Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Medicine
 
chapter
Regulations Governing the Practice of Respiratory Therapists [18 VAC 85 ‑ 40]
Action Implementation of 2022 Periodic Review for Chapter 40
Stage Fast-Track
Comment Period Ended on 1/29/2025
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12/31/24  2:09 pm
Commenter: Daniel Gochenour

Recommended Adjustments to Section: 18VAC85-40-70 Individual Responsibilities
 

There are two areas within this section that I believe should be reconsidered for clarity and inclusivity of respiratory therapy practice:

  1. Avoid an Exhaustive List of Practices
    The current list of practices appears overly specific, which might inadvertently limit the scope of what respiratory therapists can perform. To address this, I recommend rephrasing the section to encompass broader responsibilities, ensuring flexibility to adapt to evolving practices and patient needs.

    • Patients with neurological conditions may require respiratory therapy for airway protection.
    • RTs may also provide preventative care for patients at risk of respiratory complications.

      Revising the Focus on Cardiopulmonary Deficiencies and Abnormalities
      The statement, “treatment of patients with deficiencies and abnormalities associated with the cardiopulmonary system,” could exclude patients who require respiratory therapy for conditions unrelated to cardiopulmonary issues. For example:

      To make this definition more inclusive, I recommend revising the statement as follows:

    “Practice as a licensed respiratory therapist means, upon receipt of written or verbal orders from a qualified practitioner and under qualified medical direction, the evaluation, care, and treatment of patients.”

This broader definition ensures that RTs can address diverse patient needs while maintaining their professional scope under medical direction.

CommentID: 229083
 

12/31/24  2:11 pm
Commenter: Daniel Gochenour

Revising the Focus on Cardiopulmonary Deficiencies and Abnormalities
 

Revising the Focus on Cardiopulmonary Deficiencies and Abnormalities
The statement, “treatment of patients with deficiencies and abnormalities associated with the cardiopulmonary system,” could exclude patients who require respiratory therapy for conditions unrelated to cardiopulmonary issues. For example:

  • Patients with neurological conditions may require respiratory therapy for airway protection.
  • RTs may also provide preventative care for patients at risk of respiratory complications.

To make this definition more inclusive, I recommend revising the statement as follows:
“Practice as a licensed respiratory therapist means, upon receipt of written or verbal orders from a qualified practitioner and under qualified medical direction, the evaluation, care, and treatment of patients.”

CommentID: 229084