The Australian Health Workforce Ministerial Council is considering options to introduce national registration for paramedics.  There are many reasons why paramedics should be registered and these, along with options for registration, are discussed in a consultation paper that was released this month (see AHMAC Health Workforce Principal Committee (HWPC) consultation paper: Options for regulation of paramedics (2012).)  Submissions, in response to the consultation paper need to be received by 3 September 2012.

A part of the discussion paper caught my attention and is the subject of this blog post.  On page 5, under the heading 1.2 Scope of this consultation paper the paper says ‘first aid volunteers (who are not qualified as a paramedic) are not considered to be part of the paramedic workforce.’

This comment is problematic.  As noted in the discussion paper, there ‘is no standard definition of ‘paramedic’ in Australia’ (p 11).  In the absence of a ‘standard definition’ it is at least arguable that first aid volunteers are paramedics.   The discussion paper gives various definitions of who, or what is a paramedic.  These include a person who:

‘provides intensive pre-hospital health care to injured, sick, infirm and aged persons and emergency transport to medical facilities’ (p 11, citing the Australian and New Zealand (NZ) Standard Classification of Occupations (ANZSCO)).

‘a health care professional providing medical assessment, treatment and care in the out-of-hospital environment. Paramedics respond to, assess and treat patients in emergency situations, transport them to a hospital for further treatment (if necessary) or arrange alternative treatment options (p 12, citing Paramedics Australia;

The tasks of ambulance officers and paramedics are described by ANZSCO as including:

  • attending accidents, emergencies and requests for medical assistance
  • assessing health of patients, determining need for assistance, and assessing specialised needs and factors affecting patients’ conditions
  • performing therapies and administering drugs according to protocol
  • resuscitating and defibrillating patients and operating life-support equipment
  • transporting accident victims to medical facilities
  • transporting sick and disabled persons to and from medical facilities for specialised treatment and rehabilitation
  • instructing community groups and essential service workers in first aid
  • attending public gatherings and sporting events where accidents and other health emergencies may occur
  • ensuring that ambulances are adequately maintained and stocked with medical supplies, and that equipment is in good working order, and
  • preparing written reports on the state of patients’ injuries and treatment provided.

In all jurisdictions, paramedics deal with life and death and make routine clinical decisions on a daily basis, often without knowing a patient’s medical or social history. Paramedics regularly triage, assess and clinically manage unconscious, incoherent or combative patients, sometimes in multicasualty situations. (p 12).

First aid volunteers, and in particular volunteers with St John Ambulance Australia may do all those tasks with the exception, perhaps, of ‘transporting sick and disabled persons to and from medical facilities for specialised treatment and rehabilitation.  If that is true, they are paramedics.

The Discussion paper adds that:

As there is currently no uniform regulation of paramedics at a national level, a paramedic’s scope of practice is determined by employers and is not consistently defined. Employers are largely responsible for setting the levels of care to be provided, the skills required to be a paramedic and the protocols, guidelines and procedures that determine paramedic practice.

That may imply that paramedics are necessarily employees but that will be problematic given the use of honorary and volunteer paramedics across Australia.

St John Ambulance Australia (in its various earlier forms) was fundamental player in the delivery of early ambulance services and it remains an authorised provider of ambulance services.  In NSW it is an offence to

(a) directly or indirectly provide or take part in the provision of transport for sick or injured persons for fee or reward, or

(b) conduct for fee or reward any operations similar to the operations carried on by the Director-General under this Chapter,

without the consent of the Director-General… (Health Services Act 1997 (NSW) s 67E).

St John Ambulance Australia (NSW) is specifically exempt from the application of this section reinforcing their right to provide ambulance services in New South Wales.

It follows that St John Ambulance volunteers perform all or nearly all of the duties of paramedics defined by ANZSCO, should not be excluded from the definition of paramedics simply because they are volunteers and are specifically authorised to provide ambulance services.  It is therefore not clear why volunteers with St John Ambulance are not paramedics.

The aim of the consultation paper is to consider issues to do with paramedic registration including who should be eligible for registration.  The starting premise, that ‘first aid volunteers (who are not qualified as a paramedic) are not considered to be part of the paramedic workforce’ presupposes the answers to the critical question of ‘what does it mean to be qualified as a paramedic?’  That is a question the discussion process should be identifying and it may be that first aid volunteers by virtue of their training and experience are, or should be, qualified as a paramedic.

In the discussion of the various options for registration it may be argued that the term paramedic should be reserved for advanced life support officers, with other titles such as First Aid Officer, or Emergency Medical Technician, for other levels of clinical skills.  It may also be reasonable to think that a person who holds no more than a first aid certificate need not be registered, but today St John volunteers carry oxygen, defibrillators and emergency pharmaceuticals; they are not ‘mere’ first aiders any more than advance life support paramedics can be equated to the stretcher bearers of times past.

None of this may be an issue if the final result of the consultation paper is that the term ‘paramedic’ is limited to those with a three year degree in paramedicine.  In that case first aid volunteers will not be paramedics and services, like St John, will be able to deploy volunteers, some of whom are first aiders, others of whom will be registered paramedics, nurses and doctors.

On the other hand, if the result of the consultation is that paramedics are necessarily employed, or meet some definition other than being ‘first aid volunteers’ then that may be problematic for St John.  If that occurs, event organisers may determine that they need ‘paramedics’ to attend their event and provide health care.  If, by definition, that does not include volunteers then St John may well be put behind other private ambulance providers who can claim to provide ‘paramedics’.  St John ambulance may well be concerned to ensure that the ultimate result of the process is that the definition of paramedic does not exclude their well trained and professional, albeit volunteer workforce, and, more importantly, that other service providers cannot use the term paramedic in circumstances where St John cannot.

To do that the definition of paramedic should be identified by reference to an identified qualification or skill set so that St John volunteers who have the relevant qualification or can demonstrate the prescribed skills, can register as paramedics and to ensure that employees of private companies cannot use the term unless they too have the same qualifications or skill set.

Michael Eburn

19 July 2012

DISCLOSURE: Readers of this blog should note that I was a St John Ambulance volunteer from 1979 to 1988 and from 1994 to 1998.  I served with the Ambulance Service of NSW as a probationary ambulance officer in 1988 and as an honorary ambulance officer in 1989 to 1990.