State of Oregon: Occupational Therapy Licensing Board

OARS on OTA Supervision / Filing Supervision with the OTLB

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. Before an OTA can start working they must file their OT Supervisor with the board.

OTA's can now update their OT Supervisor electronically in the Licensee Portal. Log in and Click on Supervisor/Supervision Tab, add the name of the OT Supervisor, the Site of Supervision, the Start date and click SAVE. The OT that you have entered will then need to log in to their portal, and change the approval status to APPROVE. Once this done, the OT supervisor has been successfully filed with the Licensing board.

Step by step instructions on how to file supervision in the License Portal: OTA instructions for filing OT Supervision.pdf

Here is the rule:

OAR 339-010-0035

339-010-0035
Supervision of an 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:

(a) The occupational therapy assistant must log into their online license portal with the board and record the name of the licensed occupational therapist who will supervise them, the site where supervision will take place and the supervision start date.

(b) The licensed occupational therapist whose name is recorded in the online license portal with the board must log into their online license portal and confirm their supervision of the occupational therapy assistant by updating the approval status to “approved".

(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 or via telehealth as defined in OAR 339-010-0006(9) 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 or via telehealth as defined in OAR 339-010-0006(9) with supervision available as needed by other methods.

Limited Permit Supervision

OT's or OTA's working under a limited permit must have an OT Supervisor on file with the Board. To record a LP Supervisor, log in to the Licensee Portal and enter in the name of the OT supervisor. He/she will be sent an email requesting they login to the Licensee Portal to approve. Once this is done, the OT has been successfully recorded. If you have question about this procedure, contact board staff otlb.info@state.or.us.

Oregon laws on Limited Permit holders

675.320 Powers of board; fees; rules. The Occupational Therapy Licensing Board shall have the following powers in addition to powers otherwise granted under ORS 675.210 to 675.340 or necessary to carry out the provisions of ORS 675.210 to 675.340:

(11) To establish minimum requirements for limited permit to be complied with by all applicants prior to issuance of limited permit. A limited permit shall be issued to a person at the discretion of the board upon application and payment of a permit fee of $25.

339-010-0040
Limited Permit

(1) A “limited permit” is a temporary license to practice as an occupational therapist or occupational therapy assistant for a specified period of time and may be issued to applicants who meet the requirements of this rule.

(2) Students who have successfully completed the educational and field work requirements and students who receive their eligibility to take the NBCOT certification examination, but do not yet have their test results, may apply for a limited permit to practice occupational therapy for a period of 90 calendar days.

(3) Persons practicing occupational therapy in another country who are graduates of a World Federation of Occupational Therapists’ approved school and who receive their eligibility to take the NBCOT certification examination, but do not yet have their test results, may apply for a limited permit to practice occupational therapy for a period of 90 calendar days.

(4) Anyone practicing occupational therapy under limited permit may only practice under at least routine supervision (as defined in OAR 339-010-0005(1)(b)) by an Oregon licensed occupational therapist.

(5) Applicants under sections (2) and (3) of this rule:

(a) Shall submit an application in a manner provided by the Board with payment of a permit fee of $25;

(b) Must submit an official transcript and/or other verification of having successfully completed academic and supervised field work requirements as set forth in ORS 675.240 and 675.250;

(d) Must have on file with the board prior to starting work, the licensed occupational therapist who will supervisor the limited permit holder. “On file with the board” means that the licensed occupational therapist supervisor’s name, site of supervision and supervision start date has been entered into the licensees record in the License Portal and entered into approved status by the supervising occupational therapist.

(6) A limited permit may not be issued to applicants who have taken and failed the certification examination, and limited permits may not be renewed.

(7) A person who fails the exam must immediately surrender the limited permit upon receipt of examination scores.

(8) The Board may grant an extension of a limited permit to persons who, because of extenuating circumstances, are unable to take the scheduled certification examination. Request must be made in writing to the Board.

Supervision under OAR 339-010-0005(1)(b) :

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

From the AOTA Supervision guidelines:

1. Purpose: The purpose of this Model State Regulation for Supervision, Roles, and Responsibilities During the Delivery of Occupational Therapy Services is to provide a template for use by state agencies and occupational therapy regulatory boards when drafting or revising regulations to govern the clinical supervision of occupational therapy assistants, limited permit holders, and aides. The model is intended to help safeguard the public health, safety and welfare by establishing guidelines that are consistent with professional standards and accepted practice in the profession. . . .

2. Definitions A. In this section, the following terms have the meanings indicated.

(1) “Board” means the Oregon Occupational Therapy Licensing Board.

(2) “Competence” refers to an individual’s capacity to perform job responsibilities.

(3) “Competency” refers to an individual’s actual performance in a specific situation.

(4) “Limited permit holder” means an individual who has completed the academic and fieldwork requirements of this Act for occupational therapists or occupational therapy assistants, has not yet taken or received the results of the entry-level certification examination, and has applied for and been granted limited permit status.

(5) "Occupational therapist" means an occupational therapist who is licensed by the Board.

(7) "Occupational therapy assistant" means an occupational therapy assistant who is licensed by the Board to provide occupational therapy services under the supervision of and in partnership with a licensed occupational therapist.

(8) "Supervision” means 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. Within the scope of occupational therapy practice, supervision is aimed at ensuring the safe and effective delivery of occupational therapy services and fostering professional competence and development.

5. Supervision of a Limited Permit Holder

A. An occupational therapist limited permit holder or occupational therapy assistant limited permit holder who has not yet taken or received the results of the entry-level certification examination shall practice under the supervision of an occupational therapist. It is the responsibility of the supervising occupational therapist to provide and the limited permit holder to seek the appropriate quality and frequency of supervision to ensure safe and effective occupational therapy service delivery.

Resources: Supervision Log Forms / Initial Supervisory Meeting template / Examples of types of Supervision

Supervision Types - Definitions and Examples - Close, Routine and General: Types of Supervision.pdf

QUICK FACT SHEET - OTA Supervision.pdf

OTA SUPERVISION PLAN 1.pdf

Supervision Log form example 1.pdf

Supervision Log form example 2.pdf

AOTA Documents - Supervision Guidelines (2020)/ OT-OTA Partnership / Scope of Practice

AOTA's Guidelines for Supervision, Roles, and Responsibilities During the Delivery of Occupational Therapy Services have been adopted the Oregon OT Licensing Board.

AOTA Supervision Guidelines - 2020.pdf

OT-OTA-Partnership - AOTA.pdf

AOTA Scope of Practice.pdf

Bridging the gap between OTs and OTAs.pdf

Best practices for OTAs in schools.pdf

OTA Q and A: Scope of Practice

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.

Article: OTA's Role in the Evaluation Process

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

OTA's role in the Evaluation Process by Mashelle Painter

OTA's Role in Care Plans, Discharge Recommendations and Discharge Notes

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.”

Update January 2014:

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, 2014 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.

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.

OTA Supervision Q AND A: GENERAL REQUIREMENTS

Q: Can an OT Assistant update short-term goals?

A: Yes. Once the initial occupational therapy treatment/intervention plan and goals are established by the occupational therapist (OT), the occupational therapy assistant (OTA) may update short-term goals in collaboration with the OT. It’s best practice to document the collaboration between the OT and OTA.

Prior to the OTA making any updates to the short-term goals, however, the initial treatment/intervention plan, long-term goals, and initial short-term goals must be written by the evaluating OT. The OT may collaborate with the OTA in the development of these items.

Q. May an OTA treat a patient/client without a documented OT treatment plan?

A. No.

Q: Clarify the Oregon state regulations regarding the number of COTAs an OTR can supervise?

A: In Oregon, there is no specific number – it has to be “reasonable” so depends on the needs and relationship and experience. Some states have two or three. In Oregon, there is not a set specific number.

Q: Is the OT or the OTA required to file the supervision form with the OTLB?

A: It is the responsibility of the OTA. 339-010-0035 (2) Before an OTA assists in the practice of occupational therapy, he/she must file with the Board a current statement of supervision of the licensed OT who will supervise the OTA.

Q: What are the Oregon rules regarding the frequency of supervision:

A: 339-010-005 (c) states that “general supervision” requires the supervisor at have at least monthly direct contact in person with the supervisee at the worksite or via telehealth as defined in OAR 339-010-0006(9) with supervision available as need by other methods.

However, the specific frequency, methods, and content of supervision may vary and are dependent on the (a) Complexity of client needs; (b) Number and diversity of clients; (c) Knowledge and skill level of the OT and the OTA; (d) Type of practice setting; (e) Requirements of the practice setting; and (f) other regulatory requirements.

339-010-0035 (4) states the OT shall provide closer supervision where professionally appropriate.

OTA Supervision Q AND A: ROLES AND RESPONSIBILITIES

Q: Who decides if and when an OTA treats a patient/client:

A: It is the responsibility of the OT to determine when to delegate responsibilities an OT Assistant. It is the responsibility of the OTA who performs the delegated responsibilities to demonstrate service competency and also to not accept delegated responsibilities that go beyond the scope of an OTA.

Q: What are the responsibilities of the OT and OTA in regards to supervision?

A: OTs and OTAs are equally responsible for developing a collaborative plan for supervision. The OT is ultimately responsible for the implementation of appropriate and adequate supervision, but the OTA also has the responsibility to seek and obtain the appropriate quality and frequency of supervision to ensure safe and effective occupational therapy service delivery.

Q: What is the responsibility of the OT during the delivery of occupational therapy services?

A: The OT must be directly involved in the delivery of services during the initial evaluation, and regularly throughout the course of intervention, intervention review and outcomes evaluation.

Q. Can an OTA perform an initial OT evaluation and develop a plan of care?

A. The OTA may contribute to the evaluation process by implementing delegated assessments and by providing verbal and written reports of observations and client capacities to the OT.

OTAs may perform re-assessment and discharge plans of care under the supervision of an OT providing that the OT reviews and interprets the information provided by the OTA and integrates that information into the decision-making process.

Q: Can an occupational therapy assistant (OTA) perform a discharge summary?

A: An occupational therapy assistant (OTA) may gather and summarize objective information; however they may not interpret the data. It is the occupational therapist's responsibility to interpret the data gathered by the OTA and make the recommendations for discharge plan development.

The collaboration between the OT and OTA must be reflected in client documentation.

OTA Supervision Q and A: PRN

Q: Must an OTA have an OT supervisor to work PRN?

A: Yes, an OTA must always practice under the supervision of an OT.

Q: How often does an OT have to have face-to-face supervisory visits with an experienced OTA?

A: The amount of supervision will depend on the experience and service competency demonstrated by the OTA. It’s up to the OT Supervisor to determine the level of supervision that is appropriate.

A skilled OTA that has worked in the area of practice for many years, that the OT supervisor has met with and observed, and that is confident in the OTA’s skills, can meet the minimum, once per month.

Per OAR 339-010-0005 (c) "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.

Q: Do I have to notify the board every time I change supervisor if I work PRN?

A: It depends on whether or not you have a central supervisor. 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.

Q: If an OTA only works PRN in rehab facilities during the summer months is it still required to meet with the supervising OT, even though the OTA is not seeing patients?

A: If an OTA is taking a break from working, it is not necessary to continue to meet with the OT supervisor, but meetings should resume when the OTA returns. Meetings can take place with the Supervising OT prior to the start of a shift and can occur via video conference, such as face time. The supervisor may keep the OTA informed in the interim if there are new non-patient issues to discuss such as any changes with billing, documentation, etc.

Q: What if there is no OT (or not a regular staff OT) working on the day an OTA works at a building?

A: The Board recommends that the OTA take time to read the evaluation at intake of the patient even if the patient has been in the facility a long time and review what they have been working on with their regular OT/OTA. If there is any question, check another staff member or if there is something the OTA is not comfortable with, contact the DOR and do not proceed with the treatment.

Q: Do OTAs have supervisors at each facility?

A: They can, unless there is a “head” supervisor. If there is no central supervisor, an OTA may send in multiple supervision forms. They can fax it in before they start working.

Q: When census is low, OTAs may be sent to a different facility/department for the day. Is a new form/supervisor required if the OTA is meeting with different OT’s?

A: If an OTA has one “head” person designated as the supervising OTR, it does not preclude the OTA from collaborating from other OTs. A supervision form is not required if collaborating with a different OT, as long as there is a central supervisor.

Q: What if I am not getting enough support?

A: The board recommends that the OTA talk with the supervisor and see what can be worked out with the facility to schedule time when the OT supervisor is present.

OTA Supervision Q AND A: HOME HEALTH

Q: Can an OTA complete home assessments?

A: A home assessment is an assessment typically performed prior to discharge home from an inpatient or skilled nursing rehabilitation setting. It is primarily performed to determine equipment and environmental needs for the client's safety at home. It is not an evaluation performed within home health services.

A home assessment may be performed by an occupational therapy assistant (OTA) with a current client under an established occupational therapy treatment/intervention plan. The OTA can gather objective information and report observations, with or without the client and/or occupational therapist (OT) present. It is the responsibility of the OT to interpret the data gathered by the OTA and collaborate with the OTA to make recommendations. Any collaboration between the OT and OTA must be reflected in client documentation.

Q: Can OTA’s perform a screen?

A: Screens, or identification of candidates for therapy, may be performed by an occupational therapy assistant since a screen is only data gathering and non-evaluative in nature. All screens should be co-signed by the occupational therapist with collaboration documented.

Q: How often does the supervising OT need to make home visits to supervise an OTA providing home health care?

A: “General supervision” requires at least monthly direct contact, with supervision available as needed by other methods. “Close supervision” requires daily, direct contact at a service delivery site. Direct contact can be face-to-face or through video teleconferencing. The supervision does not need to be continuous during the day, but at least one time a day. Supervision is an interactive process, with the OT and the OTA sharing responsibility to see that the supervision is adequate. Home care is a difficult environment because many times there is no one present except the home care patient and the OTA. This is not an environment that easily lends itself to OTAs with less than one year of experience.

OTA Supervision Q AND A: SCHOOLS

Q: Can an OTA attend an IEP meeting without the presence of the OT?

A: It is entirely appropriate for an occupational therapy assistant (OTA) to attend an IEP meeting and present information concerning student progress and IEP goals to be addressed by occupational therapy, based on previous collaboration between the supervising occupational therapist (OT) and the OTA. If, at the IEP meeting, the IEP team requests additions or changes to the goals being addressed by occupational therapy, the supervising OT would need to review those recommendations and agree to any changes; the OTA cannot make that decision along, without additional collaboration between the OT and OTA. If, before the IEP meeting, the OT and OTA discussed and agreed upon potential changes in goals or amount or type of service, the OTA may make the changes during the IEP meeting.

Q: Can an OTA review IFSP Goals and enter it into the IFSP if it is just a review or a present level of progress?

A: As long as there are no "recommendations" or a change in goals, the OTA can draft the review. Best practice would be for the OTA to write up the review, and then have the OT look at it, and then have both names after the write-up (i.e. "submitted by Sally Smith, OTA and Joan Johnson, OTR").

Q: We provide service to multiple preschool and head start sites, usually one time per month. Does the OT have to go to each of these sites with the COTA, or could the COTA go alone and meet with the OT monthly?

A: The OT must be familiar with the site and the clients to establish the plan of care and properly supervise the OTA however, it is not required that the OT accompany each visit. The amount of supervision is dependent on many variables, such as the experience, the competency skill level.

Q: Are OTAs able to take on consultative capacities (i.e., service minutes)? If so, are there specific guidelines, and is only general supervision required from the OT?

A: Yes, OTA’s can take on consultative capacities. General supervision is required (unless certain circumstances such as limited permit, etc., same as other settings). The OT is responsible for the evaluation and developing plan of care (including determining level of service, goals, etc.). The OTA can help do assessments (once trained and competent in administering), but the OT is responsible to interpret the results and complete the evaluation. The OTA can also contribute to and collaborate on the development of the plan of care, but the OT is responsible. OTAs frequently go to IEP mtgs., but have collaborated with the OT beforehand and the OT makes any required changes to service time, goals, etc. There also might be some areas such as safe feeding protocols that the OT takes on.

Supervision of Aides

Rules on Supervision of Occupational Therapy Aides

339-010-0055

Occupational Therapy Aides Tasks

(1) An "aide" is a person who provides support services to an occupational therapist and occupational therapy assistant, but is not licensed by the Occupational Therapy Licensing Board. Any aide who is working with or supporting patients, and is performing activities covered under the occupational therapy plan of treatment, is considered an occupational therapy aide. The occupational therapy practitioner is responsible for the overall use and actions of the aide, and must ensure the competency of the aide performing the assigned tasks.

(2) An occupational therapist or occupational therapy assistant may supervise the aide. When the aide is performing treatment related tasks, the supervising occupational therapy practitioner must be within sight or earshot of the aide, and must be immediately available at all times to provide in-person direction, assistance, advice, or instruction to the aide.

(3) Treatment related tasks that the aide may assist with under the direct supervision of the occupational therapy practitioner include:

(a) Routine transfers;

(b) Routine care of patient's personal needs during the course of treatment;

(d) Assisting the occupational therapy practitioner as directed during the course of treatment.

(4) Non-treatment related tasks that may be performed by the occupational therapy aide include:

(a) Clerical;

(b) Secretarial;

(d) Supply ordering;

(e) Equipment maintenance;

(f) Fabrication of generic strapping material for splints;

(g) Transporting patients;

(h) Preparation of the work area or equipment.

(5) An aide does not provide skilled occupational therapy services in any practice setting. These rules do not apply to school aides and occupational therapists working in school settings. The rules on aides in the education setting are found in OAR 339-010-0050.

Supervision of 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:

For resources on Field Work Level 2, visit the AOTA website: Click Here.

Occupational Therapy Licensing Board

OTA's and Supervision