My comment is on this particular statement: 

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.

In supporting OTA licensure, it is important to have documented communication between staff to maintain excellent patient care.  However, as an OT  from an acute care environment I believe that the above bolded text should be modified. In the acute care setting we document on paper charts which are utilized by all disciplines and services. With rapidly changing medical and discharge status all hours of the day, an excessive burden lies on the primary OT, and patient care is compomised as a result of this time consuming responsibility. I believe cosigning every time an OTA doucments on a patient is unnecessary.  A possible solution to this problem would be to cosigned OTA notes everytime they are documenting on the patient's initial evaluation, re-evaluation, and discharge evaluation and every 10th treatment visit or 30 days, whichever comes first. Thank you for considering this perspective and the suggested option.