Thank you for the opportunity to comment on proposed legislation 18VAC-85-110.  I am happy the state has passed licensure for COTAs.  I am concerned about  Section D requiring all notes to be co-signed by an OTR/L.  I am in support that COTA/Ls and OTR/Ls need to be in communication to provide the best patient care possible.  I feel its appropriate requiring co-signature when a COTA/L assists with information on an evaluation, re-evaluation and at discharge.   I feel it places an unnecessary burden on the OTR/L that supervises and the agency that hires COTA/Ls to require every note to be co-signed. COTA/Ls have successfully completed a degree program and have passed a national exam qualifying them for this position.  The state also mandated letters of recommendations when applying for licenses.  COTA/Ls are professionals and should be held to the same high standards that LPTAs are held.  By placing more stringent regulations won't increase good patient care but decreases the time OTR/Ls have to provide for patient care.  If passes as is, this regulation could jepardize jobs and careers for COTA/Ls.