If my service isn’t attaining aspirational volume recommendations specified in rule, should I request a waiver from the Ohio Department of Health?
Chapter 3701-84 rules provide aspirational volumes that a service should attain. However, these annual procedure volumes are recommended volumes that a provider should attain, rather than required volumes that a provider must attain. In addition, a service doesn’t know whether it has met the aspirational volume until after-the-fact. It is not until the end of the year that you can determine whether the aspirational volume has or has not been met. ODH has determined that it cannot issue a waiver to an aspirational volume recommendation, as this is not a “required” criterion, nor can ODH issue a waiver after-the-fact. A waiver is issued prior to a service not meeting the requirement and, as such, a waiver cannot be issued after a failure to meet a requirement.
Recommendation: Develop and implement policies to increase the service’s volume level, document policies in the service plan, and document efforts to increase volume levels. Identify these policies in your plan of correction if cited.
For additional information, contact Chris Kenney, Director of Regulatory Services at 614-227-4865 or email@example.com.