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.

Co-signing every note is not an unreasonable requirement and time-commitment when there is computerized documentation.  However, when all you have is a paper chart that is utilized by all disciplines and services in an acute care hopsital and medical status and discharge status can rapidly change 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 support direct OTA supervision to foster improved patient care; however, I believe cosigning every note is unnecessary.  I recommend that OTA notes should be cosigned 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, not every time a OTA documents on a patient.  By rewording this section, more time can be spent on direct patient care instead of searching for charts.  Thank you for your consideration in this matter.