As Pediatric Manager in our facility, we have both OT and PT assistants.  I have reviewed the new regulations re licensure of OT assistants.  My one concern is about the wording of Section D under Supersvisory responsiblities of an OT.  The way it is currently worded, the OT assistant would document  ".......notes on patient care performed by the assistant, and the superivising occupational therapist shall review and countersign within 10 days of such information being recorded." The first part of the statement is regarding aspects of the initial evaluation, treatment plan or discharge summary which the OT assistant may have participated in.  It makes sense for those activities to be countersigned quickly by the OTR/L.  We provide OT in clinic, in multiple school systems, in early intervention and the feasibility of having each note countersigned by the OTR/L within ten days would not be feasible.  This is MORE restrictive than the current supervision.  With the new regulation supervision would happen every 10th visit or 30 days whichever came first.  The language in secion D referenced above states that ".. The occupational therapy assistant shall document in the patient record.....or other notes on patient care performed by the assistant, and the supervising OT shalll reveiw and countersign within 10 days of such information being recorded."  Was this the intent of this statement or should the 10 days apply to activities which the OT assistant performed related to evaluation and/or discharge?  Please consider changing this wording.The current wording will be a huge burder to health care providers, school therapists and may affect the use of COTA's by therapy practices and school systems.  Thank you for your attention to this concern of mine.