Occupational Therapy Licensing Board

OT Assistants - Q and A
 
1. Can an OT Assistant perform home assessments, gather data and complete a home visit check list?
An OT may delegate home assessment data collection to an OTA. However, it is the OT’s responsibility to analyze the data, make recommendations and document or co-sign findings. Gathering objective data falls within the OT Assistant’s scope of practice. The supervising OT interprets the data and works collaboratively with the OT Assistant to make recommendations.
 
2. Can an OT Assistant begin an evaluation?
Evaluations of patients are done by Occupational Therapists. The OTA, if trained, may perform the chart review and collect information from the team. The OT Assistant must then discuss the case with the supervising OT. An OT Assistant can proceed with starting the evaluation in the manner directed by the supervising OT. All evaluation interpretation must be done by the OT.
 
3. Can an OT Assistant administer the PCE (Physical Capacity Evaluation) or other standardized tests?
The OT Assistant must have the training and experience to administer the PCE or any other standardized test. The OT Assistant can collect information; however, the OT must be involved with the interpretation of the data results. For example the OT Assistant can get numbers for a pinch or grip, but the OT must interpret the numbers. The patient can work on the treadmill and the OT Assistant can collect the data, but those numbers must be interpreted by the OT. An OT Assistant with appropriate skills can test a worker’s lift tolerance, but the OT is responsible for the projections made.
 
An OT Assistant with the skills could not grade fine motor dexterity tests such as the Perdue and Minnesota Manual Dexterity Test and grip strength for validity purposes, because this interpretation is the responsibility of the OT. The OT is responsible for writing the assessment and determining evaluation validity and work categories. With training the OT Assistant can perform muscle testing and goniometry measurement tests. The measurements and test results must be interpreted by the OT.
Generally for all tests, the OT Assistant works in collaboration with the OT. For example, for the Claudia Allen standardized test, it is the supervising OT, in collaboration with the OT Assistant that is responsible for setting and evaluating the standard of work performed. When the test requires interpretation, which is in the purview of the OT’s role, but it is a collaborative decision between the OT and the Assistant how much the Assistant is involved and individual work performed. As always, the OT Assistant must always have the training and experience. When appropriate the supervising OT is responsible for providing closer supervision.
 
4. Can an OT assistant perform an ADL assessment before the supervising OT has performed an evaluation or become otherwise involved?
 No, the ADL can only be performed under the direction of the supervising.
 
5. Can an OT Assistant teach medication management?
There are several areas where an OTA, at the direction of the supervising OT may teach medication management. In a psychological situation, the OT may teach the importance of complying with prescribed dosage and timing of medication and assessing the patient’s ability to follow through. In physical disabilities setting, the OT may adapt environment or methods of application to allow patient independence with medications.
 
6. Can an OT Assistant recommend OT treatment prior to seeing a patient?
The OT Assistant does not write the treatment plan, but might, for example provide a piece of equipment such as a lapboard for UE support of a specialized eating utensil temporarily. This should be re-assessed by the supervising OT.
 
7. Must an OT co-sign daily/weekly notes?
There are no specific rules as to signing of notes. It may not be mandatory but is always a good idea. If there is no change in treatment plan or goals it is not as important as when there are changes to the plan or goals, which then makes it the responsibility of the OT and should have the OT initials.
 
8. Can an OT Assistant discharge patients?
An OT Assistant cannot discharge a patient on their own. The decision requires discussion between the OT and Assistant. The OT has final responsibility for making discharge decisions.
 
9. Can an OT Assistant prepare a Discharge Summary or sign one?
It is the responsibility of the OT to make decisions about whether a patient can be discharged. If there is no change in the plan or goals, the OT Assistant can finalize the discharge, but the summary should be co-signed by the OT who has the final responsibility for the discharge decision. It is clear that an OT Assistant must work under the supervision of an OT and that means a “process in which two or more people participate in a joint effort to promote, establish, maintain and/or evaluate a level of performance”. The OT is responsible for program outcomes and documentation to accomplish them.
In general it is recommended that an OT co-sign discharge summaries and this is common practice. However, the Board acknowledged that in some cases when an OT Assistant is not adding to or amending the goals and is simply summing up the progress, not changing charting or planning in any way, the OT Assistant can sign the summary. The board noted that in some facilities the discharge summaries are not signed at all. The conclusion of the Board in discussion of this issue at the January, 2004 meeting was that the OT does not have to co-sign the discharge summary in all cases.
OT Assistants: Role for Care Plans, Discharge Recommendations and Discharge Notes
 
A. Plan of Care (POC):
The Plan of Care (POC) which includes goals, treatment plan and frequency/duration is prepared by the occupational therapist (OTR). The occupational therapy assistant (OTA) may not modify the plan of care. However, the OTA may recommend changes to any element of the patient’s plan of care and communicate those to the supervising OTR, preferably the OTR who evaluated the patient in question.
 
It is the OTR’s responsibility to decide whether they need to see the patient in question in order to decide if they agree to the recommended changes to the POC. The OTR then must update the POC in the chart to reflect the changes before the OTA sees the patient again.
 
B. Recommendations to change a patient’s discharge plan:
If the OTA believes that a patient’s recommended discharge plan needs to be changed, the OTA must contact their supervising OTR, preferably the OTR who evaluated the patient in question.
The OTR then has the discretion to decide if they need to see that patient in question again. If the OTR agrees to the proposed changes to the patient’s discharge plan, the OTA’s note must include a statement that they consulted with the OTR, which also includes the full name of the OTR. For example: “After consultation with Jane Doe, OTR, I am recommending this patient’s discharge plan be changed to SNF.”
 
The OTA would then chart this proposed change to this patient’s discharge plan in the appropriate place in the appropriate place in the chart according to the facility’s policy. Then follow policy related to follow up communication with that patient’s direct care nurse, discharge planner, attending physician, etc, regarding the change in discharge recommendations.
 
C. Discharge Notes:
If an OTA believes a patient is no longer appropriate for inpatient OT services, they must consult with their supervising OT, preferably the OTR that evaluated the patient in question. If the OTR agrees that inpatient OT services should be discontinued, the OTA is permitted to write a discharge note with the final summary of a patient’s functional status.
 
This OTA’s discharge note must include a statement that they consulted with the OTR, which also includes the full name of the OTR. For example: “After consultation with Jane Doe, OTR, the patient is discharged from OT services.”
 
If a patient has discharged from the facility and that patient is assigned to an OTA, the OTA will write that patient’s discharge note stating, “discharged prior to the OT treatment. No OTR consultation is required.”
 
Further Guidance from the Board:
 
Facilities must follow the Standards of Practice for Occupational Therapy which includes what is needed for OT Assistants in Screening and Evaluation; and for Intervention, and Outcomes so that the Assistant provides the information to the primary therapist who would then complete the official documentation and make the changes to the POC/DC Note.
 
Facilities have their own protocols on how they handle many situations regarding use of OT Assistants. Since the OT, and not the Assistant, must set the Plan of Care, it is recommended that the OT write ADL goals, and/or the Plan of Care, broadly enough so that the Assistant can follow through as needed with individual patients.
For example, if a patient will need self care ADLs (grooming, bathing, showering, dressing), instead of writing a goal that is just bathing, the OT can write the goal as self care and the OT Assistant can follow through on broader activities for the patient within the ADL spectrum. Or if ADLs is in the Plan of Care, then the OT Assistant can work with the patient on a specific ADL such as bathing, even if there is not a goal for that specific ADL. How the OT writes the goal and/or Plan of Care will affect how much the OT Assistant can do with the patient. The intent of the Board is that it be clear in the written documentation that the Assistant is working within their scope set by the OT in the plan of care.
Can an Occupational Therapy Assistant sign a Discharge Summary?
An Occupational Therapy Assistant must work in Oregon under the Supervision of an Occupational Therapist. Administrative rule OAR 339-010-005(1) states: "Supervision" is a process in which two or more people participate in a joint effort to promote, establish, maintain and/or evaluate a level of performance. The occupational therapist is responsible for the program outcomes and documentation to accomplish the goals and objectives.
In general it is recommended that an Occupational Therapist co-sign discharge summaries and this is common practice. However, the Board at its January, 2004 meeting discussed this further. The Board acknowledged that in some cases when an Occupational Therapy Assistant is not adding to or amending the goals, and is simply summing up the progress, not changing the charting or planning in any way, the Occupational Therapy Assistant can sign the summary. It was also noted that in some facilities discharge summaries are not signed at all. There are great differences between employers as to what a discharge summary consists of and how it is used.
In conclusion, the Board noted that although it is good practice to have an OT co-sign the discharge summary, more flexibility was needed depending on the circumstances and the content of the discharge summary. Therefore, the Board concluded that an OT did not have to co-sign discharge summary in all cases.

 

 

OTA's Working in Multiple Settings​

If an OT Assistant is working in multiple settings and has more than one supervising OTR, each supervisor must sign unless there is one person who is providing overall practice supervision.  
 
For example, if an OT Assistant is working for a facility that has satellite clinics with various supervising OT's, the "head" OT may sign the Statement of Supervision at all of the facilities where the Assistant is working.  If there is a different supervisor at each facility with no central supervising OT, then each supervising OT must sign as supervising OT. 
 
Another example is that a hospital may contract to provide OT services to several skilled nursing facilities.  The OT Assistant might work at three facilities with supervision provided by three different OTs.  Unless there is a central practice OT supervisor who provides supervision to the OT Assistant in all three settings, the OT Assistant must have Statement of Supervision forms signed by all three supervising OTs. 

Board Chair, Mashelle Painter, authored the following article in the October 2013 edition of OT Practice:
Rules on Supervision

339-010-0005 Definitions

"Supervision," is a process in which two or more people participate in a joint effort to promote, establish, maintain and/or evaluate a level of performance. The occupational therapist is responsible for the practice outcomes and documentation to accomplish the goals and objectives. Levels of supervision:

(1) "Close supervision" requires daily, direct contact in person at the work site;

(2) "Routine supervision" requires the supervisor to have direct contact in person at least every two weeks at the work site or via telehealth as defined in OAR 339-010-0006(9) with interim supervision occurring by other methods, such as telephone or written communication;

(3) "General supervision" requires the supervisor to have at least monthly direct contact in person with the supervisee at the work site or via telehealth as defined in OAR 339-010-0006(9) with supervision available as needed by other methods.

339-010-0035 Statement of Supervision for Occupational Therapy Assistant

(1) Any person who is licensed as an occupational therapy assistant may assist in the practice of occupational therapy only under the supervision of a licensed occupational therapist.

(2) Before an occupational therapy assistant assists in the practice of occupational therapy, he/she must file with the Board a current statement of supervision of the licensed occupational therapist who will supervise the occupational therapy assistant.

(3) An occupational therapy assistant always requires at least general supervision.

(4) The supervising occupational therapist shall provide closer supervision where professionally appropriate.

(5) The supervisor, in collaboration with the supervisee, is responsible for setting and evaluating the standard of work performed.

339-010-0021 Imposition of Civil Penalties

(3) Civil penalties shall be imposed according the following schedule in the absence of a finding of aggravating or mitigating circumstances (per OAR 339-010-0022):

(m) Undertaking to act as an occupational therapy assistant independently of the supervision of an occupational therapist licensed by the Oregon Occupational Therapy Licensing Board, $500.​