Dear CEO Letter: Trauma Care in New York State Consolidated into a Statewide Trauma System, May 27, 2011

May 27, 2011

Dear CEO:

Trauma Care in New York State Consolidated into a Statewide Trauma System

In 1990, trauma care in New York State was consolidated into a statewide trauma system. Regulation was created (10-NYCRR-708) establishing uniform standards by which a hospital could be evaluated and subsequently designated a trauma center by the Department. These regulations were modeled after the 1990 trauma care standards of the American College of Surgeons (ACS) published in Resources for Optimal Care of the Injured Patient. The regulations have remained unchanged since that time.

During the years 2000 through 2005, with assistance from expert reviewers from the State Trauma Advisory Committee (STAC), the Department surveyed all trauma centers to assess how well each met the 1990 regulations. It was determined that, although the trauma centers continued to meet State regulations, the 1990 regulations themselves are old and require updating. In 2006, the Department formed a workgroup of content experts from the STAC to review the most current ACS standards (Resources, 2006) and update the 1990 State regulations.

Although the workgroup has made good progress, it has taken more than five years to only partially complete the project. Complicating efforts is the fact that the project began in 2006 using Resources, 2006; but now, the ACS is preparing to release Resources, 2011, which will require the workgroup to somewhat start over. Additionally, once new regulations are promulgated, the Department would then have to re-survey all trauma centers against the new regulations – a process that when last undertaken (2000–2005) took so long to complete that at the end the ACS standards upon which the State regulations were modeled had changed making the regulations out of date.

It is clear that the Department's efforts to assure the State trauma system continues to meet current trauma care standards by updating regulation and re-survey trauma centers will be a never ending repetitive cycle; causing concern about the Department's ability to support and maintain such efforts long-term. As such, instead of attempting to "keep up" by incorporating ACS standards into State regulation, the Department and STAD are exploring the possibility of directly adopting the ACS standards and having the ACS survey/verify trauma centers in New York State.

This idea was first presented to the STAC at its September 2010 meeting, and further discussed at the recent March 2011 meeting. The next STAC meeting is scheduled for September 7, 2011 at which time the STAC will be asked to make a formal recommendation on whether or not the Department should pursue adoption of ACS verification. The STAC, however, can not make a recommendation – nor the Department a decision – without being informed of the impacts this will have on the individual trauma centers and regional trauma systems. The Department and STAC are in need of comment from stakeholders such as you and your trauma care institution.

To that end, you and your staff are asked to take the time to investigate your institution's ability to meet the current ACS standards (Resources, 2006) and examine the impacts (both positive and negative) ACS verification may have on your institution and the regional trauma system in which it lies. If your hospital is part of a larger system of hospitals and/or trauma centers, you are asked to partner with your sister facilities in studying this question from the larger organizational as well as individual perspectives. Also, you should be aware that although State regulations currently recognize only "regional" and "area" trauma centers (corresponding to ACS Level 1 and Level 2, respectively), ACS also offers a Level 3 verification that would become available should New York move to the ACS. With this, if you find your hospital will have difficulty meeting the ACS standards of its current designation level, you are encourage to consider the possibility of "dropping down" one level (Level 1 to Level 2, or Level 2 to Level 3) and the positive and/or negative impacts this may have.

Once you and your staff have investigated this matter, you are asked to forward in writing (address below) your thoughts, concerns, and comments so that they may be share with the STAC and allow the STAC to make an informed recommendation to the Department at the September 7, 2011 STAC meeting. Be assured that any comments you make will be in confidence; being shared in whole only with DOH officials and the eight STAC Executive members. All comments will be blinded before being distributed to the entire 31 member STAC.

Please understand that you are not being asked to "go on the record" and make a definitive binding statement. You are simply being asked to comment on the impacts as you and your institution see them. Should the position of your institution change later-on, you will not be bound by any statement made in response to this inquiry.

This letter is being sent to the CEOs of all 40 trauma centers. So as to allow time for receipt and review of all stakeholder input before the September 7, 2011 STAC meeting, you are ask to please provide your comments by July 15, 2011.

The Department and STAC thank you for taking the time to participate in this process. Your comments will be invaluable towards a final decision. Please contact my office should you have any questions or concerns.


Lee Burns
Acting Director
Bureau of EMS
433 River St., Suite 303
Troy, NY 12180
(518) 402-0996