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I am a pediatric Occupational Therapist with 23 years experience and supervisor of two COTA/Ls in the public school system, serving over 10 schools and 120 students. 

I am very concerned about the wording under 18VAC85-80-110 Section D.  where it states , “ 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 therapists shall review and countersign within 10 days of such information being recorded.  

The bolded portion is of great concern as this is more restricting than the current regulation. The supervisory visits have been changed from every 5^th visit or 21 days to every 10th visit or every 30 calendar days whichever comes first, thus the countersigning should follow that timeframe as well. The statement including “other notes” is vague and implies any patient documentation which could be daily, weekly, etc.

The requirement of countersigning “the other notes” every 10 days is not feasible as this would mean that the COTA/L and OTR/L would need to meet every week for note cosigning. This does not follow the regulation timeline for supervision stated above. This is not feasible and not necessary for good patient care. High caseloads, travel time, different office location and in house documentation requirements are just a few impacting factors to consider, especially for those who do not work in the same facility.

I strongly urge that the wording of or other notes on patient care performed by the assistant be removed from the regulation VAC85-80-110 section D.

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