Respiratory Care FAQs

Q: Can a Respiratory Care Professional (RCP) work from a verbal order?

A: Yes. As defined in Ohio Administrative Code (OAC) rule 4761-3-01(O), "A prescription or other order" means any verbal or written order or prescription for respiratory care services as defined under section 4761.01 of the Revised Code given in accordance with division (A) of section 4761.17 of the Revised Code. R.C. 4761.17(A) states that a respiratory care professional “shall practice only pursuant to a prescription or other order for respiratory care issued by any of the following: (1) a physician; (2) a clinical nurse specialist, certified nurse-midwife or certified nurse practitioner who holds a current, valid license issued under Chapter 4723. of the Revised Code to practice nursing as an advanced practice registered nurse and has entered into a standard care arrangement with a physician; (3) A physician assistant who holds a valid prescriber number issued by the state medical board, has been granted physician-delegated prescriptive authority, and has entered into a supervision agreement that allows the physician assistant to prescribe or order respiratory care services.”

Q: Do I need a license if I’m only performing pulmonary function tests?

A: Yes. Pulmonary function tests fall within the definition of respiratory care in R.C. 4761.01(A) which states that “respiratory care means rendering or offering to render to individuals, groups, organizations, or the public any service involving the evaluation of cardiopulmonary function, the treatment of cardiopulmonary impairment, the assessment of treatment effectiveness, and the care of patients with deficiencies and abnormalities associated with the cardiopulmonary system.” OAC rule 4761-7-03 (E) defines “any service” as "any practice performed by a competently trained licensed respiratory care professional or permit holder involving the evaluation of cardiopulmonary function, the treatment of cardiopulmonary impairment, the assessment of treatment effectiveness and the care of patients with deficiencies and abnormalities associated with the cardiopulmonary system.”

Q: Can those not licensed as an RCP perform pulmonary function testing?
A: Pulmonary function testing can fall under the scope of practice for physicians, nurses, and physician assistants who have entered into a supervision agreement that allows this service. All others must be licensed as a respiratory care professional.

Q: Can a limited permit holder perform pulmonary function testing?
A: Yes, under the supervision of a respiratory care professional. As defined in OAC rule 4761-7-04, "’To practice under the supervision of a respiratory care professional’" as used in division (B) of section 4761.05 of the Revised Code requires that an RCP be readily available in the facility and responsible at all times for the direction and actions of a limited permit holder under their supervision. Three types of limited permits are issued by the board: student-based, employment-based, and graduate-based. The level of supervision and the duties assigned may vary based upon the type of limited permit holder that is being supervised. The RCP shall determine the appropriate level of supervision and assigned respiratory care duties for an employment-based limited permit holder taking into consideration institutional competency reviews and work performance. For student limited permit holders, the appropriate level of supervision and assigned respiratory care duties shall be based, in part, on competencies approved on the verification of education form completed by the student's respiratory care educational program director. At no time shall a supervising RCP assign duties that exceed the approved competencies documented on the verification of education form. Graduate-based limited permit holders may practice a full scope of respiratory care duties, but must still be supervised in accordance with this rule. Regardless of the type of limited permit held, an RCP shall not delegate to a less qualified person any service which requires the skill, knowledge and judgment of an RCP.”

Q: How often does a script need to be written for CPAP supplies?
A: Respiratory equipment and supplies fall under the jurisdiction of the Pharmacy Board. See https://www.pharmacy.ohio.gov/Licensing/HME.aspx.

Q: Can an RCP provide services in the home setting?
A: Yes. There are no restrictions on the place of practice, but the RCP must always have a prescription or other order from a physician, PA, or APRN and appropriate equipment to provide service within minimal standards of care.
 

Q: Does a polysomnographic technologist need a license?
A: No, under certain specific conditions defined in R.C. 4761.10(C), a polysomnographic technologist does not need a respiratory care license. Specifically, this statute requires that a license is not needed if: A polysomnographic technologist credentialed by an organization the state medical board recognizes, a trainee under the direct supervision of a polysomnographic technologist credentialed by an organization the board recognizes, or a person the board recognizes as being eligible to be credentialed as a polysomnographic technologist may perform the respiratory care tasks specified in rules adopted under section 4761.03 of the Revised Code, as long as both of the following apply: (a) The tasks are performed in the diagnosis and therapeutic intervention of sleep-related breathing disorders and under the general supervision of a physician; and (b) The person performing the tasks does not represent that the person is engaged in the practice of respiratory care.” OAC rule 4761-5-06 limits the respiratory care tasks that a polysomnographic technologist may perform “in the diagnosis and therapeutic intervention of sleep-related breathing disorders upon the prescription or order from and under the general supervision of a physician to:

1. Application and titration of bi-level, continuous positive airway pressure, or non-invasive ventilation;
2. Application and titration of supplemental low flow oxygen;
3. Application and monitoring of pulse oximetry;
4. Application and monitoring of capnometry; and
5. Patient education in the application of bi-level or continuous positive airway pressure, low flow oxygen, or pulse oximetry for the ongoing management of sleep-related disorders.”

Q: Is there a difference between the scope of practice of an RRT versus a CRT in Ohio?
A: Neither Chapter 4761 of the Ohio Revised Code nor Chapter 4761 of the Ohio Administrative Code specify a difference in the respiratory care professional’s scope of practice that is based on CRT or RRT status. However, OAC rule 4761-10-01(I) states: “A licensee or permit holder shall practice respiratory care within the scope of respiratory care as set forth in division (A) of section 4761.01 of the Revised Code and in accordance with acceptable and prevailing professional standards or guidelines and shall not endeavor to extend his/her practice beyond his/her competence and the authority vested in him/her under division (B) of section 4761.01 of the Revised Code.”