PREPROPOSAL STATEMENT OF INQUIRY
Subject of Possible Rule Making: Pediatric education requirements for designated trauma care services and pediatric trauma care services.
Statutes Authorizing the Agency to Adopt Rules on this Subject: Chapter 70.168 RCW, Statewide trauma care system.
Reasons Why Rules on this Subject may be Needed and What They Might Accomplish: Current pediatric education requirements (pediatric advance life support (PALS)/advanced pediatric life support (APLS) or equivalent) for clinical personnel as required in WAC 246-976-500, 246-976-510, 246-976-550, 246-976-560, 246-976-600, 246-976-610, 246-976-650, 246-976-720, 246-976-730, 246-976-770, 246-976-780, 246-976-810, 246-976-820, and 246-976-885 for designated trauma care services and pediatric trauma care services are generating significant opposition from surgeons and anesthesiologists in nonpediatric designated trauma services. They address that the training is inappropriate, it is not relevant to their practice, it does not offer new skills or knowledge, and it requires them to be away from their busy practice and source of income for a minimum of two days. On the other hand, emergency department physicians and nursing staff at these same types of facilities have not provided any opposition and think the education is useful.
The integrity of the trauma system is being threatened. Some physicians are refusing to meet the standards and lower level hospitals are threatening to drop their designation status. Therefore, the Emergency Medical Services and Trauma Care Steering Committee has recommended changing the current standards to a more acceptable set of pediatric education requirements that are more relevant to the various types of providers.
Other Federal and State Agencies that Regulate this Subject and the Process Coordinating the Rule with These Agencies: No other federal or state agencies regulate this subject.
Process for Developing New Rule: Several statutory and other Emergency Medical Services and Trauma Care Committees will participate in drafting, reviewing and commenting on the proposed rules through open public meetings and public workshops. These committees include constituents representing: Designated Trauma Services, Association of Anesthesiologists - Washington Chapter, American College of Surgeons Committee on Trauma - Washington Chapter, Washington State Fire Commissioner's Association, Washington Ambulance Association, Washington State Firefighter's Association, Washington State Hospital Association, American College of Surgeons, Emergency Nurse's Association, Washington State Law Enforcement, Association of Neurological Surgeons, Washington State Medical Association Standards Committee, Washington State Association of Fire Chiefs, the public sector and the citizens of Washington state. In addition, we also involve constituents by mailing them the appropriate draft rules for their review and input, inviting them to public WAC sessions, and by providing them with information on rules and updates at the appropriate meetings.
Interested parties can participate in the decision to adopt the new rule and formulation of the proposed rule before publication. Open public meetings and public workshops will be held throughout the state and the final draft of the proposed WAC amended language will be sent out to all affected and interested parties before the formal public hearing is held.
Any questions or concerns regarding the pediatric education requirements for designated trauma care services and pediatric trauma care services (WAC 246-976-500, 246-976-510, 246-976-550, 246-976-560, 246-976-600, 246-976-610, 246-976-650, 246-976-720, 246-976-730, 246-976-770, 246-976-780, 246-976-810, 246-976-820, and 246-976-885) should contact Scott Hogan, Program Administrator, Trauma Designation Section, Office of Emergency Medical and Trauma Prevention, 20435 72nd Avenue South, Suite 200, Mailstop TB-33A, Kent, WA 98032-2358, e-mail scott.hogan@doh.wa.gov, phone (253) 395-7009 or fax (253) 395-6724.
April 30, 2001
M. C. Selecky
Secretary