Department of Consumer Affairs, Board of Occupational Therapy

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Students - Frequently Asked Questions

GUIDELINES FOR STUDENTS

"UNDERSTANDING WHAT YOU CAN DO DURING THE DELIVERY
OF OCCUPATIONAL THERAPY SERVICES"

Occupational therapy (OT) services are provided in various settings and within different levels of care. Therefore, the intensity and type of supervision, among other things, must be determined within the context of the setting in which services are provided.

The specific frequency, methods, and content of supervision may vary by practice setting and dependent upon the:

  • Complexity of client needs,
  • Number and diversity of clients,
  • Skills of the OT and the OTA
  • Type of practice setting,
  • Requirements of the practice setting, and
  • Other regulatory requirements.

Supervision is based on the mutual understanding between the supervisor and the supervisee about each others' competence, experience, education and credentials.

Section 4181(b) of the California Code of Regulations (CCR) states:

The supervising occupational therapist shall at all times be responsible for all occupational therapy services provided by an occupational therapy assistant, a limited permit holder, a student or an aide. The supervising occupational therapist has continuing responsibility to follow the progress of each client, provide direct care to the client, and assure that the occupational therapy assistant, limited permit holder, student or aide do not function autonomously.

Supervision may include observation, modeling, co-treatment, discussions, teaching, instruction and may be provided face-to-face or via telephone, written correspondence, or electronically.

The supervision process is aimed at ensuring the safe and effective delivery of OT services and fostering professional competence and development.

The requirements for supervision of OTAs, limited permit holders, students, and OT aides are set forth in Sections 4180-4184 of the California Code of Regulations.

Frequently Asked Questions for OT/OTA Students

OT Students:

Q. Can I treat a patient/client without a documented OT treatment plan?

A. No. However, you may participate in developing the treatment plan with your supervising OT. Your supervising OT must co-sign the treatment plan.

NOTE: You and/or your supervisor should be aware of fiscal intermediary requirements regarding students.

Q. What kind of services can I provide?

A. Title 16, Division 39, California Code of Regulations (CCR) Section 4183(a) allows Level II Students to be assigned duties or functions commensurate with their education and training.

NOTE: You and/or your supervisor should be aware of fiscal intermediary requirements regarding students.

Q. How often must the OT services I provide be reviewed by my supervising OT?

A. Supervision may vary by practice setting and be dependent upon the:

  • Complexity of client needs,
  • Number and diversity of clients,
  • Competencies of the student
  • Type of practice setting,
  • Requirements of the practice setting, and
  • Other regulatory requirements.

Business and Professions Code (BPC) Section 2570.4(b) also requires that you be designated by a title that clearly indicates that you are a student or trainee.

California Code of Regulations (CCR) Section 4183(b) also requires that "all documented client-related services by ... a student shall be reviewed and cosigned by the supervising occupational therapist."

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

A. Yes. You may perform an initial evaluation, make assessments and develop a plan of care under the supervision of a licensed OT. Your supervising OT must co-sign your plan of care.

Q. Can I obtain an advanced practice approval in hand therapy, physical agent modalities or dysphagia?

A. No. Advanced Practice approval is only available to licensed OTs who have demonstrated to the Board that they have met the Board's post professional education and training requirements.

Q. Can I be supervised by an OTA?

A. Yes. CCR Section 4181(d) allows an OTA to supervise Level I OT students.

OTA Students:

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

A. You 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.

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

Q. Can I supervise students?

A. A Level II OTA student may supervise a Level I OTA student, as delegated by their fieldwork educator/supervising OT.

Q. Can I be supervised by an OTA?

A. Yes. CCR Section 4181(d) authorizes an OTA to supervise Level I and II OTA students.

Q. Can I obtain an advanced practice approval in hand therapy, physical agent modalities or dysphagia?

A. No. Advanced Practice approval is only available to licensed OTs who have demonstrated to the Board that they have met the Board's post professional education and training requirements.

Q. Can my supervisor be an OT limited permit holder?

A. No.