Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Medicine
 
chapter
Regulations for Licensure of Occupational Therapists [18 VAC 85 ‑ 80]
Action Licensure of occupational therapy assistants
Stage Proposed
Comment Period Ended on 8/7/2009
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7/28/09  3:07 pm
Commenter: Pam Jones

COTA Supervision Requirements
 
 My concern is regarding sections B & D of the Delegation to OT topic.  Section B states that supervision should take place at least once every 10th TX or every 30 days, whichever occurs first.  Section D states that documentation recorded by a COTA should be reviewed and cosigned within 10 days of the documentation being done.  While the length of time between supervision as been increased from once every 5th visit or 21 days, the time between co-signing of documentation has been decreased to occur within 10 days of said documentation.  It seems to me that under the new guidelines, even though the time between required supervision has been increased, the fact that the co-signing requirements are now within 10 days, supervision will actually occur more often than was done previously as well as more often than is required in section B.  The two requirements appear to contradict each other rather than promoting more streamlined, efficient, and cost-effect methods of supervision.  Please review and considering rewording the two requirements.
 
Thank you.
 
CommentID: 9387