Department of Consumer Affairs, Board of Occupational Therapy

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Supervision - Frequently Asked Questions

GUIDELINES FOR SUPERVISION
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 occupational therapy services and fostering professional competence and development.

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

FREQUENTLY ASKED QUESTIONS REGARDING SUPERVISION OF
OCCUPATIONAL THERAPY ASSISTANTS

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

A. No.

Q. How often must occupational therapy services provided by the OTA be reviewed by the supervising OT?

A. Section 4181(a)(1) of the California Code of Regulations (CCR) states:

Appropriate supervision of an occupational therapy assistant includes, at a minimum:
The weekly review and inspection of all aspects of occupational therapy services by the supervising occupational therapist. (Weekly review should occur once each calendar week.)

Section 4181(a)(4) also requires the supervising occupational therapist to provide periodic on-site supervision and observation of the assigned client care rendered by the occupational therapy assistant. Periodic review is defined in Section 4180(e) as at least once "every 30 days."

Based upon the supervisor /supervisee working relationship and the type of services that are being supervised, the supervising OT may chose either of these or more frequently, as he/she determines is appropriate to the needs of the client.

The supervision process is aimed at ensuring the safe and effective delivery of occupational therapy services and fostering professional competence and development. Supervision may include observation, modeling, co-treatment, discussions, teaching, instruction and may be provided face-to-face or via telephone, written correspondence, or electronically.

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. The OT and OTA must co-sign the plan of care.

Q. Can an OTA obtain advanced-practice approval in hand therapy, physical agent modalities or Dysphagia?

A. No. Advanced Practice certification is only available to licensed occupational therapists who have demonstrated to the Board that he/she has met the Board's post professional education and training requirements.

Q. Can an OTA provide advanced practice treatment and/or modalities?

A. Yes, however, the OTA must be supervised by an OT who has been approved by the Board in the appropriate advanced practice area.

Q. Can an OTA supervise an OT aide?

A. Yes, when the aide is performing a task that is not client-related.

CCR Section 4180(d) defines "non-client related tasks" as clerical, secretarial and administrative activities, transportation of patients/clients, preparation or maintenance of treatment equipment and work area, etc.

An OT aide, who provides supportive services to the OT and OTA, must be trained by an OT or OTA to perform specifically delegated tasks. An aide must first demonstrate competence to be able to perform the assigned, delegated client and non-client tasks. The OT is responsible for the overall use, actions, and supervision of the aide.

Q. Can an OTA supervise students?

A. Yes. CCR Section 4181(d) authorizes an OTA to supervise:

  • Level I occupational therapy students; and
  • Level I and Level II occupational therapy assistant students.

Q. Can an OTA function independently?

A. OTAs may function without supervision from an OT when the services being provided are services that any skilled and competent person can provide (ie. family member, educator etc.) and are neither billable occupational therapy services in a third--party reimbursement setting nor part of an occupational therapy treatment plan that requires documentation .

Examples of services an OTA may provide without supervision, may include, among other things, any of the following:

  • Job coach
  • Life coach
  • Class instructor
  • Community educator

Q. How many OTAs may an OT supervise?

A. Pursuant to Business and Professions Code (BPC) Section 2570.3(j) (2), an OT may supervise two OTAs concurrently.

Q. If I hold a certification in another field, may I use it while working as an OTA?

A. No. When functioning as an OTA, the scope and type of services must be occupational therapy. The OTA must make sure that the client knows that the services being received at only occupational therapy services.

For example: If the OTA is a registered massage therapist, it is the OTA's responsibility to make sure that that while providing retrograde massage, that he/she is providing OT services and not Massage therapy services.

Frequently Asked Questions Regarding Supervision of
OT and OTA Limited Permit Holders

Q. Does every applicant qualify for a Limited Permit?

A. No. Applicants must have applied to the National Board for Certification in Occupational Therapy (NBCOT) to take the licensing examination within four (4) months of completing the education and fieldwork requirements for licensure or certification.

Q. How long is a Limited Permit valid?

A. A limited permit is valid for four* months from the date of application with the Board or upon failing the NBCOT examination, whichever occurs first.

** There are pending regulatory amendments affecting the limited permit. Once final, a limited permit will be valid for three months from the date of issuance by the Board or upon failing the examination, or two (2) weeks following the expiration of the applicants' eligibility test period, whichever occurs first.

Q. May an OT or OTA Limited Permit (LP) holder treat a patient/client without a documented OT treatment plan?

A. No.

Q. How often must occupational therapy services provided by the OT/LP be reviewed by the supervising OT?

A. CCR 4183(a) requires all documented client-related services by the limited permit holder or student shall be reviewed and cosigned by the supervising occupational therapist.

Q. How often must occupational therapy services provided by the OTA/LP be reviewed by the supervising OT?

A. Section 4181(a)(1) of the California Code of Regulations (CCR) states:

Appropriate supervision of an occupational therapy assistant includes, at a minimum:
The weekly review and inspection of all aspects of occupational therapy services by the supervising occupational therapist. (Weekly review should occur once each calendar week.)

Section 4181(a)(4) also requires the supervising occupational therapist to provide periodic on-site supervision and observation of the assigned client care rendered by the occupational therapy assistant. Periodic review is defined in Section 4180(e) as at least once "every 30 days."

Section 4183(b) also requires all documented client-related services by the limited permit holder or student shall be reviewed and cosigned by the supervising occupational therapist.

Based upon the supervisor /supervisee working relationship and the type of services that are being supervised, the supervising OT may chose either of these or more frequently, as he/she determines is appropriate to the needs of the client.

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

A. Yes. The OT/LP may perform an initial evaluation, make assessments and develop a plan of care under the supervision of a licensed occupational therapist.

CCR Section 4183(b) requires that documented client-related services by a limited permit holder shall be reviewed and cosigned by the supervising occupational therapist.

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

A. The OTA/LP 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.

The OTA/LP may perform re-assessment or and discharge plans of care under the supervision of an OT providing that the OT reviews and interprets the information provided by the OTA/LP and integrates that information into the decision-making process. The supervising OT and OTA/LP must co-sign the plan of care.

CCR Section 4183(b) requires that documented client-related services by a limited permit holder shall be reviewed and cosigned by the supervising occupational therapist.

Q. Can an OT/LP obtain advanced-practice approval in hand therapy, physical agent modalities or Dysphagia?

A. No. In order to apply for advanced-practice certification, individuals must first become licensed.

Q. Can an OTA/LP obtain advanced-practice approval in hand therapy, physical agent modalities or swallowing Dysphagia?

A. No. Advanced Practice certification is only available to licensed occupational therapists who have demonstrated to the Board that he/she has met the Board's post professional education and training requirements.

Q. Can an OT/LP provide advanced practice treatment and/or modalities?

A. Yes, however, the OT/LP must be supervised by an OT who has been approved by the Board in the appropriate advanced practice area. The supervising OT and the OT/LP must have a written supervision agreements as outlined in CCR Section 4154(c)(1). In addition, the OT/LP may only perform these supervised advanced practice services if the OT/LP is actively attempting to acquire post-professional on-the-job training and supervision pursuant to the written supervisor agreement outlined in CCR Section 4154(e)(1).

Q. Can an OTA/LP provide advanced practice treatment and/or modalities?

A. Yes, however, the OTA/LP must be supervised by an OT has been approved by the Board in the appropriate advanced practice area.

Q. Can an OT/LP supervise OTAs?

A. An OT/LP may not act in a supervisory capacity.

Q. Can an OT/LP supervise students?

A. No.

Q. Can an OTA/LP supervise students?

A. No.

Q. Can Limited Permit holders supervise an OT aide?

A. Yes, when the aide is performing any task that is not client-related.

CCR Section 4180(d) defines "non-client related tasks" as clerical, secretarial and administrative activities; transportation of patients/clients; preparation or maintenance of treatment equipment and work area; taking care of patient/client personal needs during treatments; and assisting in the construction of adaptive equipment and splints.

An OT aide, who provides supportive services to the OT and OTA, must be trained by an OT or OTA to perform specifically delegated tasks. An aide must first demonstrate competence to be able to perform the assigned, delegated client and non-client tasks. The OT is responsible for the overall use and actions of the aide.

Frequently Asked Questions Regarding Supervision of
OT and OTA Students

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

A. No. However, the student may participate in developing the treatment plan with the supervising OT. The supervising OT and student must co-sign the treatment plan.

NOTE: Please be aware of your fiscal intermediary requirements.

Q. What kind of services can be provided by a Student?

A. CCR 4183(a) allows Level II Students to be assigned duties or functions commensurate with his or her education and training.

NOTE: Please be aware of your fiscal intermediary requirements.

Q. How often must occupational therapy services provided by a student be reviewed by the 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 all OT and OTA students to be designated by a title that clearly indicates his/her status as a student or trainee.

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

A. Yes. The OT/S may perform an initial evaluation, make assessments and develop a plan of care under the supervision of a licensed occupational therapist. The supervising occupational therapist and student must co-sign the plan of care.

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

A. The OTA/S 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.

An OTA/S 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. The OT and OTA/S must co-sign the plan of care.

Q. Can an OT/S obtain advanced-practice approval in hand therapy, physical agent modalities or Dysphagia?

A. No. Advanced Practice certification is only available to licensed occupational therapists who have demonstrated to the Board that he/she has met the Board's post professional education and training requirements.

Q. Can an OTA/S obtain advanced-practice approval in hand therapy, physical agent modalities or Dysphagia?

A. No. Advanced Practice certification is only available to licensed occupational therapists who have demonstrated to the Board that he/she has met the Board's post professional education and training requirements.

Q. Can an OT/S supervise an OT aide or a volunteer?

A. An OT/S Level II may supervise an OT/S Level I or an OTA/S, and aides performing non-client related tasks.

Q. Can an OTA/S supervise students?

A. An OTA/S Level II may supervise OT Level 1, an OTA/S Levels 1 and 2, and aides performing non-client related tasks.