to an annual, biannual or even a five year competitive bid process is
problematic. This will continually leave regional EMS agencies in jeopardy of loosing a
significant portion of their annual revenue - with as little as two months notice that
funding will be denied for the next fiscal year.

State general funds are not special project funds that if denied, will simply postpone an
EMS system enhancement for a year. Rural regional agencies depend upon these


                                                                                          12
funds for their ongoing existence and to meet the minimum system requirements
demanded by statute and regulation. By creating an atmosphere of competition for
limited state dollars among groups of counties within one of the proposed regional
groupings could very well jeopardize the viability of rural EMS systems throughout
California, erode cooperation between counties, and will certainly stifle any incentive for
any long term planning or system upgrades.



Ensure efficient use of limited state funding

It appears that the EMS Authority has taken a position that bigger is always more
efficient when it comes to the size of EMS regions. While an argument could be made
that there is greater efficiency with greater numbers, there is also a law of diminishing
returns that comes into play when a regional LEMSA tries to serve too many counties at
once.

The EMS Authority has suggested that one of the regional groupings to be considered
include eighteen (18) member counties. The majority of the counties in this grouping are
currently members of a region and it is anticipated they will need to continue a regional
affiliation in the future. The concern regarding this proposal involves the logistics of
administering such a large geographic area.

EMS Authority staff has stated that an 18-county region is justified because of the
relatively low call volume and population in this particular regional grouping. However, a
factor that needs to be considered in terms of efficiency is the incredible number of
county boards, committees, and agencies that would be involved, let alone the number
of service providers, hospitals, dispatch centers, first response agencies, etc.
Overseeing and coordinating such a large number of entities by a single LEMSA is
certainly a recipe for failure. We would argue that a strong case could be made that
smaller EMS Regions with fewer member counties could prove to be a much more
efficient model.

As stated previously, the regional administrators share the common goal with the EMS
Authority to ensure that limited state funding is used as efficiently and effectively as
possible. However, we caution against making wholesale changes in a system when a
more reasonable approach may be available.




                                                                                         13
Response to the State EMS Authority’s “Draft EMSA Policy for Funding
Regional and Multi-County EMS Agencies with State General Funds’ dated
September 2010.


Since the EMS Authority chose to abandon all standard procedures in releasing their
proposed revisions to the EMSA 104 manual, the 76 page document was presented to
us without showing ‘track changes.’ This has complicated our analysis of the proposed
revisions significantly. Attempting to do a line-by-line comparison in the very brief time
allowed for this analysis has been unnecessarily time consuming and we strongly
suggest the Authority abandon this practice in all future iterations.

Our comments to the EMS Authority’s September proposal are included in Attachment C
of this document. However, our major concerns can be summarized by the following:

         The introduction of the concept of “area grouping” adds a level of complexity to
          the configuration and funding of EMS regions with no apparent benefit.

         The EMS Authority has removed most, if not all stipulations that the allocation
          of State General Fund dollars are to be limited to funding of rural EMS
          systems. This is a significant policy change which could have a devastating
          effect on the existing rural regions. These monies have historically been used
          to fund the areas of greatest need, and to abandon this policy, especially in
          light of the current economic crisis, could very well deal a death blow to ALS
          services in the rural areas of the state.

         Most references to transitional funding should a county join, or leave a region
          have been removed. In light of recent changes in the county membership of
          regions, this language is necessary to clarify, in advance of any change, what
          the rules shall be. We strongly suggest this language be reinserted and
          additional clarifying language be added (see suggestions below).



In seeking a solution to the issues currently facing EMS regions, the question needs to
be asked, “Is the system really broken, or are we simply going through change?” As
stated previously, change is inevitable and necessary in the healthy growth and
evolution of any system. As system requirements and local needs change, there are
bound to be adjustments. At times, those adjustments may be rather insignificant. At
other times, such as in times of economic instability, the need for more substantial
change may present itself.

The EMS Authority has taken the position that the changes that have occurred in
regional affiliation over the past two years are a sign that the system is in chaos and that
a potentially costly redesign of the entire system is necessary. We would argue that
nothing has been presented by the EMS Authority to justify such a radical response.

The current publication,”Funding of Regional EMS Agencies with State General Funds”
(EMS 104), has, for nearly three decades, provided the rules for regional EMS system
configuration and funding. If the EMS Authority had not chosen to react so impulsively to



                                                                                         14
the recent changes in regional affiliation, and simply chosen to follow the EMS 104
guidelines, counties would have made their decisions to change regional affiliations, the
funding would have been adjusted based upon those new affiliations, and the regional
LEMSAs assuming responsibility for those new counties would have created the most
efficient EMS delivery system for the incoming county(s). The EMS Authority has
presented no evidence to suggest that simply allowing the changes that have taken
place to run their natural course would in anyway have reduced the system effectiveness
or created system inefficiency.

Instead of taking a “knee-jerk” reaction and frantically making hasty, and potentially
devastating changes to a system that has proven historically successful in meeting the
legislative intent on the EMS Act, we suggest that the EMS Authority refocus their efforts
from a major redesign of EMS 104, to a more reasonable and stabilizing approach.




                                                                                       15
PROPOSED SOLUTIONS

As stated previously, the challenge facing the EMS Authority and their regional partners
in this depressed economic environment should be, 1) to ensure that limited state
general fund resources are used effectively and efficiently, and 2) to ensure we have a
reasonable plan in place to be able to justify to the state decision makers that regional
funding must continue.

In order to meet the above challenge, the Regional EMS Administrators propose the
following priorities in regard to ongoing regional system configuration and funding:

   1. The EMS Authority and the Regional Administrators work cooperatively and
      collaboratively to establish respective position papers which accurately and
      effectively justify the need to maintain State General Funding for rural EMS
      regions. These position papers, and an aggressive plan to disseminate them,
      should be prepared in advance of any legislative challenge regarding regional
      funding.

   2. Review and make revisions to EMSA 104 to ensure 1) the appropriate utilization
      of state general fund dollars, 2) increased stability of regional EMS systems, and
      3) facilitate a smooth transition in the event of any future changes in regional
      county membership. Specifically, these revision to EMSA 104 should include:

           a. A reiteration that State general funds continue to be utilized solely for
              rural EMS regions to ensure the viability of these fragile systems be
              maintained
           b. Ensure all regional agencies include the minimum system components
              and structure to justify a regional system
           c. Clarify the expected role and affiliation of larger counties within rural
              regions and their purpose to support the rural counties within that region
           d. Discourage “region jumping” by member counties to ensure system
              stability
           e. Ensure that state general funding allocation do not significantly fluctuate
              from year to year to ensure the ability for long term planning
           f. “Encourage,” but not mandate contiguous county participation in the
              regional design
           g. Provide a mechanism for the smooth transition of funding in the event
              there is a change in county membership within a region

   3. The EMS Authority and the Regional Administrators work cooperatively and
      collaboratively to establish a guideline paper for counties to assist them if a
      decision to change LEMSAs is under consideration to include consideration of;
      resources, contiguousness, patient flow patterns,etc.


Priorities 1 and 3 above would need to be developed as a cooperative effort between the
regional administrators and the EMS Authority with the first priority being the most urgent
of the two.

The changes suggested under priority two above are outlined in Attachment E of this
document.


                                                                                        16
CONCLUSION


These are certainly difficult economic times. As such, it is imperative that the state,
counties, and regional EMS agencies work cooperatively to ensure that the current fiscal
challenges do not result in a complete reversal of the years of progress made in bringing
basic emergency medical services to the residents and visitors to the largest
geographical portion of the State of California. . . our rural counties.

We appreciate the opportunity to provide input to the EMS Authority on this important
issue and look forward to working collaboratively toward a reasonable and effective
resolution.



    Central California EMS Agency                  Coastal Valleys EMS Agency
      (Fresno, Kings, Madera, Tulare)                 (Sonoma, Mendocino, Napa)
                Dan Lynch,                                  Bryan Cleaver,
               EMS Director                             Regional Administrator



                                                   Mountain Valley EMS Agency
     Inland Counties EMS Agency
                                                (Alpine, Amador, Calaveras, Mariposa,
       (San Bernardino, Inyo, Mono)
                                                             Stanislaus)
            Virginia Hastings,
                                                           Steve Andriese,
           Executive Director
                                                          Executive Director


                                                 Northern California EMS Agency
       North Coast EMS Agency
                                                (Glenn, Lassen, Modoc, Plumas, Sierra,
        (Del Norte, Humboldt, Lake)
                                                                Trinity)
             Larry Karsteadt,
                                                             Dan Spiess,
            Executive Director
                                                       Chief Executive Officer

                     Sierra-Sacramento Valley EMS Agency
    (Butte, Colusa, Nevada, Placer, Shasta, Siskiyou, Sutter, Tehama, Yolo, Yuba)
                                Victoria A. Pinette,
                                EMS Administrator




                                                                                        17
     ATTACHMENTS
                     Attachment A
                    State EMS Authority’s
“FY2011 Regional EMS Agency Funding Grant Program Fact Sheet,”
                     dated July 21, 2010



                     Attachment B
                      State EMS Authority’s
           “Draft EMSA Policy for Funding Regional and
      Multi-County EMS Agencies with State General Funds’
                     dated September 2010.



                     Attachment C
         Regional EMS Administrator’s Response to:
                      State EMS Authority’s
           “Draft EMSA Policy for Funding Regional and
      Multi-County EMS Agencies with State General Funds’
                     dated September 2010.



                     Attachment D
                      Current Version of:
         EMSA #104: “Funding of Regional EMS Agencies
                  with State General Funds”



                     Attachment E
                Regional EMS Administrator’s
                    Proposed Revisions to
                         “EMSA 104”




                                                                 18
                     Attachment A
                    State EMS Authority’s
“FY2011 Regional EMS Agency Funding Grant Program Fact Sheet,”
                     dated July 21, 2010




                                                                 19
                  FY2011 Regional EMS Agency Funding
                       Grant Program Fact Sheet
                             July 21, 2010

Background
California’s regional EMS agencies have undergone significant change during the past
two years and more change is expected. These changes have moved the state away
from regional areas that are based on logical patient flow and resulted in fragmentation
in the local EMS system, geographically noncontiguous regions, and diminished
efficiencies. Half of California’s EMS regions as they exist now are non-contiguous
and/or are bisected by geographical barriers.

Currently, there are seven regional EMS agencies covering over two-thirds of the state’s
geography and providing service to thirty-four counties that have a total resident
population of 6,809,509. Last year’s budget provided $2,181,708 of state general
funding to be distributed to the regional EMS agencies based on a calculation formula
which includes a base amount, the number of counties served, and the population of
area served.

Purpose
The goal of the FY2011 Regional EMS Agency Funding Grant Program is to stabilize the
EMS system in California, ensure that regions are logically based on patient flow and
resource usage, encourage the counties to work cooperatively, and use the general fund
dollars most efficiently.

Therefore, it is proposed that we move away from the current process which provides
funding based primarily on ad hoc county groupings and population to a process that is
developed to support logical, effective geographic regions that will enhance patient care,
best utilize resources, alleviate fragmentation, provide stability within the regions,
encourage coordination among counties, and ensure efficient use of limited state
funding. Regional EMS Agency Funding will only be available if an annual funding
amount for this program is reflected in the approved State budget.

Process
To maintain quality patient care that can be delivered through a coordinated, statewide
EMS system the EMS Authority has grouped the counties in the state into seven,
defined EMS System Groupings which will are based on patient flow, resource use and
potential operational efficiencies. Attachment A shows a map of the current groupings of
counties the EMS Authority considers to be the most appropriate at this point. This map
is a working draft and is subject to change.

The FY2011 Regional EMS Agency Funding Grant Program calls for LEMSA’s
(representing three or more counties in an EMS system grouping) to participate in a
competitive process to be designated serve as the regional EMS agency (REMSA) for a
given EMS System Grouping.




                                                                                        20
There may be more than one proposal per EMS System Grouping, but only one
designation will be awarded per EMS system grouping. Proposals need not include all
counties (within the grouping) wishing to participate in the REMSA program; however, a
regional EMS agency must have a mechanism to accept any willing county within the
EMS System Grouping who wishes to join the regional EMS agency.

The grant application process will have two phases. Counties who chose not to join the
designated REMSA will have the following options:
   1. Join with another multicounty LEMSA who is not designated (and receive no
       state general fund assistance from this program).
   2. Become a single county local EMS agency (LEMSA), or
   3. Contract with another entity (as per 1797.200) for LEMSA responsibilities

   Phase I
   Grant applications will reflect a budget inclusive of proposed REMSA counties. The
   application will be scored based on delivery of required and enhanced EMS services
   within the prescribed budget and the number of counties supporting the application.

   Phase II
   The EMS Authority will designate one REMSA for each EMS System Grouping that
   has an application submitted. In situations where a county chooses to function as a
   single county LEMSA, that county will be removed from the allocation formula and
   the final REMSA allocation will be recalculated.

   Each designated REMSA will submit a revised application based on their final
   allocation. The application will include revised goals/objectives as appropriate and
   final budget. The EMS Authority reserves the right to negotiate any revisions as
   appropriate to ensure the delivery of quality EMS services within a REMSA.

The EMS Authority is currently developing grant guidance for this project. It is
anticipated that the grant guidance will be available in November 2010.


Local Match Requirements
The language in the annual Budget Act requires that recipients of State General Fund
local assistance dollars match "dollar for dollar" the annual amount received. Only cash
and direct in-kind local support will be accepted as match for receipt of state local
assistance allocations. In addition, no agency may receive more state money than they
are able to match with local cash or direct in-kind support from the member counties.

Fees received by the local EMS agency for activities that duplicate state functions for
which fees are collected will not be allowed as cash match.




                                                                                          21
The following are the only direct in-kind contributions which will be allowed as match for
receipt of state general funds.
    Directly related support functions, i.e., staff services, provided by an individual or
        group outside the agency to fulfill a function assigned to the agency.
    Related salaries and benefits of outside staff assigned to and under the control of
        the agency.
    The donation of supplies, space, or equipment to the multi-county EMS agency.

EMS System Grouping Fund-REMSA
The formula to determine the proposed funding for each EMS System Grouping is found
in Attachment B. The final budget provided to the selected REMSA will be calculated
based on factors including population and number of counties.

Proposed Timeline
The EMS Authority has developed the following timeline for implementing the FY2011
Regional EMS agency Fund Grant Program:

July 21, 2010
Introduction of FY2011 Regional EMS agency Fund Grant Program to local EMS
agency’s meeting with EMSA Director
July – September 2010
Development of grant guidance with input from local EMS agency partners:
September 2010
Meeting with select EMS partners to review draft grant guidance; Finalize grant guidance
October 1, 2010
Release grant guidance with 90 day deadline for submissions
November 2010
Grant guidance Q&A meeting for in-person and electronic participation
December 31, 2010
Deadline for grant applications
January 2011
EMSA internal review of applications and determination of REMSAs
January 31, 2011
REMSA selection notifications
February 1, 2011 – March 30, 2011
Determination of final county configuration by REMSA where appropriate; Final award
calculations for each REMSA will be provided COB March 30, 2011
April 30, 2011
Deadline for revised grant applications and final budget from designated REMSAs
May – June 2011
Contracts executed between EMSA and REMSAs
July 1, 2011
Contract start date




                                                                                        22
Attachment A
                                  Del
                                 Norte
                                                            Siskiyou
                                                                                                       Modoc



                                                                                                                                                                          Grouping II - Northeast
                                                                                                                                                                Butte County     Sacramento County
                             Humboldt      Trinity                       Shasta                         Lassen                                                  Colusa County    Shasta County
                                                                                                                                                                El Dorado County Sierra County
    Grouping I - Northwest                                                                                                                                      Glenn County     Siskiyou County
    Del Norte County                                                                                                                                            Lassen County    Sutter County
                                                               Tehama
    Humboldt County                                                                                Plumas                                                       Modoc County     Tehama County
    Lake County                                                                                                                                                 Nevada County    Trinity County
    Marin County                                                                Butte
                                                                                                          Sierra                                                Placer County    Yolo County
                                                             Glenn
    Mendocino County               Mendocino
                                                                                                                                                                Plumas County    Yuba County
    Napa County                                                 Colusa                         Nevada
    Sonoma County                                    Lake                    Sutter Yuba                  Placer
                                                                                                                                                                                     Grouping IV – North San Joaquin Valley
                                                                         Yolo                           El Dorado                                                                    Alpine County
                                           Sonoma
                                                              Napa                                                            Alpine                                                 Amador County
                                                                                     Sacramento
                                                                                                   Amador                                                                            Calaveras County
                                                                       Solano
                                                                                                                                                                                     Mariposa County
                                                     Marin                                          Calaveras
                                                                  Contra Costa
                                                                                          San
                                                                                        Joaquin
                                                                                                                      Tuolumne              Mono                                     Merced County
                                               San Francisco
                                                                                                                                                                                     San Joaquin County
                                                                       Alameda
                                                                                                                        Mariposa
                                                                                                                                                                                     Stanislaus County
                                                                                             Stanislaus
                                                               San
                                                              Mateo
                                                                                                                                                                                     Tuolumne County
                    Grouping III - Bay Area                            Santa Clara                     Merced
                                                                     Santa                                                                                                                                       Grouping V - South San Joaquin Valley
                    Alameda County                                   Cruz                                                    Madera
                                                                                                                                                                                                                 Fresno County
                    Contra Costa County
                                                                                                                                                                                                                 Kern County
                    Monterey County                                                            San                            Fresno
                                                                                                                                                                           Inyo                                  Kings County
                    San Benito County                                                         Benito
                                                                                                                                                                                                                 Madera County
                    Solano County                                                                                                           Tulare
                                                                                  Monterey                                                                                                                       Tulare County
                    San Francisco County                                                                                     Kings

                    San Mateo County
                    Santa Clara County                                                                                                                                                                                            Grouping VII – Southeast
                    Santa Cruz County                                                                                                                                                                                             Imperial County
                                                                                                       San Luis Obispo                           Kern                                                                             Inyo County
                                                                                                                                                                                                                                  Mono County
                                                                                                                                                                                     San Bernardino
                                                                                                                                                                                                                                  Riverside County
                                                                                                                   Santa                                                                                                          San Bernardino County
                                                                                                                   Barbara
                                           Grouping VI – Southwest                                                                     Ventura
                                                                                                                                                                                                                                  San Diego County
                                                                                                                                                        Los Angeles
                                           Los Angeles County
                                           Orange County
                                           San Luis Obispo County
                                           Santa Barbara County                                                                                                   Orange                  Riverside
                                           Ventura County

                                                                                                                                                                                                      Imperial
                                                                                                                                                                                  San Diego
            Attachment B


                                                           State Fiscal Year 2011-12 Proposed Funding Allocation Methodology
                                                                      Limit Any County to 500,000 Population Credit
                                                 Allocation Based on Jan. 2009 Population Estimates and Expected County Participation

                                                  Agency                                                                                                          Base                                                           Factor                                      Total
                                                 Population                                                           Pop                                         Plus                           No. of                         Added for                         Total    Regional
                 Total Agency                  (Limit 500,000                                                        Factor                          Total Pop    Pop                            Cos. In                          Each                           County    Agency                                 Agency           2011/12
   Agency         Population                    Per County)                               Base                      Per 100K                          Factor     Factor                          Region                          County                          Factor     Factor                                Percent         Allocation
Grouping I -
Northwest                 803,163                        803,163                                     3.00                            0.20                 1.61               4.61                                     5                          0.60               3.00          7.61                              17.25%          $376,430
Grouping II -
Northeast           1,455,471                      1,455,471                                         3.00                            0.20                 2.91               5.91                              16                                0.60               9.60      15.51                                 35.18%          $767,622
Grouping IV -
Northern San
Joaquin Valley            629,957                        603,574                                     3.00                            0.20                 1.21               4.21                                     5                          0.60               3.00          7.21                              16.35%          $356,675
Grouping V -
Southern San
Joaquin Valley      1,690,853                      1,248,555                                         3.00                            0.20                 2.50               5.50                                     4                          0.60               2.40          7.90                              17.91%          $390,821
Grouping VII -
Southeast           2,092,503                        531,553                                         3.00                            0.20                 1.06               4.06                               3                                0.60               1.80       5.86                                 13.30%         $290,160
Subtotal            6,671,947                      4,642,316                                                                                                                                                   33                                                             44.08                                  100%         $2,181,708
                                                                           region
                                   maximum




                                                   This column represents region
                                                   population with a population of
                    This column shows region
                      population w/o 500,000




                                                       500,000 max per county in




                                                                                                                                                                                                                                                                               and total county factor = Total.
                                                                                                                    This 0.20 population factor is




                                                                                                                                                                                                                                Factor of .60 is multiplied by
                                                                                     except those under 300,000
                                                                                     Base factor. All regions are




                                                                                                                                                                 This column is a total of the




                                                                                                                                                                                                   Number of counties in each
                                                                                     warded a base factor of 3.0




                                                                                                                                                                                                                                each region to get the total




                                                                                                                                                                                                                                                                               Total base plus pop. factor
                                                                                                                                                                                                                                the number of counties in
                                                                                                                    population to get the next




                                                                                                                                                                 base factor plus the total
                                                                                                                    multiplied by each 100K




                                                                                                                                                                 population factor.
                                                                                     pop. receive 2.5.




                                                                                                                                                                                                                                county factor
                                                                                                                    column.




                                                                                                                                                                                                   region.




                                                                                                                                                                                                                                                                                                                             24
25
                              Attachment B
                               State EMS Authority’s
                    “Draft EMSA Policy for Funding Regional and
               Multi-County EMS Agencies with State General Funds’
                              dated September 2010.


                    This Attachment can be reference at:
.
    http://emsaac.com/emsaac_documents/drafts/EMSA 104 Draft with line
                              numbers.doc




                                                                         26
               Attachment C
   Regional EMS Administrator’s Response to:
                State EMS Authority’s
     “Draft EMSA Policy for Funding Regional and
Multi-County EMS Agencies with State General Funds’
               dated September 2010.




                                                      27
                     Regional EMS Administrator’s Response to:
                                  State EMS Authority’s
                       “Draft EMSA Policy for Funding Regional and
                  Multi-County EMS Agencies with State General Funds’
                                 dated September 2010.

(Comparing the states proposed changes to the existing EMSA 104 document has been a
painstaking and lengthy process since the Authority has not made a copy of the proposal
available in a ‘track changes’ format. Therefore, the following is a preliminary list of
concerns and comments. Additional comments will be forthcoming.)

In a review of the EMS Authority’s recent proposed revisions to the EMS #104
document, there are significant changes that can have a detrimental effect on the current
regional EMS systems. Due to some of the proposed changes, there is potential that
some current regional EMS agencies will no longer exist. While the document has been
extremely difficult to compare to the prior document in order to identify all of the revisions
that have been made, the most significant areas of concern are in the areas of funding,
which includes the reduction of counties to a region or addition of counties to a region.
Because the State General Funds are so essential to the existence of EMS regions, any
reduction in funds can have a significant impact on the region or multi-county EMS
agency.

1.     Regional EMS Agency vs Multi-County EMS Agency –

       The proposed changes include the concepts of a Regional EMS Agency and a
       mutli-county EMS agency. Section 1.10 – State General Fund Allocation
       Methodology – awards an “Area Allocation” amount to a Regional EMS Agency
       but not to a Multi-County EMS Agency. While there are definitions as to what the
       difference is between the two in Section 1.8, it appears that the final difference is
       that a Regional EMS Agency is the same as a multi-county EMS agency but is it
       contiguous, in the same system grouping (EMSA’s grouping), and “grouped
       together for maximum efficiency”. At some point, a decision will need to be made
       on what is efficient and does contiguous mean that the corners of two counties
       are contiguous. The significance is the difference of a Region receiving the “Area
       Allocation” dollars which is a significant dollar amount of either $140,000 or
       $120,000.

       There could be a difference of opinion between EMSA and a region on who is a
       Regional EMS Agency and who is a Multi-County EMS Agency, which could
       mean less State General Funds. Who makes that final decision and is there an
       appeal process?

2.     Changes in County Membership –

       Section 1.9 discusses different scenarios in the event an EMS Agency loses a
       county.

       a.      If a region or multi-county agency drops to less than three counties, it is
               unclear when the State General Funds will be discontinued. We propose
               adding language to the existing 2nd paragraph in Section 1.9 that states
               “Should an existing contracted EMS Agency’s county membership be



                                                                                           28
            reduced to less than three (3) counties, it will no longer be eligible for
            State General funding with the following exception: in the event an
            agency’s membership is reduced to two (2) counties, it will continue
            to receive funding for the remainder of the contract period.” The
            additional language would assist the remaining two counties to transition
            to single LEMSAs or provide time and resources to find another county
            that may be interested. The issue is that both remaining counties are
            greatly impacted when one county leaves.

     b.     When a new county (not belonging to another region) is added to a region
            or multi-county agency, the EMSA proposed document only requires an
            updated EMS plan. If additional funds are not added to the State General
            Fund dollars, then the available funds to each of the other regions and
            multi-county agencies will be reduced. There is no language that requires
            a new county (or new region or multi-county EMS agency) to bring in new
            or additional dollars, as it has in the past, to the State General Fund
            allotment. When a new county is added to a region or multi-county EMS
            agency, can we require that additional funds must be included with the
            new county? The same needs to occur if there were a new Region or
            mutli-county EMS agency added to the system. Without additional funds,
            adding a new county, region or mutli-county EMS agency to the system
            will have a negative impact on all of the other regions by diluting their
            allotment.

3.   The total combined allocation of current funding for North Coast and CVEMS is
     less by $100,000 in the new EMSA proposal, technically for one additional
     county (Marin). Therefore, we oppose this change.

4.   The language for a region with less than 300,000 to be required a local match of
     $0.41 per capita has been eliminated. We oppose this change.

5.   Annual reporting requirements appear to have been increased dramatically. This
     comes on the heals of the EMS Authority just taking extensive efforts to reduce
     unnecessary and redundant reporting by the regions. We oppose this change.




                                                                                     29
           Attachment D
             Current Version of:
EMSA #104: “Funding of Regional EMS Agencies
         with State General Funds”

  This Attachment can be reference at:

http://www.emsa.ca.gov/pubs/default.asp




                                               30
   Attachment E
Regional EMS Administrator’s
   Proposed Revisions to
        “EMSA 104”




                               31
                           Excerpts From
       EMSA POLICY FOR FUNDING REGIONAL EMS AGENCIES WITH
                       STATE GENERAL FUND
                        (EMSA 104; June 2001)

       The Regional EMS Administrators propose the following
                      revisions to EMSA 104
1.6 The EMS Authority shall use the following guidelines in administering state
funded contracts to regional EMS agencies:

       Not all multi-county regions are eligible for State General Funding. Funding
        eligibility shall be limited to rural multi-county regions with a minimum of three (3)
        member counties that demonstrate a heavy use of the EMS system by
        nonresidents.

       Regions as identified above may include a percentage of counties that are not
        specifically impacted by nonresident use if resources in those counties provide
        necessary system components (e.g. ground / air ambulance services, receiving
        facilities, specialty care centers, etc) for the region, and as long as the
        percentage of these counties does not exceed 50% of the total number of
        member counties.

       Regions as identified above shall be made up of contiguous counties unless
        patient flow patterns or use of shared EMS system resources would justify a non-
        contiguous configuration. Exceptions may be granted to this rule if, as defined by
        the Authority:

           o   A non-contiguous regional configuration would result in a higher level of
               EMS services in the included counties than could otherwise be achieved,
               or
           o   The non-contiguous configuration of the region occurs as a result of a
               county or counties withdrawing from the region and the existing system
               continues to meet the needs of all member counties

       Regional EMS agencies shall provide a centralized administration for all member
        counties. Regions which maintain a separate administration of their individual
        counties will not be eligible for State General Funding.

       Regional EMS agencies shall provide matching funds of at least $1 for each
        dollar of state funds received.

       State funding shall be used to provide only essential minimum services
        necessary to operate the system, as defined by the Authority.

       No region shall receive both federal and state funds in the same fiscal year for
        the same purpose.
       Each multi-county system shall be eligible to receive up to one-half of the total
        cost of a minimal system for that area, as defined by the Authority.


                                                                                            32
      Multi-county systems with a population of 300,000 or less shall receive the full
       amount for which they are eligible if they provide a cash match of $0.41 per
       capita or more.


Old 1.10 (Delete) Regional Agency Definition
A regional agency is defined as three (3) or more counties.


New 1.10 New Regional Agencies

New multi-county agencies can receive a share of the available monies only if adequate
funds for a new region have been allocated in the State Budget. If new funds were not
required to add new multi-county systems, existing programs would be negatively
impacted by the redirection of funds. Therefore, before new agencies may receive
general fund support, a process to allocate additional funds to the budget must be
undertaken during the final year of eligibility for Federal Block Grant development
support to ensure there exists no negative financial impact to any of the existing multi-
county regions.


New 1.11 Changes in County Membership of a Region

A region adding one or more new counties (not previously affiliated with an EMS region)
will not receive SGF support for the new county for up to one year or counties for a
transition period as determined by the EMS Authority, based on the impact on other
regions. A region that is adding a county must update its EMS Plan to incorporate the
new county before it will be eligible for additional SGF support for that county. The plan
should explain how the change will affect services to the county and the region.

In cases where a county changes regions, there will be a transition period for both the
receiving and the losing regional agencies. The agency losing the county shall be
credited with the county in the current funding formula for up to one year. The agency
gaining the county shall not be credited with the new county for the first year of funding.

A region that has lost a county and is receiving transitional funding at its previous
eligibility level must, by the end of one year, update its EMS Plan to reflect the loss of
the county. The plan should explain how the change will affect services to the remaining
counties in the region.


A region that has lost one or more counties shall be eligible for continued transitional
SGF support for that county for a period up to one year. A county that is receiving
transitional funding at its previous eligibility level must, by the end of the transitional
period, update its EMS Plan to reflect the loss of the county. The plan should explain
how the change will affect services to the remaining counties in the region. .

In cases where a county or counties changes regions, there will be a transition period for
distribution of State General Funding, specific for that county or counties, between the
effected regional LEMSAs. The affected LEMSAs shall negotiate the length of the


                                                                                              33
funding transition period and the distribution of SGF support during that period, and
submit that transitional funding formula to the Authority for approval . The transitional
funding formula will be adjusted to the regular funding formula once the transition period
is complete.

Should an existing agency’s county membership be reduced to less than (3) counties,
they will no longer be eligible for State General Funding with the following exception; in
the event a county’s membership is reduced to two (2), they may be eligible to receive
up to one year of transitional funding in accordance with the current funding formula.

Anytime that a multi-county agency is approached by a member county of another EMS
region to discuss moving their affiliation, the director of the EMS agency shall advise the
director of the member county’s current EMS agency.

It is suggested that all regional agencies ensure that there is a clause in their contracts
with the counties that require a county that wishes to drop out of a region to give notice
by June 1 in the SFY, in order to opt out for the next one year cycle.




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