I have been a practicing COTA in Virginia since 1995.  I currently work in the Roanoke County School system.  I  have concerns regarding the wording of Section D under the  proposed COTA supervision guidelines.  My concern is with the wording that  includes "other notes" to be reviewed and signed by the OTR within 10 days.  Since most COTA's complete daily therapy notes on each client, this would require supervision on each client almost weekly.  It is understandable for evaluation material to be completed with the supervision of the OTR and signed within a ten day frame period, but would be significantly more restrictive than the guidelines set forth by AOTA requiring supervision of a COTA's treatment and the signing off of their notes every tenth visit or thirty days.  This would cause a significant increase in time spent performing supervision and decrease the viability of COTA's  in general.  I would ask that this section and wording be reconsidered to ensure that licensed COTA's can continue to perform the skills that they have been trained to do efficiently.