The education requirements were meant to be "minimum" requirements, not absolute requirements. If DODD wants to only follow the "letter of the rule, the the rules need to be revised to reflect legislative intent. Sent from my Verizon Wireless 4G LTE DROID Iris Milliken <jmilkn@buckeyecommunityservices.org> wrote: Gary, What are you thinking? Your solution is way too simple!!!! Jorji Iris (Jorji) Milliken, Executive Director Buckeye Community Services 220 Morton Street PO Box 604 Jackson, Ohio 45640 740-286-5039 From: Gary Brown <GBrown@bradyware.com> To: "'opra_members@opra.simplelists.com'" <opra_members@opra.simplelists.com> Sent: Thursday, July 17, 2014 10:56 AM Subject: RE: compliance question Maybe the rules need to change the requirement to “evidence of a HS diploma or equivalent or higher education from accredited college or university requiring HS diploma or GED as admission requirement”. The purpose of the rule should be to insure a certain education level has been obtained, not as a gotcha. It seems as though this issue comes up a lot and could be remedied to everyone’s satisfaction by a a few rule wording changes. Gary Brown, CPA Director Brady Ware & Company CPA’s and Business Advisors General Office: 614-885-7407 Direct: 614-384-8411 Fax: 614-384-8511 Cell: 614-578-2048 www.bradyware.com<http://www.bradyware.com/> From: list-manager@opra.simplelists.com [mailto:list-manager@opra.simplelists.com] On Behalf Of Lynn Emmons, PHR Sent: Thursday, July 17, 2014 10:42 AM To: opra_members@opra.simplelists.com Subject: RE: compliance question We stick with the High School Diploma because we do Delegated Nursing and that specifically requires the Diploma or GED. I did run into some issues with online HS Diplomas… which involved some conversations with the atty at DODD and conversations with the Ohio Dept of Education. We had an individual who received their HS Diploma from an online school, however it was not accredited, so we did insist that she take the GED before we could let her take the med pass classes. There is a list of accredited online courses through the ODE Lynn Emmons, PHR Human Resources Director SHC/The Arc of Medina County 330-722-1900 x200 lemmons@shc-medina.org<mailto:lemmons@shc-medina.org> LIVE. LEARN. EARN. PLAY. @ SHC/THE ARC OF MEDINA COUNTY [Small-sized facebook icon]<https://www.facebook.com/pages/SHCThe-Arc-of-Medina-County/150320185025675?r>[Small-sized Twitter icon]<http://twitter.com/SHCtheArc> From: list-manager@opra.simplelists.com<mailto:list-manager@opra.simplelists.com> [mailto:list-manager@opra.simplelists.com] On Behalf Of Cindy L. Marks Sent: Thursday, July 17, 2014 10:37 AM To: 'opra_members@opra.simplelists.com' Subject: RE: compliance question We also have not been cited for accepting college transcripts. Like Priscilla, we do check to ensure the school requires a high school diploma or GED. Cindy L. Marks, Human Resources Director CRSI – a not-for-profit provider of DD services 1150 Scioto St. - Urbana, Ohio 43078 937-653-1330-Office 937-869-1211-Cell 937-653-1342-Fax http://www.crsi-oh.com/ [CRSI-Empower-Small file (2)] From: list-manager@opra.simplelists.com<mailto:list-manager@opra.simplelists.com> [mailto:list-manager@opra.simplelists.com] On Behalf Of Priscilla Faux Sent: Thursday, July 17, 2014 10:29 AM To: opra_members@opra.simplelists.com<mailto:opra_members@opra.simplelists.com> Subject: RE: compliance question We haven’t been cited for accepting college transcripts. That is based on the person receiving a 2yr or 4yr degree that is listed on the transcript. We have gone the extra step with some transcripts from a community college to verify that the program required an high school diploma to enroll. There have been some that were training programs or even GED prep. Priscilla Faux – HR Director 513-281-6800, x106 ** The material being sent to you may contain PRIVILEGED and CONFIDENTIAL information only for the use of the addressee(s) named above. If the reader of this messages is not the intended recipient, please note that any dissemination, distribution or copying of this communication is prohibited. it is requested that anyone who receives this communication in error notify the sender immediately by email reply & destroy all copies of the transmission received. Thank you. ** From: list-manager@opra.simplelists.com<mailto:list-manager@opra.simplelists.com> [mailto:list-manager@opra.simplelists.com] On Behalf Of OPRA Sent: Thursday, July 17, 2014 9:56 AM Subject: FW: compliance question From: Debbie Schmieding [mailto:debbies@havar.org]<mailto:[mailto:debbies@havar.org]> Sent: Wednesday, July 16, 2014 3:14 PM To: list-manager@opra.simplelists.com<mailto:list-manager@opra.simplelists.com> Subject: compliance question We have recently been cited in a compliance review because we have accepted college transcripts from applicants in lieu of h.s. diploma or GED. Has anyone successfully appealed this? Debbie Schmieding Havar CONFIDENTIALITY NOTE: This message (and its attachments) is intended for use only by the individual or entity to which it is addressed and may contain information that is privileged, confidential, Protected Health Information (PHI) as defined by HIPAA or exempt from disclosure under applicable law. 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You are receiving this important information as a member service of the Ohio Provider Resource Association. Unless messages and/or replies are specifically directed, each posting/response is sent to the entire group. This group is open only to OPRA members, a large and diverse body. The views of individual list serve users do not necessarily reflect the view of the OPRA Board or Staff. To send a message to this list serve, please use the reply button. To reply only to the original sender, please respond to the email listed after "on behalf of" in the FROM line of the message header. Thank you. ________________________________ As required by IRS Circular 230, you should be aware that any tax advice contained in the body of this email was not intended or written to be used, and cannot be used, by the recipient for the purpose of avoiding penalties that may be imposed under the Internal Revenue Code or applicable state or local tax law providers. 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