By Adam Pagnucco.
A ghost of Christmas past, the ambulance fee, has returned to haunt Montgomery County government. In a story I recently retold, the county passed an ambulance fee (now known as the EMST fee) in 2012 and agreed to share a portion of the proceeds with the county’s volunteer fire services. The Montgomery County Volunteer Fire and Rescue Association (MCVFRA), an association that represents the volunteer fire departments, recently got into financial problems in part by using ambulance fees it received for general expenses rather than allowable restricted purposes. The Office of Inspector General (OIG) then issued two reports, one finding that the county did not adequately track use of the fees and another finding that the association was ineligible under county law to receive them. The OIG even called on the county to recover the money paid to the association.
Now MCVFRA is firing back. While acknowledging many of the OIG’s findings, the association disputes the OIG’s assertion that it is ineligible to receive ambulance fee money. The association states:
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County law requires that a portion of EMST revenue be allocated “for the benefit of local fire and rescue departments.” The law does not state that funds may only be paid directly to individual departments, nor does it prohibit the use of a representative or system-level entity to deliver services that benefit departments collectively. For more than a decade, the County implemented the statute consistent with this understanding, through a transparent, multi-layered process that included review by the MCVFRA funding committee, approval by the MCVFRA Board, approval by the Fire Chief, and incorporation into County budget actions subject to County Council oversight.
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This is not a small issue. If the OIG is correct, the association may not be able to collect ambulance fees going forward, jeopardizing its solvency unless county law is amended. If the association is correct, it still has some cleanup to do on its past use of fees but it has a path forward to improving its finances. At stake is not just the financial viability of the association, which fulfills an important purpose by representing volunteer fire departments, but perhaps also the structure of the county’s integrated career/volunteer fire service.
MCVFRA’s statement follows.
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MCVFRA Responds to Office of Inspector General Reports on EMST Funds
December 23, 2025
The Montgomery County Volunteer Fire and Rescue Association (MCVFRA) has carefully reviewed two recent reports issued by the Montgomery County Office of Inspector General (OIG) concerning the Emergency Medical Services Transport Insurance Reimbursement Program (EMST): the Performance Audit of the Fiscal Management Division, Montgomery County Fire and Rescue Service (OIG Publication #26-07), and the Memorandum of Investigation Regarding the Allocation of EMST Funds to MCVFRA.
Taken together, the reports identify long-standing, system-level weaknesses in how EMST funds were approved, tracked, documented, and reconciled across multiple entities over many years. Neither report alleges fraud, intentional misuse, or diversion of funds for purposes unrelated to fire, rescue, or emergency medical services. Instead, the reports underscore the need for clearer rules, stronger documentation standards, and more consistent oversight. MCVFRA agrees that those improvements are necessary.
MCVFRA fully cooperated with both reviews. During the audit process, Association leadership disclosed that it became aware that certain EMST funds awarded to MCVFRA in prior years were used for expenses outside the specific purposes identified in individual award agreements. Those uses were not permissible under applicable agreements, and that disclosure is reflected in the OIG’s findings. The Association takes these findings seriously and accepts responsibility for ensuring that funds entrusted to it are used strictly in accordance with legal and contractual requirements going forward.
At the same time, MCVFRA strongly disagrees with the OIG’s legal conclusion that the Association was categorically ineligible to receive EMST funds. MCVFRA has never claimed to be, nor represented itself as, a local fire and rescue department. The Association’s website and governing documents explicitly identify the 19 local fire and rescue departments it represents. MCVFRA exists as the recognized representative and coordinating body for those departments, providing shared administrative, compliance, volunteer-support, and system-coordination functions that directly benefit local fire and rescue departments and the County’s integrated fire and rescue system.
County law requires that a portion of EMST revenue be allocated “for the benefit of local fire and rescue departments.” The law does not state that funds may only be paid directly to individual departments, nor does it prohibit the use of a representative or system-level entity to deliver services that benefit departments collectively. For more than a decade, the County implemented the statute consistent with this understanding, through a transparent, multi-layered process that included review by the MCVFRA funding committee, approval by the MCVFRA Board, approval by the Fire Chief, and incorporation into County budget actions subject to County Council oversight.
For program years 2013 through 2023, more than $25 million in EMST funds flowed through MCVFRA for disbursement for the benefit of Montgomery County’s local fire and rescue departments. Of that amount, approximately $1.43 million, or about 5.7%, was retained by MCVFRA for approved system-level purposes benefiting those departments.
The suggestion that MCVFRA’s receipt of membership dues renders it ineligible for EMST funding has no basis in County law. Like many representative organizations, MCVFRA collects dues from its member departments to fund activities that fall outside the scope of County grants and other restricted funding sources. Nothing in the EMST statute conditions eligibility on the absence of dues or other independent revenue.
Similarly, the assertion that budget agreements to which MCVFRA is a signatory demonstrate an understanding that EMST funds may only flow directly to local fire and rescue departments is unsupported. Those agreements are executed jointly by MCVFRA, MCFRS, the County Executive’s Office, and the County Attorney. For more than a decade, all parties approved and implemented EMST allocations consistent with the understanding that system-level expenditures benefiting local departments were permissible. The record does not support a contrary interpretation.
MCVFRA is also concerned by suggestions that previously approved EMST allocations should now be subject to repayment. For more than a decade, EMST awards followed a formal, County-approved process involving multiple layers of review and oversight. The Association and its member departments relied in good faith on those approvals in planning, staffing, and delivering system-wide services that support public safety. Retroactive repayment under these circumstances would undermine that reliance and destabilize a volunteer fire and rescue system on which the County depends every day.
Importantly, neither OIG report concludes that public safety was compromised or that EMST funds were used for purposes unrelated to fire, rescue, or emergency medical services. The disagreement raised in the investigation concerns statutory interpretation and administrative structure, not the mission or intent of the EMST program.
“These reports reflect issues that developed over many years and across multiple entities,” said Russell Hartung, President of MCVFRA. “They highlight the need for clearer guidance, stronger documentation, and consistent oversight. We take our responsibility to the public and to our member departments seriously, and we are committed to addressing these issues directly while protecting the integrity of the volunteer fire and rescue system.”
MCVFRA looks forward to working collaboratively with the County Executive, the Public Safety Committee, the full County Council, and the Fire Chief to clarify the statute prospectively, strengthen oversight and controls, and ensure that system-level functions that benefit local fire and rescue departments are clearly authorized and appropriately funded.
Since the issuance of these reports, MCVFRA has been heartened by conversations with County leaders that reinforce a shared understanding of the Association’s long-standing role in supporting Montgomery County’s volunteer fire and rescue departments and its integrated fire and rescue system. Those discussions underscore the importance of ensuring clarity and continuity so that system-level coordination, support, and oversight functions remain strong and effective.
Moving forward, MCVFRA remains focused on:
- Reinforcing compliance with EMST restrictions and spending timelines;
- Improving internal documentation, accounting, and record-keeping practices;
- Reviewing procurement and grant-related processes to ensure alignment with County requirements; and
- Supporting reforms that promote transparency, accountability, and long-term stability across the volunteer fire and rescue system.
MCVFRA remains committed to its mission of supporting Montgomery County’s volunteer fire and rescue departments and the communities they serve. Additional updates will be provided as corrective actions and legislative discussions move forward.
