future of the industry.

Enclosed, please nd CoMMPs feedback on the

proposed changes for your review.

We greatly appreciate the me, a en on, and emphasis that the Na onal
EMS Educa on Standards Project Development Team placed on this important
founda on in EMS, as well as the opportunity to publicly comment.  Should
the development team require anything further from us, please do not
hesitate to contact us via our website at h p://www.commp.org

Very Respec ully, 

The Congress of Mobile Medical Professionals     





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 Base Founda on at Paramedic level (page 10)

Provide a founda onal level of training from the start of their EMS educa on,
that provides the skills, understanding and applica on of knowledge which
can be retained across a career lifespan of learning. This will develop the
underpinning of core skills for every applicant, that will ensure a structured
approach to the development of clinical reasoning, which can evolve with
each level of EMS Educa on they undertake. It will also form the founda onal
basis required to help deliver the transforma onal change Paramedicine is
taking as a profession both in the USA and Interna onally alike.
We believe EMS should consider a core curricula of entry level paramedic with
various specialty creden als, i.e., 9-1-1 response, IFT, CCT, Rural Medicine,
Mobile Medicine, Flight Paramedic, Mental Health etc. This will allow for a
general basis of knowledge of the paramedic and allow for providers to spend
addi onal training me in order to specialize their educa on to that which will
be directly applicable to their career path. 
Con nuing Educa on:(no reference, not men oned in the document)
 In EMS clinicians are currently spending extraneous me with core
competency educa on and neglec ng innova on and change. By including
con nuing educa on into the Na onal Educa on Standards, the document
can allow for an innova on in the way providers are re-educated. While the
core concepts are important, simply requiring them does not allow for
providers to grow their educa on beyond entry level. 
Making a stance on con nuing educa on including what quali es as
con nuing educa on, improving QA/QI to remove bias, and placing an
emphasis on evidence-based medicine, is impera ve for the growth of our
industry.

Preceptor Educa on: (page 55 in de ni on only) 

The quality of a clinical experience is only as good as the preceptor leading it.
In the beginning phases of educa on with truly technical skills, any
experienced provider will ll the spot in a pinch. However, when students get
to the higher-level eld internship phase, there should be some standardized

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 approach to precep ng that incorporates not only clinical leaders but those
with a high level of emo onal intelligence, cri cal thinking skills, and the
ability to teach and relate to students. This has been achieved in other elds
to a level that EMS is currently lacking. While this is a framework for ini al
educa on, preceptor training and quali ca ons is an important component to
the overall success of a student.

Assessment: Monitoring Devices (page 32)

The Assessment sec on for EMT Monitoring Devices includes 12 lead ECG
acquisi on, there would be a bene t to adding End Tidal Carbon Dioxide
monitoring. The EMT level training in Pathophysiology & Anatomy and
Physiology includes the concepts already needed to explain ETCO2 at a
technician level, and this tool can be bene cial for agencies equipped with
ETCO2 monitoring capabili es. 
Obstetrics (page 45):
 The updated obstetric requirements of the EMT listed in this sec on require
signi cant teaching me that are di cult to obtain without hands on
or simula on-based learning with a greater availability of teaching me. 

A ec ve Domain/Emo onal Intelligence:  

Emo onal Intelligence impacts every part of EMS service delivery. EMS
providers u lize human interac on in pa ent care, from dealing with
distraught loved ones to co-workers and Emergency Room sta . Our behaviors
have a strong correla on to our level of emo onal intelligence and how we
respond with interpersonal interac ons. Our a ec ve domain creates the
basis for how our emo ons play into every interac on we have. EMS
educa on has historically centered on the clinical aspects of providing service.
EMS educa on should not only set a founda on on how to treat medical and
trauma c emergencies, but also include how to treat people with compassion,
respect, and understanding. While the sec on on Therapeu c Communica on
is a good start, it can be expanded upon. By having a general understanding of
their own emo onal intelligence, along with training in providing

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 compassionate care, EMS providers can have a more holis c and proac ve
approach to engaging with pa ents, loved ones, co-workers and other agency
personnel they interact with. Including, but not limited to:
▪ Healthcare literacy 

▪ Interviewing techniques  

▪ Verbal defusing strategies

▪ Managing communica on challenges 

▪ Family centered care

▪ Adjus ng communica on strategies for age, stage of development,

pa ents with special needs

▪ Non-discriminatory

▪ Communica on that addresses inherent or unconscious bias, is

culturally aware and sensi ve, and intended to improve pa ent
outcome

Compassion should be more broadly promoted in all appropriate aspects of an

EMS provider's interac ons, especially with pa ents and their loved ones. Not
just the limited situa ons currently recommended in this document

It is well known that many complaints regarding providers and EMS in general
are due to being rude, inconsiderate, and a lack of empathy. Educa on in
emo onal intelligence that leads to compassionate behaviors can not only
reduce these complaints; they have the poten al to reduce lawsuits. As
medical schools across the country have added classes on bedside manner
and compassion, EMS should do the same. Not only with lecture, but as part
of skills sta ons, and eld clinical training. 
We would recommend an overview of Emo onal Intelligence as it relates to
overall performance as a provider at the EMR level with it increasing through


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 EMT to paramedic. As part of this process, highlight the impact and
importance of compassionate behaviors, that include understanding and
respect in all aspects of EMS delivery, especially when interac ng with a family
and their loved ones.
The a ributes of emo onal intelligence should be integrated in all aspects of
EMS educa on, not just in a few targeted areas. Emo ons and how we display
or act on them a ect everything we do. Providers should learn to understand
and how to manage their emo ons and a endant behaviors in all aspects of
being a EMS provider.
◦ Correia, (20200. Patch Adams & EMS: Patients Are People Too: h ps://
www.jems.com/pa ent-care/patch-adams-and-ems/
◦
◦ h ps://www.usnews.com/educa on/blogs/medical-school-admissions-
doctor/ar cles/why-medical-school-applicants-should-highlight-
compassion

◦ Trzeciak, S & Mazzarelli A. (2019). Compassionomics. Studer Group

[Internet]. Pensacola, Fla. www.studergroup.com.

◦ Carroll, AE. (2015). To Be Sued, Doctors Should Consider Talking to

Pa ents More. [Internet]. New York (NY). Available from: h ps://
www.ny mes.com/2015/06/02/upshot/to-be-sued-less-doctors-should-
talk-to-pa ents-more.html.

◦ Adams, P. & Mylander M, (1998) M. Gesundheit. Healing Art Press.

Rochester (VT). Available from: www.innertradi ons.com.

◦ Lamers, S. M., Bolier, L., Westerhof, G. J., Smit, F., & Bohlmeijer, E. T.
(2012). The impact of emo onal well-being on long-term recovery and
survival in physical illness: a meta-analysis. Journal of behavioral
medicine, 35(5), 538—547. h ps://doi.org/10.1007/
s10865-011-9379-8.

◦ Parker C. Emo onal t important between a pa ent’s desired feelings

and physician, Stanford research shows. [Internet]. Stanford (CA). 2015
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 April 2. [cited 2020 Sept 22. Available from: h ps://news.stanford.edu/
2015/04/02/doctor-pa ent-emo on-040215/.

◦ Health, S. How to Use Team-Based Care to Improve the Pa ent

Experience [Internet]. 2019 Jul 9 [cited 2020 Sept 23]. Available
from: h ps://pa entengagementhit.com/news/how-to-use-team-
based-care-to-improve-the-pa ent-experience.

◦ Thornton R, Glove C, Cené C, Glik D, Henderson J, Williams D.

Evalua ng Strategies For Reducing Health Dispari es By Addressing The
Social Determinants Of Health [Internet]. Health A airs. 2017 Aug 1
[cited 2020 Sept 23]. Available from: h ps://www.ncbi.nlm.nih.gov/
pmc/ar cles/PMC5524193/.

◦ Rosen, M. A., DiazGranados, D., Dietz, A. S., Benishek, L. E., Thompson,

D., Pronovost, P. J., & Weaver, S. J. (2018). Teamwork in healthcare: Key
discoveries enabling safer, high-quality care. American Psychologist,
73(4), 433—450. Available from: h ps://pubmed.ncbi.nlm.nih.gov/
29792459/. h ps://doi.org/10.1037/amp0000298.

Report Wri ng: (page 61 Appendix A)

The curriculum resources for documenta on lists resources within EMS

and does not include resources from wri ng pedagogy and research. That risks
limi ng the resources for providers, and EMS providers will keep doing the
same thing they have been doing for decades and will likely get the same
results. In order to drive the industry forward, there would be a bene t to
suggest addi onal resources to supplement educa on in documenta on. 

Angeli, Elizabeth L. “How Report Wri ng Supports Paramedic Students’

Learning.” Interna onal Paramedic Prac ce, vol. 10, no. 1, 2020, pp. 28-33.
—. Rhetorical Work in Emergency Medical Services: Communica ng in the
Unpredictable Workplace. Routledge, 2019.

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 This point might be too big and beyond the scope of this document, the
document compartmentalizes discrete skills (pharmacology, scene
management, SAMPLE) when, really, there are founda onal skills that help
providers develop those skills: cri cal thinking, re ec on, ac ve listening,
asking ques ons. I wonder if that might be worth men oning because I’m not
seeing a discussion about how providers can build a solid founda on before
building their skill wheelhouse. 

 
Hospital Handover - Communica ons (page 24)
 
Communica on plays a vital role in the management of our pa ents. Not only
do paramedics require cri cal communica on skills when speaking with our
pa ents, to ensure we can ascertain the best pa ent history to create our
treatment plan, paramedics also need to do the same thing when
communica ng with other healthcare workers. Nowhere else is this more
important than when comple ng a hospital handover. There are a few
acronyms available to codify the process of handover. Perhaps most useful is
the IMIST-AMBO (Wood, Crouch, Rowland, & Pope, 2015), (QAS, 2016),
handover acronym, which you can use for both hospital handovers and pre y
much every other clinical handover you might need to perform as a
paramedic.
 

IMIST – AMBO Clinical Handover Acronym

I Iden ca on ● Your pa ent’s name
and age / DOB
M Mechanism of injury or ● What is the
medical complaint mechanism of injury?
● What is the medical
complaint or presen ng
problem you were called
for?

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 I Injuries or informa on ● Pa ent assessment
relevant to complaint and history that is
relevant to the complaint
you were called for?
S Signs ● Vital Signs you have
taken
o   Any changes you
no ced (good or bad)
● GCS of your pa ent
o   Did it change during
treatment?
T Treatment and Trends ● What treatment
interven ons did you
perform?
● What was your
pa ent’s response to
treatment?
A Allergies (Medical or ● Allergies your pa ent
Non-Medical) may have
o   Medical Allergies
(pharmacology or other
items like medical tape,
latex or betadine etc.)
o   Non-Medical Allergies
(Seafood, cats, grass etc.)
M Medica ons ● What Medica ons are
they taking?
o   Prescribed
o   Not prescribed
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 B Background ● Medical History

o   Surgical History
o   Current Medical
Condi ons
o   Past History / Past
Medical Condi ons (if
relevant)
o   Social History (if
relevant)
o   Family History (if
relevant)
O Other Issues not already ● What did the scene
iden ed above look like (vehicle
accident, fall – how high,
smoke or other poten al
issues)?
● Social situa on of the
pa ent (how clean was
the house / apartment /
low, middle or upper
class – if relevant to
condi on)?
● Any advanced health
direc ves like do not
resuscitate etc?
● Any belongings the
pa ent may have with
them?
● Cultural or religious
considera ons the
pa ent may have?
● Any need for an
interpreter?
 
 

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 ● Hospital Handover Example
o   I – This is pa ent John Smith who is 55 years old
o   M – He has dropped a box on his right hand whilst trying to posi on it on a
high shelf this AM
o   I – His right hand appears swollen, extremely painful to touch and pain
increases on movement, radia ng up his right arm.
o   S – His vital signs have remained constant. He has a normotensive blood
pressure, pulse 90, resp rate 18, SpO2 97% RA, temp 37.4, BGL 4.7, PEARL,
chest sound clear and he has had a constant GCS of 15.
o   T – We have given him pain relief (you would state the name, dose and
response), which relieved his pain. We have also applied a vacuum splint
around the right hand, which has provided support and addi onal pain relief.
o   A – He has no medical or non-medical allergies
o   M – He takes Asmol as required
o   B – He does su er from occasional Asthma, nil other medical issues
o   O – He did not hit his head or lose consciousness from anything hi ng him
when the box came down above him; his right hand took the full impact. His
wife is on her way up to the hospital.

Competency vs hour requirement: (page 53)

As an industry it’s me to decide if we want competency-based providers

mee ng a minimum standard or well-rounded providers with cri cal thinking
abili es coming out of a educa onal experience with strong emo onal
intelligence and a ec ve domains. Competency based clinical educa on is
di cult to measure as it incorporates both subjec ve and objec ve skill sets.
Clinical decision making is subjec ve whereas technical skills are objec ve.
The concern with an increased emphasis on competency-based educa on
creates fear that a technically astute provider may lack the cri cal thinking
because they can splint or manage airways with ease. Unfortunately, the
cri cal thinking competency domains require extra classroom and clinical
me. Instructors today are pressured to turn students out as fast as possible to
help ll the shortages in EMS. Without a combina on of a competency-
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 based approach with a speci c measured hour approach, there is a greater

poten al for teaching to the test in order to push students through. 

Technically pro cient providers who “start every IV”, or “get every tube” are
o en regarded as the strongest providers, however many mes these
providers cannot recognize the issue, formulate and implement a treatment
plan, and improve pa ent outcomes. While there is a signi cant need for
strong technical providers, those a ributes must be blended with strong
cri cal thinking and clinical decision making. These processes cannot be
obtained by merely interac ng with 50 chest pain pa ents, but instead are
achieved by interac ng with many pa ents and having a clinical experience
which facilitates cri cal thinking.

A central focus of EMS educa on should be on curriculum development.

For example, many students are tested and expected to manage a low
frequency event of mul system trauma, with hours of ve ed educa on, yet
rou nely interact with pneumonia pa ents with merely 5-15 minutes of
educa on.

Moving to a strictly competency-based program has the poten al to reduce

cri cal thinking and leaves rooms for subjec vity if a student has truly met the
competency level. Similar changes have occurred in AHA classes with ACLS and
PALS, where students are able to obtain a card by following the mo ons and
taking an open book exam, without ever truly understanding or being able to
apply the material in a useful manner. Without a thorough system of checks
and balances to assist instructors in the ability to test students’ skills and
comprehensive knowledge in ve ed mechanisms, there is a risk of a future of
providers that lack cri cal thinking skills to apply the knowledge. Only through
high quality instruc on in tandem with hand on competency evalua on and
applica on can students learn these skills, as is prac ced in EMS systems in
Australia, UK, Germany. 

When compared with nursing or physician (and mid-level) educa on, EMS
fails. In other educa on se ngs providers leave the educa on with general
knowledge, and then specialize (ICU, ER, NICU, Ortho, etc).  EMS should

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 consider the same approach. Concentra ng on rural, agricultural, IFT, CCT, CP,
mental health, recrea on a er obtaining general knowledge training would be
a bene t to the industry and students.

This document creates an educa on outline for the future. The lack of a stance
on improving educa on and requiring a degree minimizes the future of EMS.
Many states are requiring bachelor’s degrees for nurses, physical therapists
and other allied health workers, yet EMS lacks any formal educa on
requirement. With the availability of online educa on, providers can easily
obtain associate degrees. Many of the general studies would improve pa ent
care in many di erent aspects. English composi on is bene cial in report
wri ng and documenta on, art is useful in communica on with children and
the development of emo onal intelligence, and sociology/psychology are used
to relate to not only pa ents but crew members and other medical
professionals. 

 In 1999, the Accredita on Council for Graduate Medical Educa on (AGME) &
the American Board of Special es, (ABMS) endorsed six domains of core
competencies: The Outcome Project.  The six core competencies follow
◦ Pa ent Care

◦ Medical Knowledge

◦ Professionalism

◦ Interpersonal and Communica on Skills

◦ Prac ce based learning and Improvement

◦ Systems based Prac ce

Even though there was standardized language around the core competencies
of medical educa on, there were no standardized assessment methods to
determine whether or not a learner had achieved all of the core competencies
prior to comple on of residency training. This de ciency ul mately led to the

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 crea on of milestones to opera onalize and implement the competencies.
These milestones described the performance levels residents and fellows are
expected to demonstrate for skills, knowledge, and behaviors in the six clinical
competency domains and are signi cant points in development that are
unique to each specialty.
 
Sources: h ps://www.acgme.org/Portals/0/MilestonesGuidebook.pdf

Crew Resource Management - (page 24)

Crew Resource Management training is severely lacking in EMS. This should be
ins lled at the EMT level and then expanded into the paramedic curriculum.
Paramedic should have Crew Resource Management incorporated into
scenarios as they will o en mes be the highest medical authority managing a
scene. There is a bene t to live scenario training of CRM in order to apply the
concepts learned at an applica on level. 
 
EMS Standards Blueprint (page 4)- Educa on should be uid, able to adapt,
and readily transform along with the needs of our communi es and country.
Revising this document every 2-3 years could lead to signi cant gaps in the
educa onal and clinical se ngs. A mechanism for making changes on an
annual basis as technology and research occurs, to make this a “living”
document, is impera ve with the speed at which technology and research
advances. For example, some of the gaps in revising educa onal standards
caused di culty in removing backboards from the curriculum despite
overwhelming research that they were causing harm. By making this a living
document with the ability to make changes as needed, we are be er able to
serve our pa ent popula ons. 
 
Unusual Occurrences - Public Health (Page 20) 
2020 has taught us many things and has exposed various gaps in our health
care system. One area we believe can be bene cial is the u liza on of EMS for
addi onal tasks such as vaccines. While it is brie y men oned on page 20, we
believe there would be a bene t from an expansion of this area to outline
di erent methods of integra ng EMS into the public health industry. 

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 Death and Dying: (Not listed, would bene t from resources in Appendix)
As EMS has evolved, the understanding of risk vs. bene t in transpor ng
cardiac arrest pa ents has expanded and ul mately transformed. Expanding
the sec on on death and dying to include more training is important in
preparing students for work in the eld. EMTs, some as young as 16 or 17
years old, may be in the posi on to tell a spouse of 50 years that their loved
one has died. Without a greater understanding of how to properly relay this
news, handle the stress and emo ons that will follow, and u lize resources to
assist the family, there is a poten al for provider/family harm. MOLST forms/
Advanced Direc ves/ and DNR’s are becoming more commonplace in the eld
and clinicians need to have an in mate understanding of these documents
from beyond the legal perspec ve that is currently being taught.

Mental Health: (Not listed, would bene t from resources in the Appendix)
We have a recommenda on for more resources about EMS providers health
and wellness, par cularly spiritual and emo onal wellness. These discussions
should be integrated into educa on from day one, and consul ng therapists,
counselors, and spiritual directors who work with trauma, PTSD, and rst
responders would be essen al resources.

Medicare Compliance - Preparatory (Page 23) or Documenta on (Page 24) -

Regulatory Compliance for reimbursement is a signi cant lack in EMS’s current
educa onal process. Many pa ents transported by EMS in the US receive their
healthcare bene ts from taxpayer funded programs (Medicare and Medicaid).
These programs have very speci c requirements for documenta on and
medical necessity. Without this crucial founda onal understanding of the
regulatory aspects, providers may face numerous legal struggles.

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