Yes, I think systemic failure is an accurate assessment of fault.
Starting at the top of the ladder, the FAA believes that EMS is just another helicopter charter. It isn't. To get the helicopter EMS job you have to have significant night experience, which most Part 135 operations avoid. Example- In 13 years in the Gulf of Mexico, I did 2 night flights as a VFR pilot, and the company tried to avoid those two flights. Night flight just isn't commonplace air taxi operation, not to mention 24/7 operations.
Often, air taxi's allowed to "take a look" and/or land short of destination. That was a mixed blessing, in that I learned weather very well as an air taxi pilot by flying into it at minimums well below my present weather minimums. Most EMS operations want to be reasonably certain of getting the patient to the receiving hospital, so "taking a look" doesn't happen.
On the subject of nights and regulations, it's stupid to pretend that "10 hours of uninterrupted rest" adequately addresses the pilot's condition going from a day assignment to a night shift. Yet, it's not uncommon (and perfectly legal) for a pilot to work a day shift, sign out at 2000 hours, take 24 hours off, and sign in the next night at 2000 hours. That's a major sleep and circadian disruption, it's well known that that affects mentation- and it's not addressed in training, policy or regulation.
EMS companies generally don't exceed the letter of the law. They act in the real world of 'profit equals existence'. If you don't make money, you don't exist for very long. The industry does pretty well within those limits, with these exceptions:
Scheduling, scheduling, scheduling!;
NVGs are decades over-due;
And training is done on the cheap and treated as a necessary evil, mandated by government. The training department can be a major asset in driving quality and safety, but not when it's scattershot by a very few overworked pilots, and especially not when done by 'management' types intent on enforcing the 'book' and all it's failings.
Pilots aren't blameless in any of this.