The South Carolina Respiratory Therapy Licensing Board, operating under the Board of Medical Examiners within the South Carolina Department of Labor, Licensing, and Regulation, is currently considering a proposal that would expand the scope of nursing practice to include ventilator management — with Respiratory Therapist (RT) oversight provided only through virtual means.

We, the undersigned, respectfully but firmly oppose this proposal.

Respiratory Therapists are highly trained, licensed specialists who dedicate their careers to the assessment and management of critically ill patients requiring airway support. Their expertise is not incidental — it is the product of rigorous education, clinical training, and years of hands-on experience at the bedside. Replacing their physical presence with a virtual consultation is not an equivalent substitute; it is a meaningful reduction in the standard of care.

Registered Nurses are invaluable members of the healthcare team. However, ventilator management falls outside the core scope of nursing education. Neither nursing school curricula nor typical on-the-job training adequately prepares nurses to independently assess and manage the complex, rapidly evolving needs of ventilator-dependent patients. Assigning this responsibility to an already overburdened nursing workforce does not improve care — it compounds an existing staffing crisis and increases the risk of adverse patient outcomes.

Beyond patient safety, this proposal carries significant operational consequences. Hospital systems that adopt this model will face increased training costs as they attempt to prepare nurses for responsibilities outside their traditional scope. Meanwhile, the demand for Respiratory Therapists will decline, threatening the livelihoods of skilled professionals who are currently serving patients across our state.

Proponents of this proposal may point to the use of telemedicine in respiratory care as evidence that virtual RT oversight is a viable model. However, this comparison is fundamentally flawed. During the COVID-19 pandemic, institutions such as Penn Medicine implemented telemedicine respiratory therapy services — but critically, these were designed to supplement existing bedside Respiratory Therapists, not replace them. They were emergency measures born out of an unprecedented crisis, not a blueprint for standard care. South Carolina would not be following a proven model — it would be setting a dangerous new precedent, one that risks the lives of the most vulnerable patients in our healthcare system.

The challenge of providing respiratory care in rural and underserved areas is not a new one, and the healthcare industry has already developed solutions that address access concerns without compromising patient safety. Companies such as rtNOW have pioneered telemedicine respiratory therapy models that connect rural hospitals and skilled nursing facilities with licensed, experienced Respiratory Therapists via video — ensuring that a qualified RT remains the clinical decision-maker, regardless of geography. Additionally, the Respiratory Care Interstate Compact (RCIC) is being developed to allow licensed RTs to practice across state lines, further expanding access in underserved communities. These models demonstrate that improving access to respiratory care does not require replacing Respiratory Therapists with nurses — it requires innovative thinking that keeps patients, and qualified specialists, at the center of care. South Carolina need not look far for a better solution. The framework already exists; it simply requires the willingness to adopt it responsibly.

This is not a routine administrative adjustment. This is a decision that will directly affect the lives of critically ill patients, the working conditions of healthcare professionals, and the long-term integrity of respiratory care in South Carolina.
We urge the Board to reject this proposal and to uphold the standard that patients in respiratory distress deserve: a qualified, licensed Respiratory Therapist physically present at the bedside.