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ASSOCIATION OF CRITICAL CARE TRANSPORT. The Critical Care Transport Standards Project

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Association of Critical Care Transport

800 17th Street NW Suite 1i00 Washington, DC 20006 (202) 828-5003 401 Edgewater Place – Suite 600 Wakefield, MA 01880 (781) 623-0750

www.acctforpatients.org

ASSOCIATION OF CRITICAL CARE TRANSPORT

The Critical Care Transport Standards Project

To date, a consensus definition of what constitutes critical care transport has remained elusive. As the need for high acuity critical care transport increases, the need for a common understanding and practice standards is imperative for patients, referring, and receiving physicians. Too often, transport is a black-hole of time in the delivery and transport of patients. At minimum transport between hospitals should be at the same or higher level of care initiated in the referring hospital. In order to address this practice gap, the ACCT Standards Committee developed a work group in May 2012 to develop a model definition of critical care transport. As a starting point the work group identified the lack of an agreed common definition for standards or regulations at the state emergency and healthcare system oversight level. As a starting point the work group recognized that the CMS Relative Value Unit (RVU) for specialty care transport (SCT) reimbursement does not reflect the wide acuity, complexity, and needed interventions during transport. As an example, many states allow an extended scope of practice for paramedics with additional training to

manage interhospital transfers of stable patients on infusion pump medications. These transports would be reimbursed under the SCT RVU. As another example, the transport of a patient requiring full extra corporeal membrane oxygenation (ECMO) on a ventilator and multiple pressors with a multi-disciplinary team would also be reimbursed under the SCT RVU despite the much higher level of practice, complexity, and needed interventions.

The lack of standards has resulted in wide variation in a multitude of CCT elements including regulation, licensing, scope of practice, equipment/technology, pharmacology, medical oversight, vehicle attributes, and documentation standards.

The Work Group met bi-weekly over four months bringing the drafts to the membership of ACCT and to other stakeholder professional and trade associations for comment and review. The combined efforts resulted in the attached Definition of Critical Care Transport which was adopted by the ACCT Board in August 2012.

Without question, developing a new standard and definition for critical care transport is a complicated endeavor with implications for individual providers and agencies. Changing a standard of care is never easy, especially in a time of tremendous healthcare cost restraint. The need, however, to assure patients and their physicians with consistent reliable and known standards of care during transport is an overwhelming and increasing need within the healthcare system. This is especially true for the most critical ill and injured patients and special populations including but not limited to high risk obstetrical patients neonatal,and pediatric patients, as well as extremely complex patients requiring ECMO during transport.

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Association of Critical Care Transport

800 17th Street NW Suite 1i00 Washington, DC 20006 (202) 828-5003 401 Edgewater Place – Suite 600 Wakefield, MA 01880 (781) 623-0750

www.acctforpatients.org

The work group and ACCT Board are grateful for both the broad and lively participation across multiple conference calls and the thoughtful comments received from professional organizations and individuals. The final paper has tried to reach a balance of what exists today and what needs to exist in the future, recognizing that the EMS and medical transport system is in constant evolution.

One example of this is the how to address the evolving scope of paramedics within the context of high acuity inter-hospital transport. The Work Group believes a minimum requirement for a transport team is to have at least one RN provider with extensive ICU consistent with accrediting organization requirements. While the International Association of Flight and Critical Care

Paramedics has established standards of practice and an external specialty credential tested by FP-C exam, these providers exist within the wider state level paramedic education and credentialing system which have tremendous variation in critical care education, practice standards and have limited exposure to multi-year in hospital ICU experience which is deemed to be a basic element in the standards. As paramedic practice continues to evolve, and in-hospital ICU experience opens, the model standards are designed to accommodate future ability to evolve the practice for paramedics to become primary critical care providers.

Another example is the standard calling for specialty transport certification recognizing that in-hospital critical care expertise of a physician, physician extender, or RN is not synonymous with the ability to manage the same patient in the austere transport environment. The Work Group strongly believes in the need to achieve specialty transport credentialing for all providers but recognizes this does not exist in all practice sectors currently.

It is the Work Groups hope that this model can inform the Critical Care Transport provider

community, system regulators, referring and receiving physicians, and most importantly patients. We recognize that this is a beginning effort and the ACCT Standards Committee is continuing this work with work groups addressing each element within the critical care transport system

Jan Cody, Chair, RN, LP, CMTE

VP of Clinical and Quality Services CareFlite, Dallas, TX Sherry McCool MHA, CMTE, RRT-NPS,

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Association of Critical Care Transport

800 17th Street NW Suite 1i00 Washington, DC 20006 (202) 828-5003 401 Edgewater Place – Suite 600 Wakefield, MA 01880 (781) 623-0750

www.acctforpatients.org

Attachment A

ACCT Recommended Definition of Critical Care Transport For Consideration by MedPAC for Medicare Reimbursement Purposes Purpose:

To provide a recommendation to MedPAC to inform the current ambulance reimbursement study on the need to create a new relative value unit (RVU) and reimbursement level for critical care transport.

Critical care transport is distinct from the currently defined “Specialty Care Transport (SCT)” and thus should be separately recognized under the Ambulance Fee Schedule. The SCT RVU in the Ambulance Fee Schedule recognizes the use of additional skills and therapies beyond the national scope of practice for a paramedic and also recognizes the additional costs of training, medical technology, and interventions for inter-hospital transport of stable patients. However, the SCT RVU does not recognize or adequately reimburse the additional resources needed for a patient who is clinically unstable or has the potential for life threatening clinical instability that that may contribute to morbidity or mortality and who requires more advanced and costly medical interventions, equipment and supplies.

The level of medical care required to transport a critical care patient includes: 1) an expert level of provider knowledge and skills appropriate to the medical needs of such patient; 2) a patient care environment commensurate with the critical care provided, including the necessary equipment and supplies; 3) the ability to address the added challenges of transport and initiate and/or maintain the continuity of tertiary or quaternary hospital care during transport; and 4) a vehicle (ground, fixed wing, or rotor wing) equipped to support the delivery of medical care to critical care patients during transport. Both the critical care transport agency and transport teams actually delivering the care to patients must have sufficient capability to meet the medical needs of critical care patients.

The choice of transport modality—ground, fixed wing, or rotor wing -- is based on multiple factors including patient acuity and medical condition, the need for time sensitive care and out-of-hospital time, (i.e. Thoracic Aortic Dissection) and logistical considerations, including distance and weather. Accordingly, critical care transport patients may be transported by any vehicle modality depending on the individual circumstances present at the time, and the choice of a particular vehicle modality does not infer that a transport is or is not a critical care transport.

ACCT's recommended critical care definition would apply to interfacility transports only, recognizing that in interfacility transport, there is a prospective physician assessment with regard to whether the patient requires critical care transport. ACCT recommends further study by MedPAC with regard to whether a CCT RVU for patients transported from the scene is advisable and appropriate based on aggregated data sets and clear outcomes.

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Association of Critical Care Transport

800 17th Street NW Suite 1i00 Washington, DC 20006 (202) 828-5003 401 Edgewater Place – Suite 600 Wakefield, MA 01880 (781) 623-0750

www.acctforpatients.org

The provision of medical care by a critical care transport team to a patient requiringcritical care transport by a critical care transport agency such that the failure to initiate on an urgent basis or maintain during transport acute medical interventions, pharmacological interventions, or technologies would likely result in sudden, clinically significant or life threatening deterioration in the patient's condition1 (subject to the corresponding definitions below).

Definition of Patient Requiring Critical Care Transport:

A patient requiring critical care transport has a critical illness or injury that acutely impairs one or more vital organ systems such that there is a high probability of imminent or life threatening deterioration in the patient's condition during transport. Examples of vital organ system failure that may contribute to morbidity or mortality include, but are not limited to: central nervous system failure, circulatory failure, shock, renal, hepatic, metabolic, and/or respiratory failure. Definition of Critical Care Transport Team:

Critical care transport services are delivered by critical care a transport team with the requisite decision making skills of high complexity to assess, manipulate, and support vital organ system failure and/or to prevent further life threatening deterioration of the patient's condition during transport.

1. The team consists of a minimum of two caregivers each of whom is able to provide acute medical interventions, pharmacology, and technological life support systems exceeding those able to be provided by the national scope of practice of a paramedic as currently defined by NHTSA’s National EMS Scope of Practice Model, DOT HS 810 657, February 2007 (and as redefined in the evolution of practice by NHTSA).

2. In addition, each caregiver on the transport team has a minimum of 3 years’ experience in their respective fields, with documented competency and experience (as defined below) in the care and transport of critical care patients. All critical care transport team members should be employed by or affiliated with the agency providing (except as provided in (iv) below) transport.

i. At least one provider is licensed as an RN, PA, NP, or physician with documented competency and experience in the provision of critical care as a primary caregiver in a tertiary intensive care unit commensurate with the type and acuity of patients transported and receives training in the transport environment pursuant to the agency's policy. To the extent that a state may develop credentialing for a Critical Care Provider that includes other licensed caregivers who meet the qualification requirements under (1) above and that requires such caregivers to have the comparable equivalent of three years experience in a tertiary intensive care unit as the primary caregiver, such credential should be considered for recognition as qualifying under this requirement.

1

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Association of Critical Care Transport

800 17th Street NW Suite 1i00 Washington, DC 20006 (202) 828-5003 401 Edgewater Place – Suite 600 Wakefield, MA 01880 (781) 623-0750

www.acctforpatients.org

ii. At least one provider has specialty certification in critical care transport (e.g. CFRN, CTRN, CNPT, FP-C & CCP-C) achieved through a validated exam administered by an independent entity not associated with a specific course or program of education. The agency needs to have a policy requiring transport certification.

iii. When treating patients within special patient populations (e.g. obstetric, pediatric or neonatal), additional experience, training, and technology must be incorporated into the team and its delivery of critical care as appropriate to the medical conditions of the patient.

iv. A critical care transport team may be augmented by adding tertiary teams of particular providers trained to deliver care to patients with certain characteristics or medical conditions. Such providers may be employed by an entity other than the critical care transport agency but should meet the minimum requirements consistent with the applicable tertiary care standard for the patient being transported (e.g. ECMO, NICU, PICU, HROB).

Definition of Critical Care Transport Agency:

The critical care transport agency must have essential systems and oversight in place to meet the medical needs of critical care patients, including:

1) The agency must be licensed and/or credentialed to operate in the state in which it is based and at the highest clinical level provided by the State, and ideally at the level of critical care to the extent that the State has an approved Scope of Practice for Critical Care Transport.

2) The agency has physician medical oversight consistent with the acuity and conditions of the critical care patients being transported. This may be a combination of medical directors or a physician team supplemented by the addition of consulting specialists. Such appropriate medical oversight includes an actively practicing physician with competency in critical care transport medicine and board certification in a specialty relevant to the provider agency mission or experience in critical care transport medicine consistent with the types, acuity and severity of patients transported.

3) The agency has structured physician directed clinical quality management and clinical performance improvement programs consistent with the condition of critical care patients being transported which demonstrates a continuous process for improving care including standards that require active involvement by physician medical directors to ensure quality and adherence to appropriate standards and reporting requirements related to quality assurance, utilization review, outcomes, proficiency measures, and patient safety.

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Association of Critical Care Transport

800 17th Street NW Suite 1i00 Washington, DC 20006 (202) 828-5003 401 Edgewater Place – Suite 600 Wakefield, MA 01880 (781) 623-0750

www.acctforpatients.org

The critical care definitions were developed in an iterative process of the ACCT Standards

Committee along with a working group and multiple national member and Association conference calls

Work Group Participants:

Craig Bates, MD, Metro Life Flight Josh Dickson, LifeFlight of Maine Stacey Dock, LifeFlight Eagle

Michael Frakes APRN, CCNS, CFRN, CCRN, EMTP, Boston MedFlight Tina Giangrasso, Air Methods,

Christopher Hall, PHI Air Medical Holly Love, LifeFlight Network Mick McCallum, LifeStar of Kansas Ruby Mehrer, LifeFlight Eagle Linda Meiner, PHI Air Medical Tim Meyer, Sanford Intensive Air Cheryl Pasquarella, LifeLink III

Donna Robinson, University of Michigan Sherry Schmitt , Flight for Life

Jim Singer, Flight for Life Charlotte Thomas, Air Methods

Suzanne Wedel, MD, Boston MedFlight References

1. Society of Critical Care Medicine

Guidelines for ICU Admission, Discharge, and Triage

2. Guidelines for the inter- and intrahospital transport of critically ill patients Crit Care Med 2004 Vol. 32, No. 1

3. CMS Manual System

Pub 100-04 Medicare Claims Processing Transmittal 1548

July 9, 2008

4. National Highway Traffic Safety Administration Guide For Interfacility Transfer

DOT HS 810 599 April 2006

5. International Association of Flight Paramedics Critical Care Paramedic Position Statement July 2009

6. About Critical Care Nursing

http://www.aacn.org/wd/pressroom/content/aboutcriticalcarenursing.pcms?menu= 7. Critical Care

http://www.nlm.nih.gov/medlineplus/criticalcare.html 8. National Highway Traffic Safety Administration

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Association of Critical Care Transport

800 17th Street NW Suite 1i00 Washington, DC 20006 (202) 828-5003 401 Edgewater Place – Suite 600 Wakefield, MA 01880 (781) 623-0750

www.acctforpatients.org

National EMS Scope of Practice Model DOT HS 810 657

February 2007

9. Michigan System Protocols INTER-FACILITY PATIENT TRANSFERS CRITICAL CARE PATIENT

TRANSPORTS (OPTIONAL) Date: September 2004 10.Washtenaw/Livingston Medical Control Authority

MICU Protocols

MICU TRANSPORT CAPABILITIES Date: April 2011

11.American Academy of Pediatrics. Guidelines for Air and Ground Transportation of Pediatric Patients Pediatrics 1986;78;943

12.American Academy of Pediatrics Pediatric Interhospital Critical Care Transport: Consensus of a National Leadership Conference Pediatrics 1991;88;696

13.American Academy of Pediatrics Pediatric Specialized Transport Teams Are Associated With Improved Outcomes Pediatrics 2009;124;40 DOI: 10.1542/peds.2008-0515

14.American Academy of Pediatrics Speed Isn't Everything in Pediatric Medical Transport Pediatrics 2009;124;381 DOI: 10.1542/peds.2008-3596

15.American Academy of Pediatrics Consensus Report for Regionalization of Services for Critically Ill or Injured Children American Academy of Pediatrics Committee on Pediatric Emergency Medicine; Pediatric Section American College of Critical Care Medicine and Society of Critical Care Medicine; Pediatric Section, Task Force on Regionalization of Pediatric Critical Care Pediatrics 2000;105;152

16.Commission for Accreditation of Medical Transport Systems, (CAMTS) 9th Edition standards 17.Massachusetts General Laws, Part I, Chapter 111C, Emergency Medical Services System;

and 105 CMR 170.000: Emergency Medical Services System

18.American College of Emergency Medicine, Clinical and Practice Management, Critical Care FAQ. http://www.acep.org/content.aspx?id=30466

ACRONYMS

PICU: Pediatric Intensive Care Unit NICU: Neonatal Intensive Care Unit HROB: High Risk Obstetrical

ECMO: Extracorporeal Membrane Oxygenation PA: Physician Assistant

NP: Nurse Practitioners RN: Registered Nurse CCT: Critical Care Transport Specialty Exams:

CFRN: Certified Flight Registered Nurse CTRN: Certified Transport Registered Nurse CNPT: Certified- Neonatal Pediatric Transport FP-C: Flight Paramedic- Certified

http://www.aacn.org/wd/pressroom/content/aboutcriticalcarenursing.pcms?menu= http://www.nlm.nih.gov/medlineplus/criticalcare.html http://www.acep.org/content.aspx?id=30466

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