The National Association of EMS Physicians (NAEMSP) strongly opposes the National Registry of Emergency Medical Technicians (NREMT) Resolution on Updated Eligibility Criteria for Initial EMS Education (22-RESOLUTION-13) as written. NAEMSP believes that as the national certifying body for EMS professionals, NREMT has a responsibility to the public to ensure the highest acceptable standards for certification are met. Training program accreditation is a nationally accepted standard for legitimate healthcare professions in the United States that protects learners and the public by ensuring that local clinicians receive an acceptable quality of training. Given that program accreditation and national certification of EMS professionals were highlighted in the EMS Agenda for the Future and EMS Education Agenda, our organization believes that the NREMT should continue to align with best practices highlighted by these nationally recognized guiding documents and maintain their current eligibility requirements for certification. NAEMSP affirms in a 2016 Position Statement (Physician Direction in Emergency Medical Services Education Programs) that the training and education of EMS clinicians explicitly requires the input and oversight of highly engaged EMS Physicians in EMS education programs. This position statement specifically references similar language in the CAAHEP Standards and Guidelines for the Accreditation of Educational Programs in the Emergency Medical Services Professions. It is vital that the current standards explicitly endorse the role of active EMS physician oversight. NAEMSP is concerned that this fundamental pillar of assurance of paramedic competency is not guaranteed within a model of state-specific certification of programs. We are aware of numerous instances of erosion of EMS Physician oversight in state-level EMS activities as a result of the expediency of political decisions. In an environment in which the quantity of EMS clinicians may seem more important than the quality, a political solution would be to diminish the importance of the EMS Physician education oversight as a certification criteria. The nationwide EMS workforce shortage requires that we find ways to bring new clinicians to this career field, including expansion of the numbers of programs to meet the educational needs as well as innovations in how content is delivered. The existing certification process for programs will have to be as responsive as possible to efficiently review applications, while ensuring that minimum existing standards are reliably enforced. However, it should not be subverted by allowing the option of state certification of programs. Submit a public comment on 22-RESOLUTION-13 by August 17, 2022.