In the second attempt at revamping Texas’ emergency medical services (EMS) and trauma care rules for the first time in nearly two decades, the Texas Medical Association praised health officials for their collaborative and transparent approach, but still harbors concerns about revisions that could reduce access to trauma care and physicians’ role in providing it.
Initial rules proposed by the Department of State Health Services (DSHS) garnered a groundswell of feedback, including from TMA, and that project was withdrawn by the state in April as health officials sought to fully address approximately 4,000 comments. DSHS released round two of its revisions Aug. 2 in the Texas Register.
“For this rule process, there were so many comments that they went back and kind of started over. That’s no small thing. [The state has] definitely been willing to listen,” said Robert Greenberg, MD, a consultant to TMA’s Committee on EMS and Trauma. The vice president and chief medical officer of emergency services at Baylor Scott & White Health, Central Texas Division, participated in a multidisciplinary ad hoc group convened by DSHS to vet the rules and stakeholder comments.
Throughout, TMA continues to push for a system that ensures safe, timely, and appropriate trauma care for all Texans, and that includes appropriate physician oversight. A significant portion of DSHS’ second round of proposed rules were aimed at aligning state standards with those of the American College of Surgeons (ACS), which TMA commended in a September letter.
For instance, such congruency ensures state standards remain current with respect to ACS updates to designation criteria and national trauma standards, TMA noted. That change is particularly important for level I and II trauma facilities, which ACS surveys during the designation process. Previous DSHS revisions also had streamlined the level IV facility categories and requirements.
At the same time, TMA cautioned against provisions that compress surveyor teams for level I and II trauma facilities by removing the requirement that such teams include an emergency physician and trauma nurse.
“We always say that trauma care is a team sport,” Dr. Greenberg said. “It’s not just about the surgeon; it’s not just about the bedside nurse; it’s about all of us working together. Our designation process should emulate that.”
In its letter to DSHS, TMA asserted the critical importance of including surveyors who are actively involved in trauma patient care, irrespective of the slightly increased costs a larger, multidisciplinary team might incur. That position builds on but recommends exceeding current ACS standards for surveyor teams.
The association also identified burdensome stipulations that could dissuade physicians from taking on leadership roles by requiring trauma medical directors to personally participate in regional advisory councils, and that could discourage level IV facilities from retaining trauma designation.
TMA continues to monitor the rule revisions, which are expected to be finalized by the end of the year. Read Texas Medicine Today for updates.
Jessica Ridge
Reporter, Division of Communications and Marketing
(512) 370-1395