Q3 2026 Commission Meeting

Interstate Commission for EMS Personnel Practice

Official Meeting Minutes

Q2 2026 Full Commission Meeting

Date: April 28, 2026

Time: 2:00 PM Central

Location: InterContinental Kansas City at the Plaza, 401 Ward Pkwy, Kansas City, MO 64112 (In-Person, with Virtual Option via Microsoft Teams). Held in conjunction with the NASEMSO Annual Meeting.

I. Call to Order & Welcome

Chairperson: Commissioner Kraig Kinney (IN)

The Q2 2026 Full Commission Meeting of the Interstate Commission for EMS Personnel Practice was called to order on April 28, 2026, at approximately 2:00 p.m. Central Time at the InterContinental Kansas City at the Plaza, with a virtual option provided via Microsoft Teams. Chairperson Kinney presided over the meeting, welcomed all attendees, thanked Commissioners and members of the public for their participation, and reviewed participation guidelines and meeting protocols.

Roll Call: Secretary Commissioner Mark Herrera (UT)

With Secretary Herrera in attendance, the Chair conducted the roll call. Vice Chairperson Wayne Denny (ID) joined virtually but experienced audio difficulties at the start of the meeting. Commissioner Brad Vande Lune (IA), Commissioner Susan Bailey (LA), Commissioner Lewis Robinson (OK), and Commissioner Susan Neugebauer (WY) participated virtually. With 22 of 25 seated Commissioners participating either in person or virtually, Chairperson Kinney declared a quorum present.

Present (22): Arkansas (Kresse), Colorado (Bateman), Delaware (Doyle), Georgia (Johnson), Idaho (Denny, virtual), Indiana (Kinney), Iowa (Vande Lune, virtual), Kansas (House), Louisiana (Bailey, virtual), Mississippi (Windham), Missouri (Vance), Nebraska (Wilson), Nevada (Sullivan), Oklahoma (Robinson, virtual), Pennsylvania (Martin), South Carolina (Jones), Tennessee (Ward), Texas (Schmider), Utah (Herrera), Virginia (Beermann-Foat), West Virginia (Weller), Wyoming (Neugebauer, virtual)

Absent (3): Alabama (Gray), North Dakota (Price), South Dakota (Hansen).

Introduction of New Commissioners: Chairperson Kinney (IN)

Chairperson Kinney introduced and welcomed three new Commissioners seated since the Q1 meeting:

• Commissioner Sam Vance (Missouri), who returns to the Commission having previously served from 2019 to 2021. Commissioner Vance expressed appreciation for the opportunity to serve again and noted he was reappointed at the end of January 2026.

• Commissioner Susan Neugebauer (Wyoming), participating virtually, who expressed her enthusiasm for joining and looked forward to working with fellow Commissioners.

• Commissioner Donna Doyle (Delaware), newly appointed by the Governor of Delaware. Executive Director Woodyard noted that Delaware is unique among member states in that more than one EMS office holds administrative authority, and that under the Compact, the Governor directly determines both the office and the Commissioner appointment through the Cabinet Secretary. Chairperson Kinney welcomed Commissioner Doyle to her new appointment.

Adoption of Business Agenda: Chairperson Kinney (IN)

Commissioner Jonathan Jones (SC) motioned to adopt the business agenda. Commissioner Anthony Martin (PA) seconded. The business agenda was adopted without opposition.

II. Public Comments Regarding Matters Not on the Agenda

Chairperson: Commissioner Kinney (IN)

Chairperson Kinney opened the floor for public comments regarding matters not on the agenda. One public comment was received from a representative of Pivotal, an electric vertical takeoff and landing (eVTOL) aircraft company, who addressed the Commission regarding emerging electric aviation technology in emergency medical services. The speaker described the company's mission focus on supporting transport crews and time-sensitive interventions, including the recent first-ever use of eVTOL for EMS response in Hyde County, North Carolina, and an upcoming program with the San Bernardino County Fire Department in California. The speaker requested the Commission's collaboration in ensuring that state-level regulatory frameworks evolve in parallel with federal innovation pathways for safe, effective integration of these technologies into the National Airspace System.

No further public comments were received.

III. Reports

Chairperson's Report: Commissioner Kinney (IN)

Chairperson Kinney reported that the Commission has continued to make significant progress since the Q1 meeting. He noted strong Executive Committee engagement, with Commissioners regularly observing those sessions, and credited Executive Director Woodyard's continued work for advancing several states closer to enactment. The Chair highlighted ongoing growth in the National EMS Coordinated Database (NEMSCD), expanding member-state participation, and meaningful federal-level engagement with NHTSA, FEMA, and other partners. He identified continued strengthening of day-to-day operations, bylaws and rulemaking activity (under the leadership of Commissioner Schmider), and continued legislative growth as the Commission's priorities through the remainder of 2026.

Treasurer's Report: Commissioner Brad Vande Lune (IA)

Treasurer Vande Lune (participating virtually) reported the Q1 2026 financial standing: previous balance of $101,087.72, debits of $43,373.90, credits of $47,500.00, with a pending balance of $105,213.82 as of March 31, 2026. The Treasurer also moved that the Commission acknowledge receipt of the calendar year 2025 financial records (balance sheet, income statement, and general ledger), recognize that those records were submitted for independent CPA review consistent with REPLICA Section 10.E.5, and direct that the CPA's written report be incorporated into the Commission's annual report.

Executive Director Woodyard confirmed that the independent CY2025 audit report had been received from the auditor on April 27, 2026. He reported the audit was clean, with one finding related to a contract term, and that the Commission ended CY2025 with a net positive of approximately $13,000. Commissioner Schmider (TX) indicated that, while he did not question the report's integrity, he was not prepared to vote in support of accepting findings he had not personally reviewed, and indicated he would vote against acceptance on that basis. Following discussion, the Chair, the Executive Director, and the Treasurer agreed that the audit acceptance motion would be tabled to allow Commissioners to review the audit letter, with circulation to occur during or shortly after this meeting.

Action: The motion to acknowledge receipt of CY2025 financial records and direct the CPA report into the annual report was tabled. Commissioner Schmider (TX) subsequently moved to accept the Treasurer's report as provided. Commissioner Sullivan (NV) seconded. The Treasurer's report was accepted without opposition.

Executive Director's Report: Executive Director Donnie Woodyard

Executive Director Woodyard provided a comprehensive report covering the legislative landscape, the federal Rural Health Transformation Program (RHTP), and the first-ever de-duplicated workforce findings from the National EMS Coordinated Database. He noted that this is a governmental meeting and that, although Commissioners hold multiple roles in their states, in this meeting they sit as the Governor-appointed delegate to the EMS Compact.

State Legislative Update

• Alaska: Four bills are introduced in the legislature to enact the EMS Compact, three as part of omnibus compact bills and one as a standalone EMS Compact bill. Following a 10-day visit, the Executive Director reported strong, broad support from the Governor, the Senate, and the House, with all parties signaling intent to move legislation across the finish line.

• Arizona: Legislation has passed the House and Senate and was reconciled, currently held due to political maneuvering on the unrelated state budget. The Governor has indicated that no bills will be signed prior to budget passage; transmittal to the Governor is anticipated thereafter. Arizona is expected to become the 26th or 27th member state.

• Connecticut: The EMS Compact is included in the Governor's Finance Bill (state budget vehicle) and is currently in committee. The bill is viewed favorably given its inclusion in the budget.

• Florida: Passed the House (near-unanimously); did not advance in the Senate before session adjournment. Re-introduction is anticipated next session with a favorable outlook.

• New Mexico: Passed the House; did not advance in the Senate before session adjournment. Re-introduction is anticipated next session.

• Montana: Sponsor identified; intent to introduce in the upcoming session.

• Illinois: Sponsor work is underway.

• Massachusetts: Bill remains in study; re-introduction anticipated next session, particularly if Connecticut enacts.

Rural Health Transformation Program (RHTP) Update

Executive Director Woodyard reported that the EMS Compact is named in the federal Rural Health Transformation Program as a top-line item, with state participation in the Compact scoring as a state-policy action under Factor D.2 of the Notice of Funding Opportunity (CMS-RHT-26-001). The program is authorized under Public Law 119-21 at $50 billion over five years, with $10 billion distributed annually.

Findings from the Office of the Executive Director's analysis of all 50 state Year 1 RHTP applications:

• Eight states' Governor's Offices have committed in their RHTP applications to enact the EMS Compact (Alaska, Arizona, Montana, New Hampshire, New Jersey, North Carolina, Ohio, and Oregon). Failure to meet such grant commitments results in penalties in subsequent years.

• Fifteen states created dedicated, named EMS initiatives in their applications.

• Forty-three states (86%) included EMS-related activities at some level.

• Eleven states had no meaningful engagement with EMS in their applications.

• Quantified state EMS allocations ranged from approximately 2% to 48% of total state awards, with a median exceeding 6%.

National EMS Coordinated Database (NEMSCD): Preliminary Federal Partners Briefing

Executive Director Woodyard previewed preliminary findings from a forthcoming federal partners briefing built on a March 25, 2026 NEMSCD extract covering 21 reporting Compact states (Delaware counted as a half-reporting state). Highlights included:

• 410,771 total EMS licenses across 22 of 25 member states reporting (EMT 57.1%, Paramedic 29.6%, AEMT 11.3%).

• 1,152 adverse actions tracked across reporting states.

• First-ever de-duplicated workforce count: 337,411 unique clinicians across 383,717 license records, representing a 13.7% inflation rate at the aggregate workforce level.

• Paramedic workforce over-count rate of 29.7% (31,255 paramedics counted multiple times); legacy state-by-state aggregation yields 136,632 paramedics across 21 reporting states, while the actual unique number is 105,377.

• AEMT workforce over-count rate of approximately 24.3% (one in four).

• Border-state mobility: 65% of multi-state clinicians hold their additional license in a bordering state; 28.8% hold additional licenses in non-bordering states.

• Mountain West regional spotlight: 33.8% of all Wyoming-licensed clinicians and 57.1% of Wyoming-licensed paramedics hold a license in another Compact state.

• Privilege to Practice coverage: 99.29% of unique clinicians have at least one license currently granting Privilege to Practice.

• A data anomaly was identified in North Dakota's Privilege to Practice flag, believed to be a data integration issue rather than a substantive eligibility issue.

The Executive Director outlined the future investment vision for the database, including direct integration with the NEMSIS PCR data system (linking the National EMS ID), the Social Security Death Index, the federal sex offender registry, the USPS forwarding service API, and the CMS Office of Inspector General exclusion list. The first such integration agreement is in active drafting. Commissioner Schmider (TX) recommended partnership with NEMSIS to align the workforce data with prehospital care record (PCR) data.

Additional Items

• EMS Week 2026 (May 17 to 23) and EMS for Children Day (May 20) are addressed in New Business below, including a proposed direct outreach campaign to all 340,000 individuals in the database with a clear privilege-to-practice record.

• National Registry of EMTs has agreed to underwrite the direct cost of the EMS Week outreach (approximately $3,000 to $4,000).

• Five press releases have been issued since the Q1 meeting (full list in the meeting book).

Committee Reports

Stakeholder Advisory Committee: Executive Director Woodyard, Acting Chair

Executive Director Woodyard reported that the committee continues to convene to share information with field partners (the committee is open to the public but does not record minutes or audio). Following the prior Chair's departure, Chairperson Kinney designated Commissioner Anthony Martin (PA) as the new Stakeholder Advisory Committee Chair.

Criminal History and Fitness to Practice Evaluation Committee: Commissioner Jonathan Jones (SC)

Commissioner Jones reported that Position Paper 2026-01 (Criminal Convictions and Licensure of EMS Personnel), unanimously adopted at the Q1 meeting, has been implemented in South Carolina with positive results, and is posted on the Commission's website under Resources. The committee continues to monitor uptake and feedback from member states. Executive Director Woodyard emphasized the strategic value of position papers as expressions of the collective view of 25 member states and the Governors who appointed Commissioners, and as a mechanism for Commissioners to advocate within their states by leveraging the Commission's voice.

Rules & Bylaws Committee: Commissioner Joseph Schmider (TX)

Commissioner Schmider reported that the committee took a brief pause due to medical issues but resumed meeting in March 2026. Work is moving forward, including review of additional bylaw items and adoption of items emerging from other committees. The committee remains open to additional Commissioner participation.

Compliance Committee: Commissioner Joe House (KS), Chair

Commissioner House reported on the proposed Compliance Committee Charter. The Executive Director presented the charter framework, summarizing the Commission's statutory obligation to enforce compliance and outlining the committee's five core functions: (1) monitor Member State compliance with all Compact, Administrative Rule, and Bylaw obligations including NEMSCD integration and data submission, adverse action and discipline reporting, biometric criminal history check implementation, and Commissioner appointment and meeting attendance; (2) prepare annual compliance reports as part of the official government record, with copies provided to Governors and state legislative leadership; (3) provide compliance updates at each scheduled Commission meeting; (4) coordinate technical assistance to member states; and (5) refer persistent non-compliance to the Executive Committee through a graduated process (committee letter, letter to Governor, formal Executive Committee action up to and including suspension of Privilege to Practice for a member state).

Commissioner Robinson (OK) raised challenges with the Oklahoma legal department in adopting standardized vendor contract language and questions of data breach liability. Executive Director Woodyard offered to provide supporting comparative data on certified vendor performance across other states and to assist directly as a reminder that connection is mandated by law. Commissioner Ward (TN) and others affirmed the value of the committee's graduated, technical-assistance-first approach.

Action: Commissioner Ward (TN) moved to approve the proposed Charter for the Compliance Committee. Commissioner Herrera (UT) seconded.

Vote: The proposed Compliance Committee Charter was approved without opposition or abstention.

Database Administrator Report: Ray Mollers (NREMT)

Mr. Mollers reported on the status of the National EMS Coordinated Database. Four-and-a-half states have not reported in the past year. Nebraska is anticipated to be live within the next one to two weeks. Mr. Mollers also confirmed NREMT's continued partnership in the EMS Week direct outreach campaign and stated that NREMT stands ready to support buildout of the database with available federal funding.

Commissioner Martin (PA) reported that Pennsylvania expects to execute its system integration agreement with ImageTrend within one to two weeks, with anticipated full transition completed by year end. Discussion followed regarding the definition and scope of "certified software vendor" status. Executive Director Woodyard clarified that certification reflects demonstrated technical capability to securely connect with and exchange records via the NEMSCD API, that the API standard is published, and that the Commission currently has two commercial off-the-shelf vendors (ImageTrend and Vector Solutions Acadis), one international vendor (Amanda), and proprietary state solutions (including Texas and Virginia, with Louisiana now indicating willingness to make its solution available to other states). Commissioner Bailey (LA) confirmed Louisiana's vendor is open to selling its program to other states.

IV. Old Business

Action: Approval of Q1 2026 Meeting Minutes: Commissioner Herrera (UT)

Secretary Herrera summarized the Q1 2026 minutes (February 11, 2026), highlighting strong participation, confirmed quorum, continued growth and pursuit of legislation, increased federal recognition, stable financials, and adoption of Position Paper 2026-01 on Criminal Convictions. Commissioner Herrera moved approval of the minutes. Commissioner Jones (SC) seconded the motion.

Vote: The minutes were approved with one abstention (Commissioner Schmider, TX) and no opposition.

V. New Business

Action: Resolution 2026-01 - Recognition of EMS Week 2026 (May 17-23, 2026)

Executive Director Woodyard introduced the resolution recognizing the week of May 17 through 23, 2026, as Emergency Medical Services Week (the 52nd Anniversary of EMS Week). He noted that the Commission has, for the second consecutive year, been recognized as a strategic partner in EMS Week. He further offered the Commission's office to assist member states in securing Governor-level proclamations recognizing EMS Week.

Commissioner Bateman (CO) moved adoption of Resolution 2026-01. Commissioner Jones (SC) seconded the motion.

Vote: Resolution 2026-01 was adopted without opposition or abstention.

Action: EMS Week 2026 Direct Outreach and Recognition Project

Executive Director Woodyard presented a project proposal to conduct, in partnership with the National Registry of EMTs, the first-ever direct outreach to all approximately 340,000 individuals in the National EMS Coordinated Database with a clear and valid record. Each clinician would receive an email recognizing their service, with a link to download a personalized certificate using their state's licensure terminology, view their Privilege to Practice status, and learn about the Compact. The certificate distribution will be limited to one per individual based on the mailing address of record. The direct cost (approximately $3,000 to $4,000) will be underwritten by the National Registry of EMTs. Member states retain the option to be excluded from the outreach by request to the Executive Director, and a separate template will be made available for non-reporting states wishing to participate independently. Commissioner House (KS) inquired whether the email would include education about the Compact; the Executive Director confirmed it would, with a link to additional information.

Commissioner Bateman (CO) moved approval of the project. Commissioner Doyle (DE) seconded the motion.

Vote: The EMS Week 2026 Direct Outreach Project was approved without opposition or abstention.

Action: Resolution 2026-02 - Recognition of EMS for Children Day (May 20, 2026)

Executive Director Woodyard introduced the resolution recognizing May 20, 2026, as Emergency Medical Services for Children Day. Commissioner Martin (PA) moved adoption. Commissioner Vance (MO) seconded the motion.

Vote: Resolution 2026-02 was adopted without opposition or abstention.

Action: Resolution 2026-03 - Appreciation for the National Registry of EMTs

Secretary Herrera (UT) moved that the Commission adopt Resolution 2026-03 in recognition of the National Registry of EMTs as an indispensable partner in the operation of the United States EMS Compact, and in appreciation of NREMT's financial, technical, and in-kind contributions, including underwriting substantially all of the Commission's operations and providing the software, infrastructure, hosting, and database administration for the National EMS Coordinated Database. Commissioner Bailey (LA) seconded the motion. Chairperson Kinney noted that, without NREMT's sustained partnership, the Commission would either not be operational or would be charging member states for participation.

Vote: Resolution 2026-03 was adopted without opposition or abstention.

Action: Resolution 2026-04 - Appreciation for the National Association of State EMS Officials (NASEMSO)

Commissioner Beermann-Foat (VA) moved that the Commission adopt Resolution 2026-04 recognizing NASEMSO as a peer organization and standing partner of the Commission and extending appreciation for NASEMSO's sustained advocacy, joint policy work, and hospitality in hosting the Commission's annual in-person meeting. Commissioner Herrera (UT) seconded the motion.

Vote: Resolution 2026-04 was adopted without opposition or abstention.

Discussion: Rural Health Transformation Program - EMS Representation

Executive Director Woodyard provided context on the Commission's policy posture regarding the Rural Health Transformation Program. Following continued engagement, the Executive Director's updated recommendation is to shift from a Congressional-mandate framework (a proposed 5% floor on state RHT awards for rural and frontier EMS stabilization) to a collaboration framework with CMS, focused on improving Year 2 NOFO guidance, benchmarks, and scoring tools available to state applicants. He outlined the rationale: preservation of state discretion over transformation plan design, a collaborative posture aligned with CMS's existing technical-assistance infrastructure, and the observation that scoring weight already favors EMS (Factor C.2) and licensure compacts (Factor D.2), with the gap being one of accessible guidance rather than incentive structure.

The Executive Director also reiterated his view that, given the five-year window of the program, the Commission's most consequential ask is reliable, multidirectional health information exchange (HIE) for EMS as the foundation for treatment-in-place, community paramedicine, alternate transport, and full integration into the broader healthcare system.

Commissioners discussed approach. Commissioner Schmider (TX) expressed concern that CMS may treat collaboration as lip service and noted there are circumstances where a mandate is appropriate, while supporting the Executive Director's proposed approach in the near term. Commissioner Vance (MO) supported giving the collaborative approach a year to demonstrate results before considering a stronger position.

Action: Commissioner Schmider (TX) moved to authorize the Executive Director to advance the Commission's position on Rural Health Transformation Program EMS representation through engagement with CMS, beginning with a written position paper for Commission review. Commissioner Ward (TN) seconded the motion.

Vote: The motion was approved without opposition or abstention. The Executive Director is authorized to engage CMS on the Commission's behalf, with the understanding that the position paper will be brought back to the Commission for review and refinement.

Discussion: National Disaster Preparedness and Interstate Mobility of EMS Personnel

Executive Director Woodyard provided background on the Commission's engagement with FEMA regarding the National Medical Transport Service (NMTS) contract (the National Ambulance Contract). He noted that the contract was originally constructed in 2007, before the EMS Compact existed, and uses a broad waiver-of-licensure approach that does not contemplate accountability mechanisms for cross-state EMS practice. The Compact, the Privilege to Practice mechanism, and the National EMS Coordinated Database now provide the infrastructure to support credentialed federal deployment with accountability. The Executive Committee previously authorized engagement with the Acting FEMA Administrator, and initial conversations have been positive.

Commissioner Jones (SC) noted that, in South Carolina, the FEMA contract is the last mechanism activated, with EMAC and Compact privileges generally sufficient. Commissioner House (KS) raised two considerations: (1) the interaction with Section 6 of the Compact, which addresses how the EMS Compact operates alongside the Emergency Management Assistance Compact (EMAC); and (2) concerns about non-Compact states with significant provider populations. Executive Director Woodyard explained that EMAC and the EMS Compact were created under the same constitutional provision and operate as co-equals, with EMAC provisions superseding in areas of conflict; however, the National Ambulance Contract is not always activated through EMAC, which is the gap the Commission seeks to address. The Executive Director clarified that the Commission's recommended position is for the EMS Compact to be recognized in the federal contract alongside EMAC as a legal mechanism, encouraged where possible but not exclusive, and not negatively impacting non-Compact states.

Commissioner Schmider (TX) suggested the Commission keep the National Ambulance Contract conversation focused (separating it from the more settled EMAC framework) and explore appropriate cost recovery for Compact services. Commissioner Bailey (LA) supported continued conversation.

No motion was offered. The Chair confirmed the Executive Director will continue engagement on behalf of the Commission, with periodic updates.

VI. NGO / Stakeholder Partner Updates

U.S. DOT NHTSA Office of EMS: Federal Partner Update

A representative from the U.S. Department of Transportation, National Highway Traffic Safety Administration (NHTSA) Office of EMS addressed the Commission and thanked the Commission for its work. The representative highlighted the Safe Streets and Roads for All (SS4A) grant program (FY2026 Notice of Funding Opportunity, deadline 5:00 p.m. Eastern, May 26, 2026), with $999.5 million available, including approximately $300 million in planning and demonstration grants. NHTSA's Administrator has identified prehospital blood transfusion as a top priority over the next three years, and SS4A applications that include public safety infrastructure and prehospital blood transfusion will receive preferential scoring. The representative encouraged member states to engage local agencies regarding application opportunities.

The representative also discussed ongoing NHTSA work on outcomes data quality, focusing initially on a defined pediatric population (ages 1 to 14) meeting crash and metric criteria for blood transfusion. NHTSA has confirmed the largest interagency agreement in agency history with NHTSA for related data work and is working on supporting the National EMS Coordinated Database integration with that effort. Commissioner Schmider (TX) raised the longstanding question of authority to compel hospital outcome data; the NHTSA representative confirmed engagement with the Office of the National Coordinator for Health IT and ongoing efforts to advance health information exchange (HIE) integration as the path forward.

VII. Adjournment and Executive Session

Having reached the end of the published agenda, Chairperson Kinney thanked all attendees and entertained a motion to recess and reconvene in Executive Session pursuant to Section 10.B.6 of the REPLICA model legislation, with closed session matters under Section 10.B.5(a). Commissioner House (KS) moved to recess and reconvene in Executive Session at 4:05 p.m. Central with Commissioners only. Commissioner Jones (SC) seconded the motion.

Vote: The motion was approved without opposition or abstention. The public meeting was adjourned, and the Commission reconvened in closed Executive Session.

Public Meeting Adjournment: Approximately 3:55 p.m. Central.

Commissioner Roll Call - April 28, 2026

Ex-Officio & Staff

Position Paper 2026-XX | DRAFT FOR COMMISSION CONSIDERATION

A position paper is a formal document that outlines an organization's stance on a specific issue, supported by research and analysis, with the goal of influencing decision-making or advocating for policy changes. It serves to clarify and communicate the organization's viewpoint to stakeholders, policymakers, and the public, while often calling for specific actions or solutions to address the issue. Position papers are essential tools for driving discussions, informing stakeholders, and promoting thoughtful, data-driven decisions.

Executive Summary

The EMS Compact extends a Privilege to Practice to qualified EMS clinicians across all Participating States and jurisdictions. As Compact membership grows, an EMS clinician licensed in one Participating State may lawfully practice in jurisdictions located in time zones far removed from the Home State. For example, a paramedic licensed in Virginia may practice under the Privilege to Practice in Alaska. In the future, if all states and eligible territories enact the EMS Compact legislation, an EMS Clinician from Virginia could practice in jurisdictions such as Guam, where local time differs from the Home State capital by fourteen hours or more.

This reality raises a simple but consequential question: when a Home State license expires on a stated calendar date, at what moment in time, and in which time zone, does that expiration take effect? Because the Privilege to Practice ends immediately upon expiration of the Home State license, the answer determines the precise moment a clinician’s authority to practice ends in every Participating State simultaneously.

The position of the Commission is that a Home State license, and the Privilege to Practice derived from it, expires at the moment the Home State licensure system reports the license as expired. Absent other guidance from the Home State, a Home State license, and the Privilege to Practice derived from it, remains valid through 11:59:59 PM local time on the license expiration date, as local time is observed at the capital city of the issuing state or jurisdiction. Under this default standard, the moment of expiration is fixed by the issuing jurisdiction’s capital city clock and does not shift based on where the clinician is physically practicing.

1. Purpose

This position paper establishes a uniform, transparent interpretation of the moment at which an EMS license expires for purposes of the EMS Compact and the Privilege to Practice. Its purpose is to ensure clarity and predictability for EMS clinicians, employers, EMS agency medical directors, and State EMS Authorities, recognizing that a license issued in one time zone may support lawful practice in jurisdictions many time zones away. Above all, this paper ensures that EMS clinicians understand that practicing in a different time zone does not extend a license expiration beyond the date and time of the jurisdiction that issued the license.

2. Background and the Issue

State licensure systems record license expiration as a calendar date. They do not ordinarily specify a time of day or a controlling time zone, because a license used only within the issuing state presents no ambiguity. Interstate practice under the Compact changes this. Without a uniform interpretation, a clinician, employer, or State EMS Authority could reasonably reach different conclusions about whether a license, and therefore the Privilege to Practice, remains valid during the window of time created by time zone differences.

While this question may rarely arise in day-to-day operations, it is foreseeable, and the consequences of ambiguity fall on clinicians acting in good faith and on the officials responsible for verifying credentials. A shared, predictable standard protects clinicians, supports employers and medical directors in verifying credentials, and ensures the National EMS Coordinated Database reflects a single, consistent moment of expiration.

3. Position of the Commission

For purposes of the EMS Compact and the Privilege to Practice, the Commission adopts the following interpretation:

A Home State license, and the Privilege to Practice derived from it, expires at the moment the Home State licensure system reports the license as expired. Absent other guidance from the Home State, the license, and the Privilege to Practice derived from it, remains valid through 11:59:59 PM local time on the license expiration date, as local time is observed at the capital city of the issuing state or jurisdiction.

Under this default standard, a Virginia license is valid through 11:59:59 PM on its expiration date as observed in Richmond, Virginia. The moment of expiration is fixed by the issuing jurisdiction’s capital city clock and does not shift based on where the clinician is physically practicing.

Other guidance from the Home State includes any statute, regulation, or published policy of the issuing state or jurisdiction that establishes a different time or time zone standard for license expiration, as well as the actual reporting behavior of the Home State licensure system. Where such guidance exists, it controls for licenses issued by that state. This position paper supplies a default interpretation only where the Home State is silent.

Primary source licensure status. State licensure systems maintain their own software processes that change a license status from licensed to expired. The status recorded in the issuing state’s licensure system is the primary source and the single source of truth for licensure status, and it is reflected in the National EMS Coordinated Database consistent with the primary source equivalency provisions of the Commission’s Administrative Rules (Rule 11.1(B)). The standard described in this paper cannot be used to assert that a license remains valid after the primary source reports it as expired. Its purpose is to ensure that EMS clinicians understand that practicing in a different time zone does not extend the license expiration date beyond the date and time established by the jurisdiction that issued the license.

4. Rationale

• Home State control. The license is a creation of the issuing state. Anchoring expiration to the issuing jurisdiction’s own local time is consistent with the structure of the Compact, in which the Home State retains exclusive authority over the license itself.

• A single national moment of expiration. Fixing expiration to one clock produces one unambiguous moment at which the license and the Privilege to Practice end everywhere, rather than a rolling expiration that varies by the clinician’s location.

• The capital city resolves multi-time-zone states. Several states span two time zones. Anchoring to the capital city provides a single, objective reference point within every issuing jurisdiction.

• Local time resolves daylight saving variation. Because the standard follows the time actually observed at the capital city, jurisdictions that do not observe daylight saving time, such as Arizona, and those that do are treated identically and without special rules.

• Transparency and predictability. Clinicians, employers, medical directors, and State EMS Authorities can all determine the exact moment of expiration in advance, from public information, without individualized inquiry.

5. Practical Application

The examples below illustrate the default standard, which applies absent other guidance from the Home State.

Eastward-licensed clinician practicing west. A Virginia-licensed paramedic practicing in Alaska holds a license valid through 11:59:59 PM Eastern Time in Richmond on the expiration date. Because Alaska local time is four hours behind Richmond, that moment corresponds to 7:59:59 PM Alaska Time on the same calendar date. The clinician’s authority in Alaska ends at that moment, in the evening of the printed expiration date as observed locally, before the calendar date has ended in Alaska.

Westward-licensed clinician practicing east. An Alaska-licensed clinician practicing in Virginia holds a license valid through 11:59:59 PM Alaska Time in Juneau on the expiration date. That moment corresponds to the early morning hours of the following calendar day in Virginia. The clinician remains authorized in Virginia until that moment, even though the local Virginia calendar has already advanced past the printed expiration date.

6. Guidance

• EMS clinicians remain individually responsible for maintaining licensure, tracking expiration dates, and renewing before expiration, as reflected in the Privilege to Practice Code of Conduct. Clinicians should renew well in advance of the expiration date and should not rely on time zone differences to extend practice authority.

• Employers, EMS agencies, and medical directors verifying credentials near an expiration date should apply the capital city standard described in this paper and verify current status through the National EMS Coordinated Database at www.EMSCompact.gov using the clinician’s National EMS ID number.

• State EMS Authorities should note that the Coordinated Database reflects licensure status as submitted by the Participating State. Where a status question arises during the window created by time zone differences, the standard in this paper governs the interpretation of the expiration date for Compact purposes.

7. Frequently Asked Questions

Q: Does this position change when my license expires?

A: No. The expiration date of a license is established by the issuing Home State. This paper clarifies only the moment in time at which that expiration takes effect for interstate practice under the Compact.

Q: I am practicing in a time zone ahead of my Home State and my license expires today. When must I stop practicing?

A: Your authority ends at the moment your Home State licensure system reports the license as expired. Absent other guidance from your Home State, that moment is 11:59:59 PM as observed at the capital city of your Home State. Depending on where you are practicing, that moment may fall on a different local calendar date. Clinicians should plan renewals well in advance and should never schedule practice around the final hours of licensure.

Q: What if my Home State already specifies a time or time zone for license expiration?

A: The Home State’s guidance controls, whether established by statute, regulation, published policy, or the reporting behavior of the Home State licensure system. This position paper supplies a default interpretation only where the Home State is silent on the question.

State Sovereignty and Compact Compliance

This document provides a uniform interpretation for Compact purposes. States that have enacted the EMS Compact retain full sovereignty over their licensure systems, including the authority to establish, by statute or regulation, the effective time of license expiration for licenses they issue. Nothing in this paper modifies a state’s licensure laws or renewal requirements.

Disclaimer: Position papers produced by the Interstate Commission for EMS Personnel Practice are designed to document the official positions of the Commission. It is important to note that these position papers are not administrative rules. Instead, they are intended to provide perspectives and insights on various matters of policy. These documents are meant to guide and inform but should not be mistaken for legally binding regulations or mandates.