Department of Consumer Affairs, Board of Occupational Therapy

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Clarification of a Physical Therapist's Responsibility while Providing Supervised Training of an Occupational Therapist Obtaining an Advanced Practice Certification in Hand Therapy or Physical Agent Modalities within the State of California

A physical therapist (PT) is authorized to provide supervised training to an occupational therapist (OT) performing treatments to qualify for or obtain advance practice certification in either hand therapy or physical agent modalities.

The supervised training must conform to the requirements of Business and Professions Code section 2570.3 and Title 16, California Code of Regulations section 4154, which, among other things, require a written agreement outlining the plan of supervision and training in the advanced practice area. While some patient therapies fall within both scopes of practice, OTs and PTs must adhere to the laws and regulations that pertain to each discipline as the two are not interchangeable.

When a PT provides supervised training to an OT who is performing hand therapy or physical agent modalities as part of training for an advanced practice certification, there are two alternate situations that may occur and the role of the PT is different in each. While under the PT's supervision, an OT must follow the direction of the PT for the specific advance practice area. In each situation, however, the OT is not deemed to be functioning as a physical therapist assistant or aide.

Alternative 1: PT Treatment Plan

An OT may perform advanced practice procedures under a PT's evaluation and treatment plan. The patient would be receiving physical therapy care and not occupational therapy care and the care of the patient is the PT's responsibility. The PT must make a professional judgment as to the level of supervision that is required.

The PT is required to perform the physical therapy evaluation and establish the treatment plan and goals pursuant to section 2620.7 of the Business and Professions Code and section 1399.85 of Title 16, California Code of Regulations. The PT should review and discuss with the OT, for educational purposes, the portion of the treatment plan relating to the advanced practice procedure. The PT may review and discuss the physical therapy evaluation with the OT that pertains to the advance practice procedure.

Alternative 2: OT Treatment Plan

The OT may perform advanced practice procedures under the supervision of a PT pursuant to a treatment plan developed by an OT who is lawfully authorized to establish the treatment plan for that advanced practice area. The patient would be receiving occupational therapy care rather than physical therapy care. The PT is responsible for ensuring that the OT performs the advanced practice procedures or techniques properly, but is not responsible for the OT treatment plan itself.

Note: This document is not a declaratory opinion of the Physical Therapy Board of California and the California Occupational Therapy Board.

Adopted by the California Occupational Therapy Board on October 11, 2007
Adopted by the Physical Therapy Board of California on August 3, 2007