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CMS-1403-FC
distinction in the license as to whether the individual
holds a credential of CRT or RRT. They are both licensed
as “respiratory therapists.” To the best of AARC’s
knowledge, there are only six States that require a
separate license for a CRT or a RRT. AARC recommended that
the proposed definition be revised.
Since CMS uses the term “respiratory therapist” in
other regulatory provisions and manual instructions where
applicable, AARC recommended that CMS delete the word
“registered” from the proposed definition. This would also
be consistent with the terms “physical therapist” and
“occupational therapist” used to define qualified personnel
in those professions.
AARC also believes that CMS can ensure that only
registered respiratory therapists, and not individuals
holding only the CRT, meet the personnel qualifications by
revising the curriculum requirements to require that
respiratory therapists have passed the registry examination
administered by the NBRC. AARC also noted that the name of
the Board administering the certification and registry
exams is the NBRC, not the National Board for Respiratory
Therapy, Inc.
Response: We thank the commenters for their support
of our proposed revisions. We believe that the comments
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