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SUPERVISION

Article in OT PRACTICE

Board Vice-Chair, Mashelle Painter, authored the following article in the October 2013 edition of OT Practice:

"The OTA's Role in the Evaluation Process" by Mashelle Painter 

Statement of Supervision

OAR 339-010-0035(2) requires a signed Statement of Supervision
(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 signed, 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.
 
The definition of “general supervision” is found in OAR 339-010-0005
(1) "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:
      (a) "Close supervision" requires daily, direct contact in person at the work site;
      (b) "Routine supervision" requires the supervisor to have direct contact in person at least every two weeks at the work site with interim supervision occurring by other methods, such as telephone or written communication.
      (c) "General supervision" requires the supervisor to have at least monthly direct contact in person with the supervisee at the work site with supervision available as needed by other methods. 


Statement of Supervision Form 

 

Limited Permit Supervision 

A signed "Statement of Supervision" must be filed in the OTLB office prior to working under Limited Permits.  It can be faxed to 971-673-0226 or scanned and emailed.  See Application Forms section for more information regarding obtaining a Limited Permit.

 

LP Supervision form.doc

 

LP Supervision form.pdf

 

 

 

 Q & A

 


What do the rules and law say about OT Assistants?

 
Under Oregon law, ORS 675.210(4) “Occupational therapy assistant” means a person licensed to assist in the practice of occupational therapy under the supervision of an occupational therapist.”
 
How does an OT Assistant have to be supervised? 
 
The Oregon rules relating to Supervision of OT Assistant is found under
OAR 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 signed, 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
     (emphasis added)
(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.
 
What is the definition of Supervision?       339-010-0005: Definitions
 
(1) "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:
(a) "Close Supervision" requires daily, direct contact in person at the work site;
(b) "Routine Supervision" requires the supervisor to have direct contact in person at least every two weeks at the work site with interim supervision occurring by other methods, such as telephone or written communication.
(c) "General Supervision" requires the supervisor to have at least monthly direct contact in person with the supervisee at the work site with supervision available as needed by other methods.     . . .
(3) "Licensed occupational therapy practitioner", for purposes of these rules, means an individual who holds a current occupational therapist or occupational therapy assistant license. 
 
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.
 
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.
 
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.    
 
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 OT.
 
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. 
 
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.
 
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.
 
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. 
 
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 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. 

AOTA Standards on Supervision
AOTA's Guidelines for Supervision, Roles, and Responsibilities During the Delivery of Occupational Therapy Services have been adopted the Oregon OT Licensing Board.
 
This document contains four sections that direct the delivery of occupational therapy services. These sections are General Supervision, Supervision of Occupational Therapists and Occupational Therapy Assistants, Roles and Responsibilities of Occupational Therapists and Occupational Therapy Assistants During the Delivery of Occupational Therapy Services, and Supervision of Occupational Therapy Aides.
 
General Supervision
These guidelines provide a definition of supervision and outline parameters regarding effective supervision as it relates to the delivery of occupational therapy services. These supervision guidelines are to assist in the appropriate and effective provision of occupational therapy services. The guidelines themselves cannot be interpreted to constitute a standard of supervision in any particular locality. Occupational therapists, occupational therapy assistants, and occupational therapy aides are expected to meet applicable state and federal regulations, adhere to relevant workplace policies and the Occupational Therapy Code of Ethics (AOTA, 2005) and participate in ongoing professional development activities to maintain continuing competency.
 
In these guidelines, supervision is viewed as a cooperative process in which two or more people participate in a joint effort to establish, maintain, and or elevate a level of competence and performance. Supervision is based on mutual understanding between the supervisor and the supervisee about each other’s competence, experience, education, and credentials. It fosters growth and development, promotes effective utilization of resources, encourages creativity and innovation, and provides education and support to achieve a goal (AOTA, 2004). Within the scope of occupational therapy practice, supervision is a process aimed at ensuring the safe and effective delivery of occupational therapy services and fostering professional competence and development.
 
Supervision of Occupational Therapists and Occupational Therapy Assistants
Occupational Therapists
Based on their education and training, occupational therapists, after initial certification, are autonomous practitioners who are able to deliver occupational therapy services independently. Occupational therapists are responsible for all aspects of occupational therapy service delivery and are accountable for the safety and effectiveness of the occupational therapy service delivery process. Occupational therapists are encouraged to seek supervision and mentoring to develop best practice approaches and promote professional growth.
 
Occupational Therapy Assistants
Based on their education and training, occupational therapy assistants must receive supervision from an occupational therapist to deliver occupational therapy services. Occupational therapy assistants deliver occupational therapy services under the supervision of and in partnership with occupational therapists.  Occupational therapists and occupational therapy assistants are responsible for collaboratively developing a plan for supervision.
 
General Principles
 
1. Supervision involves guidance and oversight related to the delivery of occupational therapy services and the facilitation of professional growth and competence. It is the responsibility of occupational therapists and occupational therapy assistants to seek the appropriate quality and frequency of supervision to ensure safe and effective occupational therapy service delivery.
 
2. To ensure safe and effective occupational therapy services, it is the responsibility of occupational therapists and occupational therapy assistants to recognize when supervision is needed and to seek supervision that supports current and advancing levels of competence.
 
3. The specific frequency, methods, and content of supervision may vary by practice setting and are dependent on the
a. Complexity of client needs,
b. Number and diversity of clients,
c. Skills of the occupational therapist and the occupational therapy assistant,
d. Type of practice setting,
e. Requirements of the practice setting, and
f. Other regulatory requirements.
 
4. Supervision that is more frequent than the minimum level required by the practice setting or regulatory agencies may be necessary when
a. The needs of the client and the occupational therapy process are complex and changing,
b. The practice setting provides occupational therapy services to a large number of clients with diverse needs, or
c. The occupational therapist and occupational therapy assistant determine that additional supervision is necessary to ensure safe and effective delivery of occupational therapy services.
 
5. A variety of types and methods of supervision should be used. Methods may include direct, face-to-face contact and indirect contact. Examples of methods or types of supervision that involve direct face-to face contact include observation, modeling, co-treatment, discussions, teaching, and instruction. Examples of methods or types of supervision that involve indirect contact include phone conversations, written correspondence, and electronic exchanges.
 
6. Occupational therapists and occupational therapy assistants must abide by agency and state requirements regarding the documentation of a supervision plan and supervision contacts. Documentation may include the
a. Frequency of supervisory contact,
b. Method(s) or type(s) of supervision,
c. Content areas addressed,
d. Evidence to support areas and levels of competency, and
e. Names and credentials of the persons participating in the supervisory process.
 
7. Supervision related to professional growth, such as leadership and advocacy development, may differ from that needed to provide occupational therapy services. The person providing this supervision, as well as the frequency, method, and content of supervision, should be responsive to the supervisee's advancing levels of professional growth.
 
 
Supervision Outside the Delivery of Occupational Therapy Services
The education and expertise of occupational therapists and occupational therapy assistants prepare them for employment in arenas other than those related to the delivery of occupational therapy. In these other arenas, supervision may be provided by non–occupational therapy professionals.
 
1. The guidelines of the setting, regulatory agencies, and funding agencies direct the supervision requirements.
2. The occupational therapist and occupational therapy assistant should obtain and use credentials or job titles commensurate with their roles in these other employment arenas.
3. The following are used to determine whether the services provided are related to the delivery of
occupational therapy:
a. State practice acts;
b. Regulatory agency standards and rules;
c. Domain of occupational therapy practice; and
d. Written and verbal agreement among the occupational therapist, the occupational therapy assistant, the client, and the agency or payer about the services provided.
 
Roles and Responsibilities of Occupational Therapists and Occupational Therapy
Assistants During the Delivery of Occupational Therapy Services
General Statement
 
The focus of occupational therapy is to support the client’s “health and participation in life through engagement in occupation” (AOTA, 2008, p. 626). Occupational therapy addresses the needs and goals of the client related to engaging in areas of occupation and considers the performance skills, performance patterns, context and environment, activity demands, and client factors that may influence performance in various areas of occupation.
1. The occupational therapist is responsible for all aspects of occupational therapy service delivery and is accountable for the safety and effectiveness of the occupational therapy service delivery process. The occupational therapy service delivery process involves evaluation, intervention planning, intervention, implementation, intervention review, and outcome evaluation.
2. The occupational therapist must be directly involved in the delivery of services during the initial evaluation and regularly throughout the course of intervention and outcome evaluation.
3. The occupational therapy assistant delivers occupational therapy services under the supervision of and in partnership with the occupational therapist.
4. It is the responsibility of the occupational therapist to determine when to delegate responsibilities to an occupational therapy assistant. It is the responsibility of the occupational therapy assistant who performs the delegated responsibilities to demonstrate service competency.
5. The occupational therapist and the occupational therapy assistant demonstrate and document service competency for clinical reasoning and judgment during the service delivery process as well as for the performance of specific techniques, assessments, and intervention methods used.
 
When delegating aspects of occupational therapy services, the occupational therapist considers the following factors:
a. Complexity of the client’s condition and needs;
b. Knowledge, skill, and competence of the occupational therapy practitioner;
c. Nature and complexity of the intervention; and
d. Needs and requirements of the practice setting.
 
Roles and Responsibilities
Regardless of the setting in which occupational therapy services are delivered, occupational therapists and occupational therapy assistants assume the following generic responsibilities during evaluation, intervention, and outcomes evaluation.
 
Evaluation
1. The occupational therapist directs the evaluation process.
2. The occupational therapist is responsible for directing all aspects of the initial contact during the occupational therapy evaluation, including
a. Determining the need for service,
b. Defining the problems within the domain of occupational therapy that need to be addressed,
c. Determining the client’s goals and priorities,
d. Establishing intervention priorities,
e. Determining specific further assessment needs, and
f. Determining specific assessment tasks that can be delegated to the occupational therapy assistant.
3. The occupational therapist initiates and directs the evaluation, interprets the data, and develops the intervention plan.
4. The occupational therapy assistant contributes to the evaluation process by implementing delegated assessments and by providing verbal and written reports of observations and client capacities to the occupational therapist.
5. The occupational therapist interprets the information provided by the occupational therapy assistant and integrates that information into the evaluation and decision-making process.
 
Intervention Planning
1. The occupational therapist has overall responsibility for the development of the occupational therapy intervention plan.
2. The occupational therapist and the occupational therapy assistant collaborate with the client to develop the plan.
3. The occupational therapy assistant is responsible for being knowledgeable about evaluation results and for providing input into the intervention plan, based on client needs and priorities.
 
Intervention Implementation
1. The occupational therapist has overall responsibility for implementing the intervention.
2. When delegating aspects of the occupational therapy intervention to the occupational therapy assistant, the occupational therapist is responsible for providing appropriate supervision.
3. The occupational therapy assistant is responsible for being knowledgeable about the client’s occupational therapy goals.
4. The occupational therapy assistant selects, implements, and makes modifications to therapeutic activities and interventions that are consistent with demonstrated competency levels, client goals, and the requirements of the practice setting.
 
Intervention Review
1. The occupational therapist is responsible for determining the need for continuing, modifying, or discontinuing occupational therapy services.
2. The occupational therapy assistant contributes to this process by exchanging information with and providing documentation to the occupational therapist about the client’s responses to and communications during intervention.
 
Outcome Evaluation
1. The occupational therapist is responsible for selecting, measuring, and interpreting outcomes that are related to the client’s ability to engage in occupations.
2. The occupational therapy assistant is responsible for being knowledgeable about the client’s targeted occupational therapy outcomes and for providing information and documentation related to outcome achievement.
3. The occupational therapy assistant may implement outcome measurements and provide needed client discharge resources.
 
Supervision of Occupational Therapy Aides
An aide, as used in occupational therapy practice, is an individual who provides supportive services to the occupational therapist and the occupational therapy assistant. Aides do not provide skilled occupational therapy services. An aide is trained by an occupational therapist or an occupational therapy assistant to perform specifically delegated tasks. The occupational therapist is responsible for the overall use and actions of the aide. An aide first must demonstrate competency to be able to perform the assigned, delegated client and non-client tasks.
 
1. The occupational therapist must oversee the development, documentation, and implementation of a plan to supervise and routinely assess the ability of the occupational therapy aide to carry out non-client-and client-related tasks. The occupational therapy assistant may contribute to the development and documentation of this plan.
 
2. The occupational therapy assistant can supervise the aide.
 
3. Non-client-related tasks include clerical and maintenance activities and preparation of the work area or equipment.
 
4. Client-related tasks are routine tasks during which the aide may interact with the client. The following factors must be present when an occupational therapist or occupational therapy assistant delegates a selected client-related task to the aide:
Depending on the setting in which service is provided; aides may be referred to by various names. Examples include, but are not limited to, rehabilitation aides, restorative aides, extenders, paraprofessionals, and rehab techs
a. The outcome anticipated for the delegated task is predictable.
b. The situation of the client and the environment is stable and will not require that judgment, interpretations, or adaptations be made by the aide.
c. The client has demonstrated some previous performance ability in executing the task.
d. The task routine and process have been clearly established.
 
5. When performing delegated client-related tasks, the supervisor must ensure that the aide
a. Is trained and able to demonstrate competency in carrying out the selected task and using equipment, if appropriate;
b. Has been instructed on how to specifically carry out the delegated task with the specific client; and
c. Knows the precautions, signs, and symptoms for the particular client that would indicate the need to seek assistance from the occupational therapist or occupational therapy assistant.
 
6. The supervision of the aide needs to be documented. Documentation includes information about frequency and methods of supervision used the content of supervision and the names and credentials of all persons participating in the supervisory process.
 
Summary
These guidelines about supervision, roles, and responsibilities are to assist in the appropriate utilization of occupational therapists, occupational therapy assistants, and occupational therapy aides and in the appropriate and effective provision of occupational therapy services. It is expected that occupational therapy policies, the Occupational Therapy Code of Ethics (AOTA, 2005), and continuing competency and professional development guidelines.
 
References
American Occupational Therapy Association. (2004). Guidelines for supervision, roles, and responsibilities during the delivery of occupational therapy services. American Journal of Occupational Therapy, 58, 663–667.
American Occupational Therapy Association. (2005). Occupational therapy code of ethics (2005). American Journal of Occupational Therapy, 59, 639–642.
American Occupational Therapy Association. (2008). Occupational therapy practice framework: Domain and process (2nd ed.). American Journal of Occupational Therapy, 62, 625–683.
 
Additional Reading
American Occupational Therapy Association. (2005). Standards of practice for occupational therapy.  American Journal of Occupational Therapy, 59, 663–665.
 
Authors
Sara Jane Brayman, PhD, OTR/L, FAOTA, Chairperson, 2002–2005
Gloria Frolek Clark, MS, OTR/L, FAOTA
Janet V. DeLany, DEd, OTR/L
Eileen R. Garza, PhD, OTR, ATP
Mary V. Radomski, MA, OTR/L, FAOTA
Ruth Ramsey, MS, OTR/L
Carol Siebert, MS, OTR/L
Kristi Voelkerding, BS, COTA/L
Patricia D. LaVesser, PhD, OTR/L, SIS Liaison
Lenna Aird, ASD Liaison
Deborah Lieberman, MHSA, OTR/L, FAOTA, AOTA Headquarters Liaison for The Commission on Practice
Sara Jane Brayman, PhD, OTR/L, FAOTA, Chairperson
Adopted by the Representative Assembly 2004C24
Edited by the Commission on Practice 2009
This replaces the 2004 document Guidelines for Supervision, Roles, and Responsibilities During the Delivery of Occupational Therapy Services (previously published and copyrighted in 2004 in the American Journal of Occupational Therapy, 58, 663–667).
Copyright © 2009 by the American Occupational Therapy Association.
 
November/December 2009, Volume 63, Number 6  THE REFERENCE MANUAL OF THE OFFICIAL DOCUMENTS OF THE AMERICAN OCCUPATIONAL THERAPY ASSOCIATION, INC.
 
 
 
 

Supervision for Fieldwork Students
Fieldwork Students must have supervision.  In Oregon, Pacific University, School of OT has a fieldwork Co-coordinator.  Generally questions should go there first.  The OT Licensing Board does get some questions on supervision, and often those questions come to the board because the question really deals with co-signing notes for reimbursement.  Those questions deal with Medicare/Medicaid issues.
 
For information about fieldwork supervision please refer to the school through which you are doing your fieldwork, and the AOTA guidelines.  They are found at: www.aota.org.
 
For some specific information you can click on the link you want below: 
 
Guide lines for level II Field Work for OT students. for more on AOTA Guidelines for student fieldwork or for information on Medicare Reimbursement for Students Issues.