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Paramedic Subscription Program Administrative Rules

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FULLERTON FIRE DEPARTMENT

PARAMEDIC SUBSCRIPTION PROGRAM
ADMINISTRATIVE RULES

 Adopted by Fullerton City Council on May 7, 2024

  1. Introduction 
    These guidelines have been adopted by the City Council of the City of Fullerton to govern the City’s Paramedic Subscription Program.

  2. Program Overview

    The Paramedic Subscription Program is a program that the City makes available on a voluntary (“opt-in”) basis.

    The Program provides the opportunity for eligible Households, Businesses and Non-Resident Students to choose to enroll in the program (and pay a flat annual fee) rather than take on the risk of having to pay out-of-pocket expenses for emergency medical services provided by the City.

    Enrollment in the Program is not required to receive assistance, including EMS/paramedic services, from the City’s Fire Department. Enrollment does not alter the amounts of fees-for-services that are charged by the City for emergency medical services. Such fees are charged to a patient (and the patient’s insurance, if any) regardless of whether the patient is enrolled in the Program. Enrollment only provides a waiver of eligible out-of-pocket expenses in connection with emergency medical services provided by the Fire Department. No waiver is provided by the Program for fees for basic ambulance transportation or mileage charges.

  3. Definitions

    The following terms have the meanings set forth in this Section 3.

    1. Business: A person (or business entity) that has obtained a business license from the City and that engages in business in the City from a permanent physical location located in the City where that person employs one or more individuals.
    2. Eligible Employee: An employee of a Business who works primarily at the permanent physical location of the Business within the City. If the business is a sole proprietorship or a partnership, Eligible Employee also includes each sole proprietor or partner who works at least half-time at the permanent physical location providing.
    3. Enrollee: A Household, Non-Resident Student, or Business that has enrolled in the Program for a Program Year
    4. Household: All persons, whether related or unrelated, who live the same dwelling unit (such as a single family home or an apartment unit) or hotel/motel room as their primary residence. Where an individual has a congregate care facility (such as a nursing home or convalescent facility) as their primary residence, that individual qualifies as a Household, but each such person living in such facility constitutes a separate Household.
    5. Non-Resident Student: An individual who attends an accredited educational institution within the City of Fullerton, but does not permanently reside within the City limits.
    6. Program Year: A period that runs from July 1 of one calendar year until June 30 of the following calendar year.

  4. Eligibility Criteria
    1. Only Households, Non-Resident Students, and Businesses may enroll in the Paramedic Subscription Program.
    2. A Household may enroll in the Paramedic Subscription Program only if the primary residence of that Household is located in the City of Fullerton.
    3. A Non-Resident Student may enroll in the Paramedic Subscription Program only if that Non-Resident Student is enrolled as a full-time student at an accredited educational institution located in the City of Fullerton.
    4. A Business may enroll in the Paramedic Subscription Program only if that Business operates a permanent physical location in the City of Fullerton and has obtained a Business License from the City for operation at that location.
    5. The Fire Department (or such other department as is authorized by the City Manager, or his or her designee, to verify program eligibility) shall verify eligibility for the Paramedic Subscription Program before granting an applicant enrollment in the Paramedic Subscription Program. Such verification process may involve requiring an applicant to provide evidence of eligibility, such as a utility bill, lease documents, business license or evidence of school enrollment. The City Manager, or his or her designee, may promulgate guidelines regarding acceptable forms of evidence.
    6. Because Medicaid programs do not require recipients to pay a cost-sharing amount to the City, a Household is ineligible for the Paramedic Subscription Program if all members of the Household are enrolled in Medi-Cal or a Medicaid program operated by another state.

  5. Fees
    1. Fees for enrollment in the Paramedic Subscription Program are as adopted by the City Council and may be found in the City’s Comprehensive Fee Schedule.
    2. The fees must be paid by each Enrollee for each Program Year in which they enroll.
    3. A Business that chooses to enroll for a Program Year must pay one fee for every ten Eligible Employees. A business does not have the option of paying for less than the total number of Eligible Employees at the Business location. If the number of Eligible Employees at the Business location increases during a Program Year, the Business must inform the City of this and pay any additional fees due as a result of the increased number of Eligible Employees.
       
  6. Enrollment and Changes in Enrollment
    1. Enrollment for a Program Year begins on the May 1 prior to the beginning of that Program Year. For example, enrollment opens on May 1, 2025 for the Program Year that runs from July 1, 2025 through June 30, 2026.
    2. The date of enrollment in the Program for a specific Program Year is the latest of (i) the date the City receives a valid enrollment form from the Household, Non-Resident Student, or Business seeking to enroll in the Program, (ii) the date the City receives payment of the required fee for enrollment, or (iii) the first day of the Program Year.
    3. The City Manager, or his or her designee, shall create an enrollment form for the Program and such form shall indicate the address to which the form should be returned (along with payment of the applicable fees) to the City via postal mail or in-person submission.
    4. The City Manager, or his or her designee, may authorize alternative methods of enrollment that a prospective employee may opt to use as a substitute for enrollment via return of the paper form referenced in Section 6.3. Such alternative methods of enrollment may include, but are not limited to:
      1. Enrollment via the City’s internet website.
      2. Enrollment via telephone.
      3. Enrollment by submission of a pdf image of the enrollment form via email.
    5. The City Manager, or his or her designee, may authorize alternative methods for payment of required fee. Such alternative methods may include an option for an enrollee to have the fee billed via the utility billing system. If an alternative method involves billing the prospective enrollee, the date of enrollment in the Program for an enrollee who pays via utility billing may be retroactively deemed by the City to be the later of (i) the date on which enrollment was received by the City or (ii) the first day of the membership year.
    6. Existing Enrollees that relocate within the City during a Program Year may transfer their enrollment to their new location. It is the subscriber’s responsibility to notify the Fire Department of any change of address to ensure that that subscription records are accurately maintained.
    7. No refund will be provided if, during a Program Year, an enrollee relocates outside of the City, ceases business operations, reduces the number of Eligible Employees, or otherwise becomes ineligible for enrollment or unlikely to be in need of the City’s emergency medical services.
       
  7. Effect of Participation
    1. The City will waive the out-of-pocket portion of the City’s Emergency Medical Services fees for eligible services.
    2. For purposes of Section 7.1, Emergency Medical Services fees are only those fees that are charged by the City for EMS or paramedic services provided by the City’s Fire Department. Base rates for ambulance transportation and mileage rates for such transportation are not Emergency Medical Services fees for purposes of Section 7.1.
    3. For purposes of Section 7.1, eligible services are services that are provided by the City’s Fire Department to (i) an individual who is part of an enrolled Household, (ii) an Eligible Employee of an enrolled Business so long as the services are provided at the permanent physical location of the Business, or (iii) an enrolled Non-Resident Student. Eligible services do not include services that are provided to guests, visitors, or customers of an Enrollee.
    4. In order to receive the waiver described in Section 7.1, the person who receives the eligible service must (i) provide the City, upon request, with information about any medical insurance (including Medicare Part B) that the person is covered by, (ii) authorize the City to bill that insurance for the Emergency Medical Services fees, and (iii) cooperate with all reasonable requests of the City for the person’s assistance in the City’s efforts to bill that person’s medical insurance.
    5. For purposes of Section 7.1, “waiver of the out-of-pocket portion” of a fee means that the City will not require that the person receiving services pay the portion of the fee that remains unpaid after the City receives payment from any health insurer that covers the person. Where the person receiving services has no medical insurance, the City will waive the entirety of the fee.
       
  8. Enrollee Accountability
    1. A Household that chooses to enroll must identify to the City upon request the members of the Household.
    2. A Business that chooses to enroll must identify to the City upon request the Eligible Employees at the Business location.
    3. Requests for the identification of Household members or of Eligible Employees may be made by the City at the time of enrollment or after enrollment and may be made multiple times with respect to an enrollment year. Such requests may specify specific date(s) for which the information is requested (e.g. “the members of the Household as of November 18, 2028.”).
    4. The City may require that information that is required to be submitted to the City must be provided in a signed statement under penalty of perjury.
    5. The City may revoke the enrollment of any Enrollee that misrepresents the number/identities of the Eligible Employees (if a Business) or Household members (if a Household) or makes a fraudulent claim for a waiver. The subscriber shall be provided with a notice of revocation in writing.
       
  9. Data Privacy and Records Management

    The City employs encryption and secure data storage solutions to protect subscriber data. Data privacy and records management shall be in accordance with all applicable Federal and State laws, as well as City of Fullerton Administrative Policies. 

  10. Program Administration and Disputes
     The City of Fullerton is committed to promptly and fairly resolving any issues arising from the Paramedic Subscription Program. Subscribers who wish to appeal decisions or dispute issues related to the Paramedic Subscription Program may do so under the following process:

    1. Subscribers must submit their disputes or appeals in writing to the Fullerton Fire Department. The submission should clearly state the nature of the dispute, any relevant details, and the desired resolution.
    2. Subscriber disputes or appeals should be addressed to: Fullerton Fire Department (Attention: Paramedic Subscription Program Dispute), 312 East Commonwealth Avenue, Fullerton, California 92832.
    3. Upon receipt, the dispute will undergo an initial review by the designated program coordinator to determine if the issue can be resolved. If the dispute cannot be resolved at this level, it will be escalated to the City Manager.
    4. The City Manager, or designee, retains the authority to interpret these regulations reasonably and resolve any disputes that arise from the implementation of various sections of this resolution.
    5. Responses to disputes or appeals will be sent to the subscriber in writing within 30 days of receipt.