Overall Economic Direction (2020→2024)

Net expansion of economic freedom for RNs/EMS; expected modest ↑ growth via staffing flexibility and faster clinical decision-making, with manageable compliance costs.

Wisconsin Nursing Regulation — Year-to-Year RN Impact Report

Comparing 2020 vs 2024; showing only entries where impacts_registered_nurses = true.

Economic frame

  • Freedom & contestability: Broader substitution in EMS, wider sources of on-line consultation, and RN discretion in labor induction expand choice sets and reduce bottlenecks. Removal of some staffing mandates increases managerial flexibility.
  • Compliance burden & fixed costs: Added CPR documentation and arrest/conviction reporting are light but ongoing; FSEDs face a binding staffing floor (emergency-specialized RN) that raises fixed costs.
  • Innovation/diffusion (telehealth, EMS integration, skill mix): Opening medical direction to PAs/APNPs supports distributed/tele-consult models and team-based care; substitution rules enable more adaptive EMS crew composition.
  • Labor supply & matching: Greater ability to deploy RNs across EMS/prenatal settings improves matching, especially in rural markets; FSED requirement may tighten local RN labor supply.
  • Risk/quality externalities (scarcity, moral hazard): Reporting requirements and medical director approval partially internalize quality risks; removal of explicit staffing minima warrants outcome monitoring.

Net assessment

Classified as net expansion of freedom/growth. Main adjustments: task reallocation toward top-of-license practice, faster consultations, and more elastic EMS staffing; modest new compliance for safety/quality.

Back-of-the-envelope channels

  • Entry/exit & capacity: Directionally ↑ for EMS and rural units; potential ↓ margin for small FSED entrants due to staffing floor.
  • Productivity: Likely ↑ from reduced delays (on-line consultation), improved crew formation, and fewer prescriptive staffing constraints.
  • Compliance cost: Ongoing light costs for documentation/reporting; substantial ongoing labor cost for FSED RN specialization.

Policy notes

  • Sunset/measurement: Track EMS response times, canceled runs for staffing, consultation wait times, OB induction adverse events, ED/FSED coverage, wage/price dispersion, rural access.
  • Targeted alternatives: Prefer competency- and audit-based oversight (random CPR audits, risk-based reporting thresholds) over blanket staffing rules; use outcome-based triggers in maternity and FSED standards.

Agency DHS, Chapter 110

2020: wisconsin/2020-04-14/clean/DHS/110.txt2024: wisconsin/2024-07-18/clean/DHS/110.txt

Compared to 2020, the 2024 rule adds reporting and CPR documentation requirements for all “EMS professionals,” a term that includes registered nurses when they function in EMS settings. It also broadens who may provide on-line medical consultation to include PAs and APNPs. Finally, RNs may now substitute for emergency medical responders as well as EMS practitioners on EMS crews if trained, competent, and approved.

2024 adds new EMS professional duties: maintain CPR documentation throughout the license period and report arrests within 7 days and convictions within 48 hours. These apply to RNs when functioning as EMS professionals.

additionrecordkeeping_or_reporting, disciplinary_actionsRN ImpactConfidence: high
RN rationale: “EMS professional” expressly includes registered nurses; thus, the new documentation and reporting duties apply to RNs when acting in EMS roles under DHS 110.
  • Maintain documentation of current CPR course at the healthcare professional level throughout the triennial period while functioning as an EMS professional.
  • Notify DHS within seven days of any arrest substantially related to EMS practice.
  • Notify DHS in writing within 48 hours of any felony or misdemeanor conviction and provide the judgment and complaint/details.
Evidence
2020 DHS 110.13(1)-(5)
An EMS professional shall maintain a current credential ... An EMS professional shall notify the department of any change in his or her name, address, or other information ...
2024 DHS 110.13(4m)
An EMS professional shall demonstrate current competencies in CPR at the healthcare professional level by maintaining documentation of successful completion of a CPR course … throughout the triennial license period.
2020 DHS 110.04(24)
EMS professional or EMS personnel means a certified first responder, licensed emergency medical technician, registered nurse, physician assistant or physician, who is authorized to provide emergency medical care.
2024 DHS 110.13(6)
An EMS professional shall notify the department within seven days of any arrest for violation of any law substantially related to the practice of emergency medical services.
2024 DHS 110.13(7)
An EMS professional shall notify the department of a felony or misdemeanor conviction in writing within 48 hours after the entry of the judgement of conviction…
2024 DHS 110.04(24)
EMS professional means a certified emergency medical responder, licensed emergency medical services practitioner, registered nurse, physician assistant or physician…

2024 expands who can provide on-line medical direction to EMS professionals to include physician assistants and advanced practice nurse practitioners, not only physicians.

modificationscope_of_practice, supervision_or_collaborationRN ImpactConfidence: high
RN rationale: RNs functioning as EMS professionals receive on-line medical consultation; the expansion changes who may lawfully provide their medical direction.
  • May receive on-line medical consultation/orders from a physician assistant or advanced practice nurse practitioner (within that clinician’s scope/credentials), in addition to physicians.
Evidence
2020 DHS 110.04(49) (2020 numbering)
On line medical control means direct voice contact between a physician at the medical control hospital and EMS professionals for the purpose of medical direction.
2024 DHS 110.04(49)
On-line medical consultation means direct contact between a medical consultation physician or physician assistant or advanced practice nurse practitioner and EMS professionals…

2024 broadens substitution authority so a physician, PA, or RN may take the place of any emergency medical responder or EMS practitioner, not just EMTs.

modificationscope_of_practice, supervision_or_collaborationRN ImpactConfidence: medium
RN rationale: RNs can now be counted in place of EMRs as well as EMS practitioners on EMS crews if trained/competent and approved by the service medical director.
  • May fill staffing slots for an emergency medical responder or EMS practitioner at any service level if trained/competent in that level’s skills and approved by the service medical director.
  • May not practice above the level at which the service is licensed.
Evidence
2020 DHS 110.50(2)
A physician, physician assistant or a registered nurse may take the place of any EMT at any service level provided he or she is trained and competent… and provided he or she is approved by the service medical director.
2024 DHS 110.50(2)
A physician, physician assistant or a registered nurse may take the place of any emergency medical responder or emergency medical services practitioner at any service level… and provided he or she is approved by the service medical director.

Agency DHS, Chapter 124

2020: wisconsin/2020-04-14/clean/DHS/124.txt2024: wisconsin/2024-07-18/clean/DHS/124.txt

Key RN-impacting changes include expanded RN authority to discontinue labor‑inducing medications by hospital policy (without standing orders), deletion of the explicit circulating RN requirement at every delivery, and a new requirement that freestanding emergency departments have an RN specialized in emergency nursing on‑site at all times. Additionally, the repeal of the state’s CAH requirements removed the explicit 24/7 RN availability mandate at the state level.

Hospitals’ policies for labor‑inducing medications now allow an RN to discontinue the medication when warranted even if no standing orders exist, whereas 2020 required standing orders to authorize RN discontinuation.

modificationscope_of_practice, supervision_or_collaborationRN ImpactConfidence: high
RN rationale: Expands RN authority and responsibility during induction by permitting policy‑based discontinuation without prescriber standing orders; RNs must still be present at initiation and monitor mother/fetus.
  • Be present when administration of a labor‑inducing medication is initiated and remain immediately available to monitor maternal and fetal well‑being.
  • May discontinue a labor‑inducing medication per hospital policy if circumstances warrant, even when no standing orders authorize discontinuation.
Evidence
2020 DHS 124.20(5)(i)8.c
A registered nurse shall be present when administration of a labor inducing agent is initiated and shall remain immediately available to monitor maternal and fetal well being. A physician’s or licensed nurse midwife’s standing orders shall exist allowing the registered nurse to discontinue the labor inducing agent if circumstances warrant discontinuation.
2024 DHS 124.07(8)(c)
Hospitals shall develop and implement policies allowing the registered nurse to discontinue the labor-inducing medication if circumstances warrant discontinuation and no standing orders by a physician or a nurse-midwife are in place authorizing their discontinuation.

The explicit requirement that a circulating nurse (RN) be present at every infant delivery is not included in the updated maternity standards.

deletionsupervision_or_collaboration, scope_of_practiceRN ImpactConfidence: medium
RN rationale: Removes a specific RN staffing mandate in delivery rooms, potentially affecting RN assignment requirements for births.
  • Removed: Mandatory RN role as circulating nurse at every infant delivery.
Evidence
2020 DHS 124.13(7)(b)
There shall be a circulating nurse at every infant delivery.
2024 DHS 124.07(5)
Delivery rooms shall be used only for delivery and operating procedures related to deliveries unless permitted by a written safety risk assessment that facilitates safe delivery of care.

New freestanding emergency department (FSED) standards require on‑site staffing to include at least one RN specialized in emergency nursing at all times.

additionscope_of_practice, otherRN ImpactConfidence: high
RN rationale: Creates a new practice setting with a minimum on‑site RN qualification—specialization in emergency nursing—which affects hiring and staffing of RNs at FSEDs.
  • At freestanding emergency departments, at least one RN specializing in emergency nursing must be on‑site at all times.
Evidence
2024 DHS 124.09(4)(a)2
One registered nurse, who through education, training, and experience specializes in emergency nursing.

State rule DHS 124.40 (Critical Access Hospitals) was repealed; 2020 explicitly required CAHs to have RNs available on a 24‑hour basis.

deletionsupervision_or_collaboration, otherRN ImpactConfidence: medium
Effective date: effective 7-1-20
RN rationale: Removes an explicit state‑level requirement for 24/7 RN availability in CAHs; RN staffing obligations may now rely on federal COPs and hospital policy.
  • Removed (state rule): CAHs shall have registered nurses available on a 24‑hour basis.
Evidence
2020 DHS 124.40(5)(a)
…shall have registered nurses available on a 24 hour basis as required by s. DHS 124.13(1)(a).
2024 DHS 124.39(3)(b) Note
Section DHS 124.40 was repealed by CR 19-135, effective 7-1-20. This provision will be treated in future rulemaking.