International Association of Arson Investigators/International Association of Fire Chiefs/
International Association of Fire Fighters/International Fire Service Training Association/
National Fire Protection Association/National Volunteer Fire Council/
North American Fire Training Directors

May 23, 2005

The Honorable Michael Chertoff
Secretary, Department of Homeland Security
Washington, DC 20528

Dear Secretary Chertoff:

Recently, the George Washington University Homeland Security Policy Institute (HSPI) released a
report titled “Back to the Future: An Agenda for Federal Leadership of Emergency Medical Services.”
The report proffers a number of recommendations to raise the current level of representation
emergency medical services (EMS) receive within the Department of Homeland Security (DHS). As
the organizations which represent a substantial majority of EMS in this country, we fervently believe
that the changes proposed in this report would have a deleterious effect on EMS and undermine all
progress made to date within DHS to coordinate and consolidate homeland security policies and
programs consistent with the mission of your department.

Furthermore, we question the validity of the information used in the report to justify the position of
HSPI. We believe that in certain instances, HSPI is conjecturing, and in other instances providing an
incomplete picture or distortions that serve to advance their arguments. Certain members of the
HSPI Steering Committee and HSPI Task Force on Emergency Medical Services removed their names
from this report because it was not properly vetted. There would not be this perceived ringing
endorsement for a separate federal agency dedicated exclusively to EMS issues had HSPI sought
comments from these distinguished members who represent our nation’s fire service at the national
level. Instead, the report would have included alternative proposals to a new agency, such as
working within the framework of the United States Fire Administration or enhancing the Federal
Interagency Committee on Emergency Medical Services, as proposed in Congress, to address EMS
issues.

Before giving thought to the HSPI report, it is important to clarify the definition of EMS. It stands
for Emergency Medical Services, inclusive of initial response through advanced life support care and
transport. EMS is a service provided by myriad entities and individuals. EMS is NOT an isolated
component but is a time-critical essential public service. Citing statistics from a 2004 Journal of
Emergency Medical Services (JEMS) study, HSPI claims “44.89 percent of EMS systems are fire-based
and 55.11 percent are hospital-based, private, stand-alone government agency or another type of EMS
organization.” However, we believe that the 2004 JEMS 200 City Survey provides a clearer picture of
the workload of the various EMS entities in this country. Of the 200 most populous cities surveyed,
90% reported that fire service personnel provide medical first response. The statistic cited by HSPI
refers to the EMS systems in place, not the services provided by these various systems.

Page Two – The Honorable Michael Chertoff

Addressing the issue of federal funding, the HSPI report claims that EMS providers receive only four
percent of the first responder funding allocated by DHS. Once again, the report egregiously omits
fire-based EMS from its definition of EMS. In fact, EMS qualifies for and receives funding through a
variety of DHS programs, including the Assistance to Firefighters Grant Program, Urban Area
Security Initiative, State Homeland Security Grants Program as well as programs administered by
other federal agencies. Because this is such a critical issue to all vested parties, we would support a
thorough analysis by GAO on the amount of federal funding available to EMS. We do not dispute the
need for additional funding; rather we question the assumption underlying the four percent figure.

Moreover, the HSPI recommendations would redirect homeland security funding to for-profit and
hospital based transport agencies, which may not be the most effective use of limited homeland
security dollars. Such agencies often receive reimbursement for services from Medicare and other
insurance coverage, while fire departments providing only initial emergency care receive no
compensation.

Lastly, but most importantly, we would like to address the idea of a separate U.S. EMS agency. EMS
is one component of an emergency response system, and creating a separate federal entity for EMS
would balkanize emergency response and diminish the role of the United States Fire Administration.

It would also potentially isolate EMS into an office separate from the other first responder programs
at DHS. Every report published since 9-11 by various task forces and commissions has advocated
consolidation and integration in homeland security strategies. This idea of a new EMS agency
contradicts the consensus opinion of the Congress, administration and think tanks alike.

Is there room for improvement? Absolutely. Is there a need for better coordination in DHS,
especially where EMS is concerned? Without a doubt. However, such drastic measures such as the
ones HSPI suggests will only weaken public safety. We must recognize the existing infrastructure for
EMS within the federal government, utilize it where it has been successful, and coordinate its
activities both at the federal and local levels. The individual states drive EMS policy; an added level
of federal bureaucracy will only hamper their efforts. Our efforts should be concentrated on the
coordination of EMS resources, not rearranging the deck chairs.

Any proposals involving the role of EMS within the Department should be initiated by, and carefully
vetted through, EMS providers from all disciplines – fire-based and non-fire-based. Unfortunately,
HSPI chose not to take this route. The lack of support from any nationally recognized fire service
leader and the opposition of several national EMS organizations show that this issue needs an open
and public discussion within the first responder community.

We look forward to working with you and your staff on this issue. If we can ever be of assistance,
please do not hesitate to contact our offices. Thank you for your continued support and your
commitment to our nation’s first responders.


Sincerely,
International Association of Arson Investigators
International Association of Fire Chiefs
International Association of Fire Fighters
International Fire Service Training Association
National Fire Protection Association
National Volunteer Fire Council
North American Fire Training Directors

Fire_opposition_letter.zip (39 Kb, 0 downloads) Fire Opposition Letter