December 31, 2020
Commissioners of St. Mary’s County
PO Box 653
Leonardtown, MD 20650
Re: Public Hearing – January 5, 2021 – EMS Billing

Dear Sirs,
Please accept this letter as my comments submitted for the public hearing on January 5, 2021, to consider the legislative proposal stating the “Commissioners of St. Mary’s County are the Authority Having Jurisdiction for the purposes of Emergency Medical Services (EMS) Billing.”

The title of the proposed legislation is misleading of its true scope and purpose. Jurisdiction will not be limited to only EMS billing. The proposal without its verbosity states, “The Commissioners of St. Mary’s County may adopt and implement ordinances or resolutions … to … manage, direct, and regulate … emergency medical services …”

The purpose of the legislation is to provide the county with “jurisdiction over the provision of services provided by Rescue Squads and Advance Life Support … units or entities in St. Mary’s County.” The reason for jurisdiction is that to transition “from 100% volunteer service to a combination of career and volunteer service … the local elected officials need to be the authority having jurisdiction over EMS services …” EMS billing is a Trojan horse. This is a power grab by the county department of emergency services to take control of the volunteer rescue squads.

St. Mary’s County Commissioner John O’Connor appears to be an adherent of the political doctrine that politicians should never let a crisis go to waste. The epidemic has resulted in a shortage of volunteers and necessitated the county supplementing the rescue squads’ staffing with EMS contractors initially paid for with federal funds.

This is the “nose of the camel,” an innocuous act that opens the door to ulterior purposes and outcomes. O’Connor, the legislation’s sponsor, and Mr. Stephen Walker, director of the county’s emergency services department, are collaborating to place county employees in the volunteer rescue squads.

In a reversal of roles, the volunteers will become supplemental to the county employees.

However, the impediment to this scheme is the source of long-term funding for the costs of the county employees, hence the need for EMS billing.

The 2021 continuation of the EMS contractors requires county funding, which is available in the unassigned general fund balance of $33.4 million as of June 30, 2020. Walker argues that county employees will be less expensive than contractors, but without providing any proof of this
claim.

In a December 1 memo, Walker suggests reassigning funding for the Advanced Life Support Unit to his department, and “If that occurs, the contractor could continue to provide services until we transitioned Medics into County employees.”

In a December 15 memo, Walker writes, “I recommend we begin to transition contract employees to hourly employees; continuing to use the services of the contractor until all Contract EMT’s and Contract Medics have
transitioned to County hourly employees.”

The county sees the opportunity to recover its costs by billing patients for rescue squad transport services. A rescue squad can seek direct reimbursement from health insurance carriers for ambulance services. With this legislation, the county can do so by having the “ambulance
service provider … under the jurisdiction of a political subdivision of the State” (MD Code § 15-138).

Without this legislation, the alternative “foot in the door” is a memorandum of understanding (MOU) in which the rescue squad authorizes the county to seek direct reimbursement from insurance carriers on its behalf.

After paying the county’s third-party billing service fees and supplemental staffing, the rescue squad receives the balance. Will the MOU
funding affect the non-profit status of the rescue squads?

Do the rescue squads understand that they would be helping to fund their future demise?

How much will the county charge for transporting a person to the hospital, previously all-volunteer and in-part funded with a property tax fee?

  • Reportedly, Walker said in a newspaper interview that the cost for an ambulance ride and services could be between $400 and $600 charged
  • to the person’s health insurance provider. Prince George’s County’s fees for ambulance transport include $500 for Basic Life Support transport, $650 for Advanced Life-1 Support transport, and $750 for Advanced Life Support-2 transport.
  • Are the St. Mary’s County Commissioners blind-sided by a lack of information?
  • • What are the costs-versus-benefits of replacing volunteers with county employees?
  • • As the number of county EMS employees increases, what are the projected future
  • costs and the fee structure?
  • How many patient transports equal a break-even between expenses and revenue?
  • Will the fee be higher for out-of-county transports?
  • By what amount will the price per transport increase with the number that is unpaid due to waivers and people without health insurance?
  • If the future transition of the rescue squads from all-volunteer to employees is unavoidable due to the interaction of population growth and EMS call demands, why should the transition be to county employees?
  • Has the alternative of the rescue squads partnering with the management of MedStar St. Mary’s Hospital been considered? The public sector provision of essential public services should not supersede its delivery by the private sector, if available.


I suggest that the county commissioners wait until the epidemic subsides before assessing the resilience and adequacy of the volunteer rescue squads. Continue to fund EMS contractors from the general fund and defer EMS billing and the conversion to county employees. Crisis management, the political exploitation of COVID, and opportunistic bureaucratic expansion should not influence this decision. Community volunteerism is at stake.
Sincerely;
Vernon Gray,

California, Md.

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