1. What is your department s primary purpose and objectives?

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1 77 South High Street, 16th Floor Columbus, Ohio Tel. (614) Fax (614) Corey C. Schaal, Executive Director 1. What is your department s primary purpose and objectives? The Ohio Respiratory Care Board has dual functions: the licensing and regulation of respiratory care professionals under Chapter 4761 of the Ohio Revised Code and licensing and registration of Home Medical Equipment facilities offering to sell, deliver, rent, install, demonstrate, replace or maintain specified home medical equipment in Ohio under Chapter 4752 of the Ohio Revised Code. The mission of the Board is to protect and serve the public of Ohio by effectively and efficiently regulating Home Medical Equipment facilities and the practice of Respiratory Care in the State of Ohio through the licensing of qualified facilities and practitioners, the establishment of standards for respiratory care educational programs and home medical equipment facilities and the enforcement of the laws and rules governing these practices. The Ohio Respiratory Care Board s guiding principle in the regulation of respiratory care is to improve the quality of respiratory care delivered to the public by respiratory care professionals. The Board concentrates on effective, thorough and expedient licensure of Respiratory Therapists, investigating consumer and health organization complaints, and adjudicating matters that allege practitioner misconduct. The Ohio Respiratory Care Board s guiding principle for home medical equipment licensure is to validate the quality and safety of facilities that provide home medical equipment services to Ohio consumers. The home medical equipment act requires facilities to hold a license or a certificate of registration to engage in the sale, delivery, installation, maintenance, replacement, or demonstration of home medical equipment. Home medical equipment facilities that hold licenses are inspected by the Board to assure compliance with the quality and safety standards of the State of Ohio. Home medical equipment facilities that hold a certificate of registration are accredited by one of eight organizations recognized by the Ohio Respiratory Care Board as having accreditation standards that meet or exceed the standards used for licensed facilities. 2. What is your department s past and anticipated workload, the number of staff required to complete that workload, and the department s total number of staff? Also provide a breakdown of how many staff work in administration, customer service, or in the field. The Respiratory Care Board is a working board of nine members appointed by the Governor, with the advice and consent of the Senate. Five members are licensed Respiratory Care Professionals who have been engaged or actively associated with the practice of respiratory care for at least five years prior to appointment. The Ohio Society for Respiratory Care may recommend to the Governor individuals to serve in that capacity. Two members are to be business people with at least five years of management experience in home medical equipment services. The Ohio Association of Medical Equipment Services may recommend owners or executives for those positions. One member represents the public and may be recommended to the Governor by the American Lung Association. Finally, one member is to be a physician who has clinical training and experience in the management of pulmonary disease. The Ohio State Medical Association may recommend a physician to fill this position on the Board. Currently, the Board is at full capacity and the interested organizations always have individuals to recommend should a vacancy occur. The Board conducts a minimum of six full-day meetings each year and has committees which occasionally meet on and outside of the normal Board meeting days. 1

2 The Board has a small full-time staff consisting of five employees responsible for conducting the daily administrative functions of the Board. There is one Investigator who handles complaint investigations, continuing education audits and criminal background investigations for both the Respiratory Care and the Home Medical Equipment functions. There is one Licensing Examiner who handles preliminary licensing matters for Respiratory Care Professionals (RCP) and Limited Permit Holders (L.1 & L.2). There is one Home Medical Equipment Manager who assists the Executive Director in some administrative functions, but primarily handles the preliminary licensing matters for Home Medical Equipment Licenses (HMEL) and Home Medical Equipment Certificates of Registration (HMER). There is one Administrative Professional who handles basic administrative tasks, but then provides primary back-up to both the Licensing Examiner and the Home Medical Equipment Manager. There is one Executive Director who handles final license review and approval and managerial/executive administrative functions, along with public records requests and scope of practice inquiries, aside from being the secondary backup for the Licensing Examiner and the Home Medical Equipment Manager and the primary back-up to the Investigator. Several of the staff are cross-trained in different aspects as it relates to the day-to-day responsibilities in the office. The activities within the office include issuance of RCP Licenses, Limited Permits, Home Medical Equipment Licenses, and Home Medical Equipment Certificates of Registration; application and complaint investigations and disciplinary hearing preparation, continuing education audits and program approvals, public records requests, certified state license verifications, scope of practice inquiries, and managerial and executive administrative functions (Board meeting management, website, fiscal, human resources, state requirements records retention, asset management, state plans, etc ). There are approximately 8,000 licensed Respiratory Care Professionals, 300 Limited Permit Holders (primarily students and recent graduates), and over 850 Home Medical Equipment facilities that have either the Home Medical Equipment License or the Home Medical Equipment Certificate of Registration. The Board averages handling new RCP & L.1 applications and new HMEL & HMER applications each year. Most licenses go through a renewal process every two years, but the Limited Permits are renewed on an annual basis as these are limited in both scope and duration student limited permits are limited to certified competencies and for a maximum duration of 3 years, if renewed annually, and no more than one year past the date of graduation. 3. Please identify the rules adopted by your department and explain how these rules are consistent with the legislative mandate of the department as expressed in the statutes that created and empowered the department? Ohio Revised Code establishes that the Ohio Respiratory Care Board shall regulate the practice of respiratory care in this state and the persons to whom the board issues licenses and limited permits under this chapter and shall license and register home medical equipment services providers under Chapter 4752 of the Revised Code. As such, the Board shall adopt, and may rescind or amend, rules in accordance with Chapter 119 of the Revised Code to carry out the purposes of this chapter, including rules prescribing: (1) The form and manner for filing applications for licensure and renewal, limited permits, and limited permit extensions under sections and of the Revised Code; (2) The form, scoring, and scheduling of examinations and reexaminations for licensure and license renewal; (3) Standards for the approval of educational programs required to qualify for licensure and continuing education programs required for license renewal; 2

3 (4) Continuing education courses and the number of hour requirements necessary for license renewal, in accordance with section of the Revised Code; (5) Procedures for the issuance and renewal of licenses and limited permits, including the duties that may be fulfilled by the board's executive director and other board employees; (6) Procedures for the denial, suspension, permanent revocation, refusal to renew, and reinstatement of licenses and limited permits, the conduct of hearings, and the imposition of fines for engaging in conduct that is grounds for such action and hearings under section of the Revised Code; (7) Standards of ethical conduct for the practice of respiratory care; (8) Conditions under which the license renewal fee and continuing education requirements may be waived at the request of a licensee who is not in active practice; (9) The respiratory care tasks that may be performed by an individual practicing as a polysomnographic technologist pursuant to division (B)(3) of section of the Revised Code; (10) Procedures for registering out-of-state respiratory care providers authorized to practice in this state under division (A)(4) of section of the Revised Code; (11) Requirements for criminal records checks of applicants under section of the Revised Code; and (12) Procedures for accepting and storing copies of hyperbaric technologist certifications filed with the board pursuant to division (A)(11) of section of the Revised Code. With regards to Home Medical Equipment, the Board shall adopt rules to implement and administer Chapter 4752 of the Revised Code. Pursuant to Ohio Revised Code , the rules shall do all of the following: (1) Specify items considered to be home medical equipment for purposes of divisions (B)(1) and (2) of section of the Revised Code; (2) Establish procedures for issuance and renewal of licenses and certificates of registration under this chapter, including the duties that may be fulfilled by the board's executive director and other board employees; (3) Specify the national accrediting bodies the board recognizes for purposes of issuing certificates of registration under this chapter; (4) Establish standards an applicant must meet to be eligible to be granted a license under section of the Revised Code; (5) Establish standards for personnel policies, equipment storage, equipment maintenance, and record keeping to be followed by home medical equipment services providers licensed under this chapter; (6) Establish standards for continuing education programs in home medical equipment services for individuals who provide home medical equipment services while employed by or under the control of a home medical equipment services provider licensed under this chapter; (7) Establish standards and procedures for inspection of home medical equipment providers licensed under this chapter and the facilities from which their home medical equipment services are provided and for appeal of inspection results; (8) Establish fees for issuing and renewing licenses under this chapter, in an amount sufficient to meet the expenses the board incurs in administering the licensing program; (9) Establish fees for conducting inspections of home medical equipment services providers licensed under this chapter, in an amount sufficient to meet the expenses the board incurs in administering the inspection program; (10) Establish fees for issuing and renewing certificates of registration under this chapter, in an amount sufficient to meet the expenses the board incurs in administering the registration program; and (11) Establish any other standards, requirements, or procedures the board considers necessary for the implementation or administration of this chapter. Specific rules related to our Board can be found in Ohio Administrative Code Chapter 4761 for Respiratory Care and Chapter 4761:1 for Home Medical Equipment. 3

4 4. Does your department s jurisdiction or any of its programs overlap or duplicate those of other departments? If so, what is the extent to which your department coordinates with those other departments and the extent to which the department s programs could be consolidated with the programs of other state departments? No There are no other agencies which handle the licensing and regulation of respiratory care professionals or the licensing and registration of Home Medical Equipment facilities. Fifteen years after the creation of the Respiratory Care Board by the General Assembly, the Board s composition and mandate were expanded to include Home Medical Equipment service providers. There is a natural overlap between the two fields as Respiratory Care Professionals are specially trained to set-up and use various technologically-sophisticated and life-sustaining equipment which are sold or rented by the HME facilities. Many HME facilities have Respiratory Care Professionals on staff as some equipment requires setting and adjustment by licensed healthcare providers who have been competently trained with these pieces of equipment. As such, there are existing efficiencies in both the scope of practice and in administrative duties which come from having one staff handle both the fields of Respiratory Care and Home Medical Equipment. Splitting the Respiratory Care Board in two and consolidating those functions into other Boards would eliminate these existing efficiencies. From time to time, the Board does work with the Chiropractic Board, Pharmacy Board, Nursing Board and Medical Board on matters related to scope of practice. However, the programs do not overlap. In fact, having the area of Home Medical Equipment separate from the Medical Board and the Pharmacy Board alleviates a potential area for conflict of interest. Whereas Physicians, Chiropractors and Pharmacists have individual licenses from the Medical, Chiropractic and Pharmacy Board respectively, there are members of these professions who have also taken to selling or renting home medical equipment to the public and have separate Home Medical Equipment Licenses for their businesses. As such, moving HME under the Pharmacy Board places oversight over some Doctors and Chiropractors businesses under that Board. In addition, this oversight by Pharmacy could be seen as preferential to Home Medical Equipment providers who are also pharmacists, to the detriment of others, especially the independent Home Medical Equipment service provider. Since the General Assembly adopted licensure of Home Medical Equipment providers in 2004, the field has been regulated by the expanded Respiratory Care Board. An independent HME Board would likely not be self-sufficient, but merging with the existing Respiratory Care Board made fiscal and practical sense. Today, the same arguments could potentially be made with regards to the State Board of Orthotics, Prosthetics & Pedorthics. Similar to the other health care related Board already mentioned, there are common scope of practice inquiries which arise. While the products of Orthotics, Prosthetics & Pedorthics are similar to what is defined as HME in Ohio, there are some HME providers who sell these products. Similar to the State Board of Orthotics, Prosthetics & Pedorthics, the Respiratory Care Board has experience licensing individuals. To these ends, a policy discussion regarding merging the functions or staff of these Boards bares consideration as it could lead to efficiencies even though the programs do not specifically overlap. 5. Is your department necessary to protect the health, safety, or welfare of the public? If so, how? Yes By monitoring and regulating who can become a licensed Respiratory Care Professional, our staff seeks to ensure that competent individuals are administering medical gases and medications, operating ventilators and hyperbaric chambers and performing procedures on individuals in cardiopulmonary impairment. Prior to becoming licensed Respiratory Care Professionals, we regulate students and monitor colleges and universities that offer respiratory care programs to ensure training is sound and adequate. For those in the profession, the Board protects the public by investigating complaints and conducting disciplinary hearings to ensure that bad and unethical conduct does not go un-checked. Violations of our Ohio law is subsequently reported to the National 4

5 Practitioner Data Bank and made available to everyone via both public records requests and posting of actions in the state s elicense system. In addition to the investigations and adjudications, on the HME side, the Board protects the public by ensuring that licensed facilities are either accredited or have proper insurance and are inspected to make sure that facilities are clean and sanitary, that records are being both kept and kept confidential, and that the public has access to information to keep them safe. While the Board relies on accrediting organizations to monitor the HMER facilities, the Board independently contracts with four inspectors to visit each HMEL facility. While the law requires inspections to be conducted at least every four years, our staff attempts to have this occur at least once every three years more in line with national standards. Our Board members take their roles seriously and believe they are in their positions to protect the health and safety of the people of Ohio. 6. What is the amount of regulation exercised by your department compared to such regulation, if any, in other states? Forty-nine (49) of 50 states require a specific state license for a person to practice respiratory care or therapy. The only remaining state which does not require licensure is Alaska. However, many employers in Alaska require those employed in respiratory care to be credentialed and appropriately trained. As Alaska has no educational programs accredited in respiratory care, many practicing individuals have or had licenses issued by other states, including Ohio. Most other Respiratory Care Boards have similar, but not identical, rules and regulations regarding licensure, scope of practice, continuing education, training and disciplinary actions. For example, Ohio is close to the median for required hours of continuing education with 20 every two years. And, Ohio does specifically require 1 of the 20 hours to be on ethics. Whereas several states (California, Pennsylvania, etc ) require 30 hours of CE every two years, Michigan and Utah require no continuing education to maintain licensure. Ohio has the fourth highest number of licensed Respiratory Care Professionals in the country, only California, Texas and Florida have more licensees. As such, Ohio is considered a leading state in the field of respiratory care. In 2015, Ohio started to require the higher credential of Registered Respiratory Therapist in order to obtain initial licensure, California and Arizona have followed suit with several other states looking at, or in the process of, mirroring Ohio s requirement. With regards to Home Medical Equipment (HME) facilities, Ohio is one of 27 states that require licensure. Of the ten largest states by population, only Georgia and New York do not require state licensure. All of Ohio s neighboring states, with the exception of West Virginia, require state licensure. However, HME licensure is similar to accreditation, which is performed by several national organizations. In order to enroll or maintain Medicare billing privileges, the federal government, the Centers for Medicare and Medicaid Services, requires an HME facility to be accredited, which includes site inspection. As such, most HME providers are either state licensed or accredited. To assist the field, Ohio offers two forms of HME licensure the HMEL and the HMER. The Home Medical Equipment License (HMEL) allows smaller providers or those not interested in Medicare billing the opportunity to operate safe, inspected facilities without the higher costs of being accredited. For providers interested in federal funding, the Home Medical Equipment Certificate of Registration (HMER) allows these facilities to operate without the need for state inspections, the state relies upon the inspections 5

6 required by the national organizations for accreditation. As such, the cost of applying for an HMER is less than applying for an HMEL. 7. Describe the general costs and impact of your department s activities on Ohio s businesses and individuals. The Board is self-sustaining through licensure and renewal fees and does not require money from the general revenue fund to complete our responsibilities. Almost all fees are set in the Revised Code (RCP) or the Administrative Code (HME). Inspection fees for Home Medical Equipment License (HMEL) facilities are set by the Board and are based upon the cost of conducting the inspection. Currently, the Board charges $300 per inspection. The Board adjusts the fees biennially and within the statutory limits to provide sufficient revenues to meet its expenses. The Board, subject to the approval of the controlling board, may establish fees, except fees established at amounts adequate to cover designated expenses, in excess of the statutory amounts. These fees shall not exceed the amounts specified by more than fifty per cent. At the present time, the RCB fees are at the statutory maximum amounts, but HME fees, which are set in the Administrative Code, are below the limit levels. As such, to increase revenues from RCP Licenses and Limited Permits, the Board would need to either have the Revised Code amended, or seek approval from the controlling board. All fees and fines received by the board are deposited or transferred into the state treasury to the credit of the occupational licensing and regulatory fund 4K90 Fund. Name of Fee or Revenue Source Current Fee Respiratory Care Prof. Initial Fee $75 or $ Limited Permit 1 Initial Fee $20 or $10 2 Respiratory Care Prof. License Renewal $100 Limited Permit 1 Renewal $10 Limited Permit 2 Renewal $50 Respiratory Care Prof. Late Renewal $50 Limited Permit 1 Late Renewal $5 Limited Permit 2 Late Renewal $25 RCP Miscellaneous Fees $10 - $20 RCB Fines $100 - $1,000 HME Facility License- Initial $300/$400 if > two year license. HME Facility Certificate of Registration Initial $150/$300 if > two year registration. HME Facility License Renewal $400 HME Facility Certificate of Registration Renewal $300/$150< six mo. HME Facility License Inspection Fee $300 HME Facility Fines < $5,000 1 An applicant who is a veteran or on active duty military service may request a 50% fee reduction. 2 An applicant who is a veteran or on active duty military service may request a 50% fee reduction 6

7 HME Miscellaneous $10 HME Facility Certificate of Registration Renewal Late Fee Variable HME Facility License Renewal Late Fee Variable 8. Identify and explain your customer service standards and what methods you use to monitor or improve customer service at your agency. Initially adopted in 2012 pursuant to Section of the Ohio Revised Code, the Respiratory Care Board considers good customer service to be a foundational requirement for successful achievement of its mission. All employment positions in the Ohio Respiratory Care Board are positions with a significant level of contact with the public. As such, the following customer service standards were adopted by the Ohio Respiratory Care Board: Customer Service Standards Anticipate the needs of customers by identifying expectations and working toward meeting needs. Exceed expectations of all customer groups. Hold ourselves accountable for organizational service commitment. Be aware of communication style, tone of voice and communicate professionally. Be sensitive to eye contact when communicating in person. Cover the Board s core office hours from 7:30 a.m. to 4:30 p.m. External Customers: customers and/or vendors Listen to customer requests and take immediate action to assist them. Keep customers informed of any delays in service. Greet all customers in professional and courteous manner. Inform customers what to expect from the agency and normal process time. Respond to website requests and questions by the end of the business day. Finish all interactions with customers in professional and courteous manner, even when the customer is not extending the same. Internal Customers: employee to employee; those who use services within the organization Interact in a professional and courteous manner. Communicate with internal customers by or phone daily with updates in the process. Work to resolve internal issues with other departments and coworkers by addressing problems and working toward solutions. Demonstrate respect for each other and hold each other and ourselves accountable for appropriate behavior and adherence to agency policies. Telephone Etiquette Answer the phone within three rings. Identify yourself when answering the phone. Listen to the caller s requests and help to answer questions or resolve issues. Ask caller for permission before putting them on hold. Offer to take a message if someone is not available to speak to them. End the call in a courteous manner by thanking the caller. Voice Mail 7

8 Update voic greeting when out of the office, inform callers of anticipated return, and contact person for questions. Respond to all voic messages by the end of the business day. Update out-of-office notification when out-of-office for extended period of time. Give name of contact person and expected return date. Respond to s before the end of the business day. Be aware of your writing tone when responding, but be direct concerning the Board s policy, procedures, laws and rules. The standards and questions regarding them are routinely discussed at monthly all staff meetings. 9. Please provide an assessment of the authority of your department regarding fees, inspections, enforcement, and penalties. We are authorized by Revised Code Chapters 4752 and 4761 to fulfill the duties of the Board with regards to fees, inspections, enforcement, and penalties. 10. Has your department s operation been impeded or enhanced by existing statutes and procedures and by budgetary, resource, and personnel practices? If so, which sections? The Board staff has been able to provide all the required services within the context of the current sections of the Revised and Administrative Codes of Ohio. The current budget has allowed the Board to continue the functions of licensing qualified facilities and practitioners, establishing standards for respiratory care educational programs and home medical equipment facilities and enforcing of the laws and rules governing these practices. 11. Has your department recommended statutory changes to the general assembly that would benefit the public as opposed to the persons regulated by the department? If so, have those policies been adopted and implemented? In our last several annual reports, the Board has asked for clarifying language to (A) (8) of the Revised Code. The current law regulating the practice of respiratory care permits the Board to sanction a licensee if the person uses a dangerous drug or alcohol to the extent its use impairs an individual s ability to practice at an acceptable level of competency. The Ohio Respiratory Care Board believes this language leads to variable interpretation and should be clarified by the legislature. It is the Board s belief that intent of Section (A) (8) was to make rendering respiratory care while under the influence of a dangerous drug or alcohol a violation of the law. This proposal was included in HB 266 from the last General Assembly, but issues regarding other provisions of the bill raised concerns with other licensing Boards that were not resolved prior to the end of the session. 12. Has your department required or requested any persons it regulates to report to it the impact of department rules and decisions on the public as they affect service costs and service delivery? The Board staff attend periodic meetings organized by the Ohio Society for Respiratory Care and the Ohio Association of Medical Equipment Services to discuss rules and Board activity. In addition, the Board s Executive 8

9 Director attends several regional meetings of managers and educators to share updates on the activities of the Board to gain perspectives from those preparing licensees and those seeking to employ them. 13. Describe how your department encouraged public participation in its rule-making and decision-making? The Board reaches out to both main associations representing the fields of respiratory care, the Ohio Society for Respiratory Care, and home medical equipment, the Ohio Association of Medical Equipment Services. In addition, the Board posts proposed rules, hearing notices and its meeting minutes on its website. 14. What is the process for formal public complaints that are filed with the department? And how are they resolved? The Board receives and processes each complaint made against any licensee, HME, or unlicensed individual or facility, when the complaints allege acts or practices which may constitute one or more violations of the provisions of Chapters 4761 or 4752 of the Revised Code and/or the provisions of rules promulgated by the Board. Any member of the public or the fields of Respiratory Care or Home Medical Equipment, or any federal, state or local official, may make and file a complaint with the Board. Upon receipt of a complaint and the complaint response from the subject of the complaint, the Board Investigator will confer with the Executive Director and a Board member responsible for complaint supervision to determine what disposition or type of investigation is to be initiated to investigate and/or resolve the complaint. When the complaint has been resolved, the Board Investigator or Executive Director shall advise the complainant in writing of what disposition has been made of his/her complaint. The licensee or entity who is the subject of the complaint will also be advised in writing by the Board Investigator or Executive Director of what disposition the Board has made of the complaint. In the event of an Administrative Hearing by the Board, the member assigned to supervise investigations and having previous knowledge of a specific complaint, would be excused from participation as a Board member deliberating the case. 15. Does federal law require that Ohio perform some or all of the tasks of your agency? If so, what functions are required and how are they met? The practice and licensure of Respiratory Care is handled at the state, not federal, level. With regards to Home Medical Equipment, federal requirements are placed directly on the businesses and do not go through our Board. For example, the Medicare billing privileges requirement, from the Centers for Medicare and Medicaid Services, which requires an HME facility to be accredited, this is required by the federal government, but it does not require us to provide an HMER license to that facility or for us to inspect it. 16. Please describe in detail how any state regulation or rule, of your department, exceeds or differs from any similar federal requirements with a similar impact. N/A 9

10 17. Please identify the department s practices and methods to comply with public records requests; any methods to make your records more generally available or online; the number of public records disputes during the last 2 years and the top 3 record types that are requested by the public. There have been no public record disputes in recent memory. The top three types of public records requested are prior administrative actions on licenses primarily requested from employers or HR firms; contact information addresses, s, phone numbers for licensees for entities seeking to do mass communication; and certified verification of state licensure from licensees primarily seeking to apply for licenses in other states. Many Respiratory Care Professionals will have multiple state licenses and there are traveling Respiratory Therapists who practice in several states traveling across state lines. As for compliance, a public records request can be made in writing, letter or , by phone, or in-person. If amenable, the document is provided electronically, as a pdf or an excel file attached in an . The Board does not charge for this. The certified verification of state licensure is also provide for our licensees at no charge. All requests, even those in person or via the phone, are documented and saved by the Board staff. The document requested, the response to the requester, and any reply confirming receipt which is request to confirm fulfillment of the request are also kept by the Board staff. Aside from certified verification of state licensure, all public record requests are handled by the Executive Director. If your department issues licenses, please answer the following: 18. Are such licenses required by federal law and, if so, what law(s)? No none of our licenses are required by federal law. 19. What is the extent to which licensing ensures that practitioners have occupational skill sets or competencies that correlate with a public interest? What is the impact that those criteria have on applicants for a license, particularly those with moderate and low incomes, seeking to enter the occupation or profession? For students receiving a Limited Permit, the Board has identified basic and advanced competencies that need to be obtained for full licensure. An individual can get a Limited Permit with a small number of competencies certified by their school s program director, but this in turn limits the individual s scope of practice. As the competencies are obtained and noted, then the Limited Permit Holder can submit a new verification of education form which enables the person s scope of practice to grow. In order to get a full RCP License, an individual has to have graduated with an associate or bachelor degree from an accredited program in Respiratory Care. There are 22 educational programs located throughout the state. Most of these programs are in public community colleges. As such, the Respiratory Care programs are fairly accessible and economical. As of 2015, most new licensees in Ohio need to have the tougher RRT Registered Respiratory Therapist credential as opposed to the lesser CRT Certified Respiratory Therapist credential. As graduates from accredited programs are supposed to be graduating with the skills and knowledge level to pass the national exam to obtain the RRT, the Board is ensuring that practitioners have the skills necessary to perform at a level which is to be expected. 10

11 20. What is the extent to which the requirement for the license stimulates or restricts competition, affects consumer choice, and affects the cost of services? With regards to Respiratory Care, the number of licensees is at a relatively all-time high number. On top of this, the scope of practice is not exclusive. As such, if competent in the procedure, a physician or registered nurse can do whatever a Respiratory Care Professional can do. As such, licensure for respiratory care does not restrict competition, negatively affect consumer choice, or increase the cost of the service provided. In fact, service provided by a Respiratory Care Professional is likely to be obtained at a lower cost than if provided by a physician or registered nurse. With regards to the HME business licenses, these requirements are seen as a negligible cost of doing business. And, with over 850 facilities providing services, there are many options available to Ohio consumers. By offering two types of HME licenses, the HMEL & the HMER, the Board is attempting the meet the needs of the providers to operate more thoroughly and efficiently to keep the cost of doing business down in Ohio. 11