While we are grateful to have the OTAs licensed in the state of Virginia, it seems that the regulations are more restrictive than seems appropriate.   As both a treating clinician as well as a clinical manager of therapists and therapy assistants in acute care, inpatient rehabilitation, and outpatient rehabilitation, OTAs are an essential part of the rehabilitation team in today’s healthcare system.   What is disconcerting is the wording in 18VAC85-80-110 D “The occupational therapy assistant shall document in the patient record any aspects of the initial evaluation, treatment plan, discharge summary or other notes on patient care performed by the assistant, and the supervising occupational therapist shall review and countersign within 10 days of such information being recorded.”   Please consider changing this requirement.  If the OT and OTA are following 18VAC85-80-110 B and meeting and discussing  every 10^th treatment session or 30 days, then I do not understand the need for the co-signature on every note.  The current wording/regulation has been burdensome and costly to health care providers in the last 6 months without offering any benefits to patient-care.  In fact it may even be taking away from patient care by the supervising OTs because more time needs to be spent reviewing and signing notes.  Could it be enough that the communication requirement above be documented?  If the OTAs do participate in the initial assessment and/or discharge assessment I do think it is reasonable to ask for a co-signature.  My fear with the current wording is that it may be less cost effective in the end to employ these fine clinicians.  Thank you for considering a change.