Letter from the FAA, dated May 4, 2012, to Intermedix (Lee County EMS billing vendor) providing legal interpretation that accepting payment for any flight requires operations under at least a part 119 certificate. This clearly outlined that charging for any flight under part 91 was not legal. Intermedix requested this interpretation on January 23, 2012. Hopefully the Lee Clerk of Clerks audit will examine Lee County EMS billing practices for any time Lee County operated under part 91; according to the MEDSTAR website here, part 135 certificate was obtained in April 2005. Links to the letter are below.