As an employer of occupational therapists and occupational therapy assistants, I am pleased that the OTA's in Virginia are now licensed.  I am writing to express my concern about the requirement for an OT co-signature on each note written by an OTA.  This regulation seems over burdensome, especially in light of the requirements for communication betwen the OT and OTA on a regular basis.  It seems that documentation of the communication required (every 10th treatment of 30 days) and co-signatures on any initial assessments or discharge summaries to which an OTA has contributed could provide appropriate documentation of oversight.  I respectfully request that you consider changing the co-signature requirement.

Thank you -

Shawne E. Soper, PT, DPT

Director of Contract Services

Sheltering Arms