HEMS Data Reporting Requirement 

AMOA Response to the Current FAA Proposal

6/28/13

Air medical operators have long supported the establishment of an FAA operational data collection 

requirement. Enhanced collection and reporting of accurate, timely data can further improve the safety of 

air medical operations. However, we believe the process by which that operational data is collected and 

stored must meet the following conditions:

• The data must be useful to both the FAA and to the industry to support our mutual efforts to 

improve aviation safety; it should therefore be collected and reported in a manner that allows for 

meaningful study and analysis of the industry.

• The collection and the reporting of the data should be as minimally burdensome as possible; and

• The FAA must protect, as required by the law, any proprietary information contained in the 

reported data.

Background

Congress enacted the HEMS data collection requirement in Section 306 of the “FAA Modernization and 

Reform Act of 2012”, codified at 49 USC §44731(“the Act”). Given the expected safety benefits to come 

from appropriate collection and analysis of the HEMS data and the need for it to be useful to both the 

HEMS industry and the government, the FAA should implement the data collection reporting requirement 

through a general rulemaking process that allows the opportunity for public comment from the industry 

and other important stakeholders to assure that congressional intent is carried out. We believe the law can 

be implemented without imposing an extraordinary economic burden provided its data elements are 

applied consistent with the operational realities of the air medical sector and its terms are clearly defined. 

We have been advised the FAA has chosen instead a process that will limit the ability of the agency to 

gain the feedback of the public and to best achieve congressional intent. 

We believe the current FAA proposal fails to address both the industry’s goals and the intent of the 

legislation in the following ways:

1. The terms used are undefined and subject to inconsistent implementation and enforcement;

2. The correlation of the various data points is inconsistent with the law and creates a much 

greater economic burden on operators than is required by the law; and

3. It undermines the safety value of the law by failing to require reporting of the data necessary 

to determine the total number of air medical flights and flight hours that will help government 

and industry evaluate the accident rate for air medical operations.

The attached table compares the FAA’s proposal to the specific requirements of the Act, it identifies our 

specific concerns with the FAA’s proposed approach and our recommended method of data collection.

We note here that the FAA’s proposal does not define key terms such as “flight request,” “flight,” and 

“dispatch”. If “flight” is defined to mean - as it is currently defined in the Federal Aviation Regulations -

as originating with a takeoff and ending with the landing, then the flight “requested” according to the 

logic of the definition would only record the leg of the flight transporting the patient. However, a typical

helicopter air ambulance operation, usually involves two or three legs with associated take offs and 

landings.

Collecting the data in this manner, and correlating it in the way the FAA proposes, results in a flight hours 

total that only reflects flights conducted with a patient on board and does not include the total number of 

hours operated by the aircraft. We cannot derive an accident rate, analyze safety trends, or determine risk 

factors in all phases of an air medical flight operation with such limited data.
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Further, the FAA proposal requires operators, who collect a multitude of aviation safety data on their 

aircraft, to collect and separate that data in a manner not required by the Act. This is an added and 

unnecessary burden, especially as this additional data contributes little in terms of safety analysis.

We urge the FAA to collect the data in a way that fully the aggregates the information for purposes of 

public disclosure on an industry basis so as not to disclose proprietary information that can be used to a 

competitive advantage; the objective of this data collection effort is safety, not tracking the commercial 

activities of individual company operations. We fully support data collection efforts that assist industry 

operators, representative organizations, and the FAA in our combined efforts to enhance safety.
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Specific Concerns with Draft FAA Report for Helicopter Air Ambulance (HAA) Data Collection 

The FAA should adhere to the requirements of the HAA data collection statute (49 USC § 44731), 

mindful of its aviation safety purpose, and do so without unduly burdening air medical operators or 

compromising proprietary information. The draft data collection report does not reflect the spirit or actual 

language of the Act. AMOA’s specific concerns are summarized below:

Section 44731 Requirement Draft FAA Data Report Requirement AMOA Proposed Changes

(1) Number of helicopters the 

operator uses to provide HAA 

services and the base locations of 

the helicopters

Goes beyond the law to require 

reporting of each helicopter by 

registration number and its 

corresponding base location. Many 

helicopters are not assigned to a 

specific base; further, the base location 

of HAA helicopters is not static. The 

draft report also interprets the word 

“base” as base location at time of 

“flight activity” and is confusing – does 

this mean location of the helicopter or 

location of the base at each point of 

takeoff? 

The FAA instead should require 

separate reporting of the number 

of helicopters flown and the bases 

used each quarter. Further, a 

requirement to report base 

location should use consistent 

methodology and not allow for 

alternatives based on “best 

judgment.” 

(2) Number of flights and hours 

flown, by registration number,

during which the helicopters were 

providing HAA services [Note that 

this is the only data point in the 

law requiring correlation to 

individual aircraft registration 

numbers]

Goes beyond the law to require 

reporting of this information correlated 

to base location and the other data 

elements. 

The FAA should track the plain 

language of the law to require 

quarterly reporting of the number 

of flights and hours flown by 

registration number. Further and 

to avoid confusion, a “flight” 

should be defined to mean each 

flight segment involving a takeoff 

and landing.

(3) Number of flight requests 

accepted or declined and the type of 

each such flight request.

Goes beyond the law to require a report 

correlating this information to 

registration number, base location, time 

of day, total flight time, IFR time, 

thereby making reporting significantly 

more burdensome. 

The FAA instead should require 

reporting of the number of flight 

requests accepted or declined and 

the type of the request on a 

quarterly basis without a 

correlation to registration 

number, base location and the 

other data elements.

(4) Number of accidents, if any, 

involving the operator’s helicopters 

while providing air ambulance 

services and a description of the 

accidents

Consistent with the law. The definition of “accident” 

should track the NTSB definition 

to assure reporting consistency.

(5) Number of flights and hours 

flown under IFR while providing 

HAA services

Goes beyond the law to require 

reporting of this information correlated 

to registration number, base location, 

time of day, total flight time. 

The FAA instead should require 

the number of flights and hours 

flown IFR on a quarterly basis 

without a correlation to 

registration number and base 

location and the other data points.

(6) Time of day of each flight flown 

while providing HAA services

Goes beyond the law to require 

reporting of this information correlated 

to registration number and base location 

and the other data points. Further, the 

draft report interprets this data point to 

mean “time of day at dispatch” but 

“dispatch”, a misnomer, would be the 

time a third party makes a call for HAA 

The FAA instead should consider 

defining time of day to be 

consistent with the regulations 

defining “day” and “night”.
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services, not the time of day the flight 

takes off -- what the law appears to call 

for. The FAA also should be aware that 

this data element alone is likely to result 

in over 100,000 reports on a quarterly 

basis just for AMOA members. How 

will a spreadsheet along the lines of the 

draft report accommodate this number? 

(7) The number of incidents, if any, 

in which a helicopter was not 

directly dispatched and arrived but 

not utilized for patient transport

Goes beyond the law to require 

reporting of this information correlated 

to registration number, base location 

and the other data points. 

There is no evidence that any 

such incidents ever take place, 

but to comply with the plain 

language of the law, the FAA 

instead should require reporting 

of any such incidents each quarter 

without requiring a correlation to 

registration number, base 

location, IFR time, time of day.