The accident rate for HEMS is actually higher then any other commercial sector of the helicopter industry. The only other groups with higher accident rates are flight instruction and recreational flying.
While HEMS makes up a huge part of the industry, the flight time per aircraft is relatively low. Which is why when conducting accident studies, the data is depicted against flight hours (total accidents vs. 100,000 flight hours).
You mentioned that flying day VFR in the GoM presents less risk than HAA. I agree with that, at least in comparison to flying HEMS around mountainous terrain, at night, in a region with volatile weather. It is well documented that there have been far less fatalities in the offshore sector. And as an offshore pilot myself, I acknowledge that there are many challenges with the job but, as long as your equipment is working properly, it isn’t a terribly difficult job. So what it boils down to is this; the more challenging the job, the more experienced the pilot should be.
So why is it that HEMS is the one industry cutting corners in this regard? The hiring minimums are now so low, that pilots who have only worked as CFIs can hire on at bottom feeder companies. Put in a year flying tours and you can get hired at one of the “good ones”.
That’s what everyone gets fired up about. This absurd cycle of lowering qualifications to maximize profit. To significantly reduce HEMS accidents, three things need to occur (And it’s not dual pilot IFR)
1.) Raise hiring minimums and pay to attract more experienced pilots
2.) Design a more robust training program. 6 month check rides with a heavy emphasis on IIMC recovery and off airport precautionary landings.
3.) A change in company culture to truly support safety. They all preach it, but most only hold to it within an acceptable profit margin.