Number
221212
Version
SUBSTITUTE 1
Reference
Sponsor
ALD. BORKOWSKI
Title
Substitute ordinance relating to various revisions to ambulance certification regulations.
Section
75-15-1 rc
75-15-2-a-7 am
75-15-2-b-1 am
75-15-3 am
75-15-4-a am
75-15-10 am
75-15-11-a am
75-15-11-b am
75-15-11-c ra
75-15-11-c cr
75-15-12-e cr
75-15-12-f cr
75-15-13-c rn
75-15-13-c cr
75-15-14-c-1 am
75-15-14-c-2 am
75-15-14-c-3 am
75-15-15-a-1 am
75-15-15-a-2 am
75-15-15-a-3 am
75-15-15-a-4 am
75-15-15-a-5 am
75-15-15-a-6 am
75-15-15-a-7 am
75-15-15-a-8 am
75-15-15-a-9 am
75-15-17-a-1 am
75-15-17-a-2 am
75-15-17-a-3 am
75-15-17-a-4 am
75-15-17-b-1 am
75-15-17-b-2 am
75-15-17-b-3 am
75-15-17-b-4 am
75-15-17-c-1 am
75-15-17-c-2 am
75-15-17-c-3 am
75-15-17-c-4 am
75-15-17-c-5 am
75-15-17-c-6 am
75-15-17-d-1 am
75-15-17-d-2 am
75-15-17-d-3 am
75-15-17-e-1 am
75-15-17-e-2 am
75-15-17-e-3 am
75-15-17-e-4 am
75-15-17-e-5 am
75-15-17-e-6 am
75-15-17-e-7 am
75-15-17-e-8 am
75-15-17-e-9 am
75-15-17-e-10 am
75-15-17-e-11 am
75-15-17-e-12 am
75-15-17-e-13 am
75-15-17-f-2 am
75-15-17-f-3 am
75-15-19-a-0 am
75-15-19-a-7 cr
75-15-19-b-1 am
75-15-19-b-3 am
75-15-19-b-4 am
75-15-19-c am
75-15-21 am
75-15-24 cr
75-15-25 cr
75-15-26 cr
75-15-27 cr
Analysis
This ordinance makes various revisions to terminology used for ambulance certification regulations, updates rate for ambulance supplies and services, and creates a requirement for providers to obtain approval from the fire department for special event plans.
Body
The Mayor and Common Council of the City of Milwaukee do ordain as follows:
Part 1. Section 75-15-1 of the code is repealed and recreated to read:
75-15. Ambulance Certification Regulations.
1. DEFINITIONS. In this section:
a. “Advanced life support” (“ALS”) means advanced life support as defined in s. DHS 110.04(1r), Wis. Adm. Code.
b. “Agreement” means the ambulance service standards agreement identified in sub. 2-b-2.
c. “Ambulance” means a certified emergency vehicle used to transport sick, disabled or injured individuals as defined in s. DHS 110.04(4), Wis. Adm. Code and s. 340.01(3)(i), Wis. Stats.
d. “Ambulance rate” means the base fee for ambulance conveyance which cannot be exceeded by certified providers on city authorized dispatch.
e. “Basic life support” (“BLS”) means basic life support as defined in s. 256.15(1)(d), Wis. Stats.
f. “Board” means the ambulance service board.
g. “Certified provider” means a provider from the private sector that applied for and obtained a certificate to supply care within the Milwaukee emergency medical services system as a certified provider within a defined service area.
h. “Committee” means the committee designated by the common council as responsible for ambulance service regulations.
i. “Emergency medical care” means medical care to sick, disabled, or injured individuals at the scene of an emergency, during transport to a hospital, while in the hospital emergency department until responsibility for care is assumed by the regular hospital staff, or during transfer of a patient between health care facilities, which is based on state-approved patient care protocols, as defined in s. DHS 110.04(21), Wis. Adm. Code.
j. “Emergency medical services” (EMS) means those services which are required as a result of an unforeseen attack of illness or an injury. These include rescue, ambulance, hospital emergency departments, communications and public education services.
k. “EMT” means emergency medical technician as defined in s. DHS 110.04(27), Wis. Adm. Code.
L. “Fire department” means the city of Milwaukee fire department.
m. “Incident” means each event that causes MFD dispatch, through its usual procedures to refer a request for ambulance transport service to a certified provider, by telephone or other electronic means.
n. “Limited certified provider” means a provider from the private sector that holds a certificate to supply care within the Milwaukee emergency medical services system as a certified provider without a defined primary service area and which can respond to incidents as assigned or dispatched.
o. “Milwaukee emergency medical services system” means a system composed of fire department personnel and equipment, and private sector personnel and equipment, for the purpose of providing advanced life support and basic life support responses, treatment and conveyances within city limits.
p. “Milwaukee fire department dispatch” (“MFD dispatch”) means the dispatch center operated by the department of emergency communications at any location for receiving and dispatching all calls for emergency medical assistance.
q. “Non-transporting EMS provider” means an emergency medical service provider that provides emergency medical care with staff licensed as EMS practitioners to sick, disabled or injured individuals, but that does not transport patients as prescribed in s. DHS 110.04(47), Wis. Adm. Code.
r. “Paramedic” means an EMS provider licensed in the state of Wisconsin as a paramedic as defined in s. DHS 110.04(51m), Wis. Adm. Code and s. 256.01(14), Wis.Stats.
s. “Primary service area” means the geographical area in which an ambulance service provider is designated to provide first-in EMS under contract with a local government, as defined in s. DHS 110.04(60), Wis. Adm. Code. “Primary service area” does not include an area a provider services through mutual aid or back-up arrangements.
t. “Private sector” means any person, firm, partnership or corporation within the city providing ambulance services on a fee-for-service basis.
u. “Service area” means a geographically-defined area within the city assigned in accordance with sub. 13.
v. “Special event plan” means a written document in a format approved by the Milwaukee county office of emergency management - emergency medical services, specifically addressing all of the items listed in s. DHS 110.44, Wis. Adm. Code.
Part 2. Section 75-15-2-a-7 of the code is amended to read:
2. AMBULANCE SERVICE BOARD.
a. Establishment.
a-7. Designee of the Milwaukee county [[medical society EMS committee]] >>office of emergency operations emergency medical services division<< by action of the committee, who shall not be a current medical director of a provider.
Part 3. Section 75-15-2-b-1 of the code is amended to read:
b. Duties.
b-1. The board shall advise the committee on all matters pertaining to issuance, renewal, suspension, revocation and reinstatement of certified, >>limited and non-transporting<< provider certificates, and shall, consistent with sub. 13, assist in the development and modification of service plans.
Part 4. Section 75-15-3 of the code is amended to read:
3. CERTIFICATION. No one from the private sector shall within the city act as a certified >>, limited, or non-transporting<< provider within the Milwaukee emergency medical services system without first having obtained a certificate as provided under this section. This section applies only to private sector providers supplying [[services to]] >>care that originates within the city of Milwaukee, or that integrates into<< the city of Milwaukee emergency medical services system.
Part 5. Section 75-15-4-a of the code is amended to read:
4. APPLICATION FOR CERTIFICATION AS CERTIFIED PROVIER AND SERVICE AREA.
a. Applications for certificates as a certified provider >>, a limited certified provider, or a non-transporting provider<< under this section shall be filed with the [[health]] >>fire<< department on forms approved by the committee. The board and the committee are authorized to require sufficient information to determine the qualifications of the applicate to engage in the business of providing basic life support and advanced life support ambulance conveyances to the Milwaukee emergency medical services system. The application signed in proper form shall be presented to the common council for referral to the committee for its recommendation.
Part 6. Section 75-15-10 of the code is amended to read:
10. INSPECTION. No ambulance shall be granted a permit to operate under the terms of this section until it has been inspected and found to be in a thoroughly safe condition for the transportation of the sick and injured. The inspection shall be made by the Wisconsin department of transportation, division of state patrol, which shall determine that the ambulance complies with all the requirements set forth in [[s. 46.50 , Wis. Stats.]] >>ch. Trans 309, Wis. Admin. Code.<< Verification of the inspection shall be provided to the board at the annual certification hearing.
Part 7. Section 75-15-11-a and b of the code is amended to read:
11. FINANCIAL RESPONSIBILITY.
a. >>Insurance Requirement.<< A certified >>, limited, or non-transporting<< provider shall furnish the city with a certificate of insurance, issued by a company authorized to do business in the state of Wisconsin, confirming that the certified provider has been issued a current policy insuring the provider against loss or damage that may result to any person or property, the policy of insurance to be in the limits of $1,000,000 for any one person injured or killed, $3,000,000 for all persons injured or killed in case of one accident resulting in bodily injury or death of more than one person, and $3,000,000 for injury or destruction to the property of others in the case of accident. The policy shall guarantee payment of any final judgement rendered against the provider within the limits provided in this paragraph irrespective of the financial responsibility or any act of omission of the certified provider. The city of Milwaukee shall be named as an additional insured.
b. Cancellation. All certificates shall be executed by an insurance company licensed to do business in the state of Wisconsin. All certificates shall be approved as to form and execution by the city attorney before they are accepted by the [[health]] >>fire<< department, and shall contain a provision or endorsement by which the insurance carrier shall be required to notify the fire department by registered mail or personal service of the cancellation of the insurance policy. Notice of cancellation shall be received by the fire department at least 30 days prior to the effective date of cancellation. If at any time the policy of insurance is cancelled by the issuing company, or the authority of the issuing company to do business in the state of Wisconsin is revoked, the fire chief shall require the certified provider to replace the policy with another policy satisfactory to the chief, and in default thereof the certified provider’s certificate issued under this section [[shall]] >>may<< be suspended until proof of valid policy is presented by a certified provider. >>Suspension shall be at the discretion of the board and effectuated by vote of the common council.<<
Part 8. Section 75-15-11-c of the code is renumbered 75-15-11-d and amended to read:
d. Exceptions. Private sector providers [[,]]>>who are<< not participating within the city emergency medical services system, >>and who are providing transport services that terminate, but do not originate, within the city of Milwaukee,<< need not file the insurance required herein. >>This exception also applies to private sector providers providing emergency medical care within the city of Milwaukee as a form of mutual aid or back-up.<<
Part 9. Section 75-15-11-c of the code is created to read:
11. FINANCIAL RESPONSIBILITY.
c. Transporting and non-transporting private sector providers furnishing care for specials events or private facilities shall assume the same financial responsibility as private providers participating in the 911-based EMS system.
Part 10. Section 75-15-12-e and f of the code is created to read:
12. REQUIREMENTS.
e. Utilize the incident command system for all special events, mass casualty incidents, and major incidents.
f. Maintain an annual subscription to and utilize the fire department approved secure EMS electronic incident surveillance system for all special events which may require the provider to be dispatched by the public safety access point operated by the city.
Part 11. Section 75-15-13-c of the code is renumbered 75-15-13-d.
Part 12. Section 75-15-13-c of the code is created to read:
13. SERVICE AREAS.
c. Subcontracting of Service Areas. To ensure the equitable and effective distribution of EMS services, a certified provider may subcontract with a provider with limited certification to provide supplemental services within the certified provider’s area. The conditions of subcontracting agreements shall be presented to the fire department for approval and integration in the CAD system to minimize system disruption and inappropriate dispatching of resources.
Part 13. Section 75-15-14-c-1 to 3 of the code is amended to read:
14. DETERMINING RATES BILLED BY PRIVATE SECTOR PROVIDERS.
c.
c-1. For patients who are residents of the city of Milwaukee, for basic life support, [[$740]] >>$778.92<< and, for basic life support-lights-and-sirens response, [[$740]] >>$778.92<<. When patients require treatment without transport, a [[$237]] >>$249.47<< basic life support non-transport fee shall apply.
c-2. For patients who are not residents of the city of Milwaukee, for basic life support, [[$856]] >>$901.03<< and, for basic life [[support-emergency]] >>support-lights-and-sirens response<<, [[$856]] >>$901.03<<. When patients require treatment without transport, a [[$341]] >>$358.94<< basic life support non-transport fee shall apply.
c-3. In addition to the charges provided in subds. c-1 and 2, a charge of [[$20.14]] >>$21.20<< per mile shall be assessed for mileage, mileage to be defined as the distance traveled with the patient in the ambulance from the point of patient origin to destination.
Part 14. Section 75-15-15-a-1 to 9 of the code is amended to read:
15. BASIC LIFE SUPPORT ANCILLARY CHARGES BILLED BY PRIVATE SECTOR PROVIDERS. Pursuant to sub. 12-d, certified providers are authorized to charge the following:
a. Ancillary charges.
a-1. Airway supplies: [[$27.07]] >>$28.49<<.
a-2. Ventilation and CPR supplies: [[$396.68]] >>$417.55<<.
a-3. Bandaging and Trauma Treatment supplies: [[$23.05]] >>$24.26<<.
a-4. Personal Protection Equipment supplies: [[$35.00]] >>$36.84<<.
a-5. Obstetrics and Child Delivery supplies: [[$245.21]] >>$258.11<<.
a-6. Splinting and Immobilization supplies: [[$496.98]] >>$523.12<<.
a-7. Oxygen Therapy and supplies: [[$106.63]] >>$112.24<<.
a-8. BLS supplies (COVID decontamination or other routine supplies) [[$35.00]] >>: $36.84<<.
a-9. CPAP Mask supplies: [[$56.85]] >>$59.84<<.
Part 15. Section 75-15-17-a-1 to 4, b-1 to 4, c-1 to 6, d-1 to 3, e-1 to 13, and f-2 and 3 of the code is amended to read:
17. CHARGES FOR PATIENT SERVICES DELIVERED BY THE FIRE DEPARTMENT.
a.
a-1. Paramedic non-invasive service or treatment without conveyance: [[284.24]] >>$299.19<<.
a-2. Paramedic invasive service or treatment without conveyance: [[284.24]] >>$299.19<<.
a-3. Paramedic service with transport Level ALS-1: [[$879.89]] >>$926.17<<.
a-4. Paramedic service with transport Level ALS-2: [[$967.67]]>>$1018.57<<.
b.
b-1. Paramedic non-invasive service or treatment without conveyance: [[$400.24]] >>$421.29<<.
b-2. Paramedic invasive service or treatment without conveyance: [[$400.24]] >>$421.29<<.
b-3. Paramedic service with transport Level ALS-1: [[$991.71]] >>$1043.87<<.
b-4. Paramedic service with transport Level ALS-2: [[$1141.14]] >>$1201.16<<.
c.
c-1. ALS supplies: [[$100.36]] >>$105.64<<.
c-2. Intubation supplies: [[$184.66]] >>$194.37<<.
c-3. I.V. and supplies: [[$75.89]] >>$79.88<<.
c-4. Defibrillation supplies: [[$225.73]] >>$237.60<<.
c-5. EKG and supplies: [[$194.38]] >>$204.60<<.
c-6. Oxygen and supplies: [[$106.63]] >>$112.24<<.
d.
d-1. Items approved in Drugs, Group 1: Acetaminophen (1000 mg tablet & 160 mg/5 mL Liquid), Albuterol (2.5mg)/Ipratropium (0.5mg)/3 mL (.83%), Amioderone HCI (150mg), Aspirin (chewable 81 mg), Atropine Sulfate (0.3 mg), Calcium Gluconate (10 ml), Dextrose 10% (D10), Dextrose 5% (D5), Duoneb, IV-D5W, Glucose (oral gel 15 g), IV-Sodium Normal Saline (bags & capped), Ondansetron Tabs, Ondansetron IV/IO, shall be charged a rate of [[$40.78]] >>$42.93<<.
d-2. Items approved in Drugs, Group 2: Diphenhydramine 50 mg, Dopamine, EPL 1 mg/10 mL IV, EPI 1 mg/cc IV, Lidocaine Drip 1 gm/25 mL, Lidocaine HCI (2%) 50 mg, Sodium Bicarbonate (50 CC), shall be charged a rate of [[$46.95]] >>$49.42<<.
d-3. Items approved in Drugs, Group 3: Fentanyl, Ketamine (Pediatric) Infusion, Ketorolac 30 mg/1 mL, Midazolam HCI 1 mg, Nitroglycerine Spray 0.4 mg IV, Norepinephrine 4 mg/4mL, shall be charged a rate of [[$60.55]] >>$63.73<<.
e.
e-1. Adenosine: [[$113.69]] >>$119.67<<.
e-2. Glucagon, up to 1 mg: [[$113.69]] >>$119.67<<.
e-3. Dexamethasone20mg/5mL: [[$74.15]] >>$78.05<<.
e-4. E-Z IO: [[$152.01]] >>$160.01.<<
e-5. Patient ID & Tracking: [[$3.97]] >>$4.18<<.
e-6. Hydroxocobalamin(Cyano-kit): [[$1141.81]] >>$1201.90<<.
e-7. CPAP mask supplies: [[$56.85]] >>$59.84<<.
e-8. Airway Supplies: [[$27.07]] >>$28.49<<.
e-9. Ventilation and CPR Supplies: [[$396.68]] >>$417.55<<.
e-10. Bandaging and Trauma Supplies: [[23.05]] >>$24.26<<.
e-11. Personal Protective Supplies: [[$35.00]] >>$36.84<<.
e-12. Obstetrics and Child Delivery Supplies: [[$245.21]] >>$258.11<<.
e-13. Splinting and Immobilization Supplies: [[$496.98]] >>$523.12<<.
f.
f-2. When the fire department Heavy Urban Rescue Team is required to alter a structure, the department is authorized to charge a supplemental charge of [[$600]] >>$631.56<< to cover the costs of supplemental materials and equipment.
f-3. When the [[licensed provider]] >>fire department<< is dispatched to >>assist a licensed provider at the request of<< a commercial property or a skilled nursing facility to perform a lift assist for a patient not requiring transport, the department is authorized to charge the rate outlined in sub. 14-c-1 or 14-c-2 as appropriate to the facility>> or firm<<.
Part 16. Section 75-15-19-a-0 of the code is amended to read:
19. VIOLATIONS a. Suspension and Revocation. The common council may, subsequent to a hearing conducted by the committee, suspend, revoke, deny>>, not renew or place other limitations on<< [[or not renew]] a certificate issued under this section for any reasonable cause which shall be in the best interests and good order of the city, including, but not limited to, the following findings:
Part 17. Section 75-15-19-a-7 of the code is created to read:
>>a-7 In the case of a limited provider or a non-transporting EMS provider, where the committee, on hearing evidence, determines the provider has failed to follow a special event plan, any standard set forth by DHS, or any of the other requirements in this ordinance or has substantially underperformed in its responsibility to provide care or transport, the common council may suspend, revoke, deny, not renew, or place limitations or restrictions on the certificate issued under this section on the provider’s ability to supply care within the Milwaukee emergency medical services system as a service provider which shall be appropriate under the circumstances.<<
Part 18. Section 75-15-19-b-1, 3, 4, and c of the code is amended to read:
b. Hearing.
b-1. Whenever the committee has scheduled a hearing for determining whether to recommend suspension>>, revocation or limitation<< [[or revocation]] of a certified provider's certificate, the certified provider shall receive written notice of the hearing not less than 10 days prior to the hearing. The notice shall specify the nature of the complaint against the certified provider.
b-3. At the conclusion of the hearing, the committee shall make its recommendation to
the common council. If the recommendation is to suspend>>, revoke or limit<< [[or revoke]] a certified provider’s certificate, each member of the committee voting in favor of the action shall state the basis therefore on the record.
b-4. The certified provider shall be provided with written notice of any recommendation of the committee. If the recommendation is to suspend>>,revoke or limit<< [[or revoke]] the certified provider’s certificate, the provider may, within 10 days of the notice, appeal the recommendation by filing written notice with the city clerk. If notice of appeal is filed, a copy of the transcript of the hearing shall be provided to each common council member at least 3 days prior to the common council vote on whether to accept or reject the recommendation of the committee.
c. Penalty. Anyone who acts as a certified provider without having obtained a certificate to do so, or who violates any other part of this section, shall upon conviction be subject to a forfeiture of not less than [[$100 nor more than $250]] >>$25,000,<< and in default of payment, be committed to the county jail or house of correction for a period of time not to exceed 10 days. Each day in which any person shall operate as a certified provider without having obtained a certificate, or after revocation of the same, shall constitute a separate offense.
Part 19. Section 75-15-21 of the code is amended to read:
21. HIGH UTILIZERS. City of Milwaukee residents, identified through the quality control process of the fire department, private provider, or a healthcare partner, whose usage of the EMS system [[falls at or above the 95th percentile]] >>exceeds 5 calls in a 12-month period<< shall be enrolled in a program to assess the needs of the individual and identify ways to monitor and improve the individual’s personal health in an effort to reduce the individual’s utilization of the EMS system. Evaluation and intervention [[shall]] >>may<< include members of medical direction, the applicable hospital systems represented in sub. 2-a-6 >>or recognized independent clinics<<, and the personal physician >>, primary care provider or appropriate specialist<< of the indicated patient, with discussions and plans to be held in private to protect the individual’s privacy. The fire department may utilize resources within its mobile integrated health system and the health department to facilitate positive outcomes for these patients.
Part 20. Section 75-15-24 to 277 of the code is created to read:
24. SPECIAL EVENT PLANS. a. Any provider providing services for a special event shall submit a written plan approved by Milwaukee county office of emergency management - emergency medical services containing, at a minimum, the items described in s. DHS 110.44, Wis. Adm. Code.
b. In the event a 911 caller requests EMS from an approved special event during the scheduled dates and times, the approved special event provider, and not the assigned service area provider, shall be dispatched. If the special event provider’s ambulance is not available or not on the scene, a response commensurate with the caller’s request shall be dispatched by the provider assigned to the service area.
c. The plan for an event with total projected attendance exceeding 5,000 people shall include a mass casualty plan approved by the fire department and sufficiently address the items listed in s. DHS 110.44(20r), Wis. Adm. Code.
d. A provider providing service for a special event shall have an approved plan to integrate its service into the 911 dispatch service of the city of Milwaukee.
e. Unless specifically waived, all BLS and ALS service provided at a special event shall be in accordance with Milwaukee county office of emergency management emergency medical services standards of care.
f. A provider shall not charge more than the city-approved rates for any emergency medical care provided to an attendee at a special event within the city that falls within the Milwaukee county office of emergency management emergency medical services standards of care.
g. A special event plan for a multiday event, or a sporting event, shall not exceed 90 calendar days or the normal season for a given single sport, whichever is greater. A blanket plan covering multiple sports, separate events or geographic locations substantially removed from each other shall not be considered.
h. A limited or non-transporting certified provider not providing a 911-based response system shall pay to the fire department a fee of $200 to review and approve each special event plan. The fee shall also cover temporary modifications to the computer-aided dispatch system for routing calls and notifying appropriate agencies as noted in s. DHS 110.44(15) and (16), Wis. Adm. Code.
i. Class AA, A, and B events as defined in s. 105.55.5, Wis Stats., serviced by non-transporting or limited certification providers shall incur fees from the department of emergency communication for routing calls and integrating the provider into the city’s incident command system in compliance with s. DHS 110.44(15), Wis. Adm. Code, and providing emergency incident support to appropriate agencies as noted in S. DHS 110.44(15) and (16), Wis. Adm. Code.
i. In the event of a mass casualty incident, the provider shall immediately notify the fire department via dispatch and shall fold into the incident command system under the department, should circumstances dictate.
k. Any provider not receiving approval from the fire department shall be considered as not having met the requirements of s. DHS 110.44(10), (14), (17) and (20), Wis. Adm. Code.
25. TARGET HAZARDS. A private provider furnishing non-911-based services for skilled care medical facilities shall complete the limited certification process set forth in sub. 4.
26. ADVERTISING. a. A provider shall submit all forms of proposed advertising, for clinical care or transport, to the general public to the fire chief for review prior to the advertising being disseminated in any form. The review is for the purpose of ensuring that the communication has no adverse impact upon the substantial interests of the EMS system. If the fire chief makes an adverse finding, he or she shall immediately advise the provider and work with the provider to develop an unobjectionable alternative.
b. All of a provider’s advertising and marketing materials directed to the general public for clinical care or transport shall state: “In case of emergency, call 911.” If the provider places a telephone number on the exterior of an ambulance, the words, “In case of emergency, call 911” shall also appear.
27. DISPUTE RESOLUTION FOR PRIVATE PROVIDER AGREEMENT. In the event a certified provider and the fire department are unable to resolve a dispute regarding an alleged breach of the terms of the agreement, the common council shall, subsequent to a hearing conducted by the committee on hearing the evidence, make a determination and issue any remedies allowed under the agreement. The determination shall be considered a final, appealable determination.
LRB
APPROVED AS TO FORM
____________________________
Legislative Reference Bureau
Date: ______________________
Attorney
IT IS OUR OPINION THAT THE ORDINANCE
IS LEGAL AND ENFORCEABLE
____________________________
Office of the City Attorney
Date: ______________________
Requestor
Fire Department
Drafter
LRB177323-1
Gunnar Raasch
3/3/22
TECHNICAL CORRECTIONS -- JAMES R. OWCZARSKI -- MARCH 27, 29, and 30, 2023