RRTs can independently authorize APD-funded home oxygen therapy applications
The Assistive Devices Program (ADP) has expanded the role of hospital-based and some community-based RRTs by authorizing them to complete the Application for Funding Home Oxygen (application) in place of the prescriber. This expanded role recognizes the specialized training and expertise Respiratory Therapists have regarding oxygen administration, as well as the vital part they play in the implementation of home oxygen therapy. Please follow this link to find important information about this and other recent changes to the ADP-funded home oxygen therapy.
RRTs are permitted to independently administer oxygen under the 5th authorized act (“administrating a prescribed substance”) in the Respiratory Therapy Act and the Prescribed Substances regulation. These legislative provisions now permit RRTs to complete the application without the requirement of the prescriber’s signature. Therefore, when a physician or a nurse practitioner prescribes home oxygen therapy, the eligible RRT completes the application by:
- Transcribing the applicant’s diagnosis
- Confirming the applicant has tried other treatment measures without success; and
- Confirming that oxygen is medically indicated, and is reasonable and necessary.
There is no longer a requirement to have the application signed by the prescriber (i.e., physician or nurse practitioner). Therefore, because the RRT is signing the application under their own authority, the task under carries with it a number of essential professional accountabilities, which are as follows:
- Ensuring there is a valid order for the oxygen from either a physician or nurse practitioner. It is important to understand that in authorizing the application, the RRT is not prescribing the oxygen but is transcribing and verifying an existing order. Additional information on what constitutes a valid orders can be found in the CRTO Orders for Medical Care Professional Practice Guideline;
- Using appropriate professional judgement when confirming that oxygen therapy is medically indicated, and is reasonable and necessary;
- Adhering to all published professional standards of practice, which includes not only the CRTO Standards of Practice but also A Commitment to Ethical Practice, and the Oxygen Therapy Clinical Best Practice Guideline.
- Recognizing and addressing any conflict of interest that might exist in accordance with the CRTO Conflict of Interest regulation and the CRTO Conflict of Interest Professional Practice Guideline. More information and tools regarding Addressing Conflict of Interest can be found on the CRTO website.
- Maintaining appropriate communication with the patient, their family, the prescriber (MD or NP) and other care providers, and ensuring complete and accurate documentation, as outline in the CRTO Documentation Professional Practice Guideline.
- Keeping employment information current; particularly when moving to or from employment with an oxygen Vendor of Record. You can update your employment information via the Member Login portion of the CRTO website.
Things to Consider Before you sign an Assistive Devices Program (ADP) Home Oxygen Application
Do I have any terms, conditions and limitations (TCLs) or any other restrictions on my certificate of registration prohibiting me from authorizing ADP Home Oxygen Applications?
RRTs are now able to independently authorize the Assistive Devices Program (ADP) Home Oxygen Applications, and their ability to do so comes from the 5th authorized act – Administering a prescribed substance by inhalation (the “prescribed substance” in this case being oxygen). Therefore, only RRTs who can perform the 5th act without restrictions are permitted to sign the ADP Home Oxygen Applications.
The following groups of Respiratory Therapists may have TCLs preventing them from authorizing the ADP Home Oxygen Application:
Graduate Respiratory Therapist (GRT)
Members with a Graduate Certificate of Registration are prohibited from performing any procedures under the 5th authorized act, and therefore, are prohibited from authorizing ADP Home Oxygen Applications. In addition, GRTs have a standard TCL that requires them to only perform authorized acts under general supervision, and this also prohibits them from authorizing ADP Home Oxygen Applications.
Limited (Practical) Respiratory Therapists (PRT)
Member who holds a Limited Certificate of Registration are prohibited from performing any procedures under the 5th authorized act, and therefore, are prohibited from authorizing ADP Home Oxygen Applications.
General Certificate of Registration with TCLs (RRT)
Some General Members of the CRTO have TCLs that limit what authorized acts they can perform, or stipulate the degree of supervision required to perform certain acts. These are often added when an RRT is re-issued a certificate of registration after being away from practice for a number of years. For example, an RRT may have a term that states they “shall only perform a controlled act, authorized to Respiratory Therapy, for the purpose of gaining competence in that procedure if performed under direct supervision”. This would prevent the RRT from authorizing Home Oxygen Applications. The same term requiring general supervision would also prevent an RRT from authorizing Home Oxygen Applications.
However, some RRTs with TCLs have exceptions to certain authorized acts (or specific portions of an act). For example, an RRT may require direct or general supervision for all authorized acts “with the exception of administering a substance by inhalation”. In this instance, the RRT would be able to authorize Home Oxygen Applications because they are permitted to perform the act without the requirement of supervision.
If you have any questions about how your TCLs pertain to the authorization of ADP Home Oxygen Applications, please contact Carole Hamp RRT, Manager of Quality Practice at firstname.lastname@example.org.
Who is eligible to sign the Home Oxygen Program forms?
Any RRT with the authority to independently administer oxygen, and who are not employed by an oxygen Vendor of Record (e.g., a home care company). GRTs, PRTs, and Inactive members are not eligible to sign the applications, nor are any RRTs with terms, conditions or limitations preventing the independent administration of oxygen. If you are unsure about your eligibility, please contact the CRTO.
What if I work for a hospital that has a joint venture arrangement with a home care company?
RRTs who work for home oxygen Vendors of Record are not permitted to authorize the home oxygen application forms. However, there are a number of hospitals that have joint venture arrangements which involve some but not all the RRTs who work for that organization. Therefore, the RRTs who are directly involved with the home oxygen need to recognize that their role puts them in a conflict of interest that prohibits them from authorizing the ADP home oxygen application forms. RRTs that work for hospital with joint venture arrangements but are not directly involved with the administration of that service are still permitted to authorize the ADP home oxygen application forms.
Can an RRT transcribe a home oxygen order that comes from a medical directive?
When an RRT authorizes a home oxygen application, they must provide the home care vendor with a copy of the prescriber’s order. Both a direct order and a properly constructed medical directive meet the criteria of a valid order, and either can be used as validation of the home oxygen order. For more information as to what constitutes a properly constructed medical directive, please see the CRTO’s position statement entitled Medical Directives and the Ordering of Controlled Acts.
Do I work for a Home Oxygen Vendor of Record or does my hospital have a Joint Venture agreement with a Vendor of Record?
Oxygen vendors who have a formal agreement with ADP are considered to be a Vendors of Record (VoR), and RRTs who work for a VoR (full time, part time or on a casual basis) are not permitted to authorize the ADP Home Oxygen Application.
In addition, there are a number of hospitals that have joint venture arrangements with a VoR (i.e., a home oxygen company that operates out of a hospital), and some RRTs at that facility may work directly for the VoR – while others do not. Therefore, it is up to each individual RRT who works at a hospital with a joint venture arrangement to identify when their role places them in a conflict of interest, and then to abstain from authorizing ADP Home Oxygen Applications.
If you have any questions about how your role at a VoR or a hospital with a joint venture impacts on your ability to authorize ADP Home Oxygen Applications, please contact Carole Hamp RRT – Manager of Quality Practice at email@example.com
I only work at a Vendor of Record on a casual basis. Can I sign the initial application?
No. You must not be employed by a Vendor of Record when signing the initial application. This ensures that there is no conflict of interest related to your employment and the needs of the patient.
Are there any other criteria that determine my eligibility to sign the applications?
Yes. You must have an Ontario contact number (i.e., business contact) ensuring that there is means to contact you to clarify information about the patient, if required. As well, you must not be employed by a Vendor of Record when signing the initial application. This ensures that there is no conflict of interest related to your employment and the needs of the patient.
Why does an RRT have to be able to independently administer oxygen?
Previously, all applications needed to be signed by the person who originally prescribed home oxygen (i.e., a physician or nurse practitioner). That step has been removed to improve the efficiency of the process and to speed up patient discharge and access to home oxygen. However, when an RRT signs the application, he/she is affirming that home oxygen is both indicated and appropriate for the patient. This assessment and affirmation can only be done by an RRT with the legislated authority to independently administer oxygen.
How is the Assistive Devices Program notified about who is eligible?
10-12 times per year, the CRTO sends a list to the Assistive Devices Program of all RRTs who meet the eligibility criteria. If your employment information has changed, be sure to update your file with the CRTO promptly to ensure that your most current status will be included with the next upload to ADP.
ADP now has funding available for Short-Term Oxygen Therapy. Can RRTs sign those applications as well?
Yes. RRTs ability to complete and sign the application relates to both short-term and long-term funding applications. Please follow this link to find important information about this and other recent changes to ADP-funded home oxygen therapy.