I am the Lead OT for Roanoke City Public Schools. There are 3 OTRs including myself who work with and supervise 2 COTA/Ls in over 20 schools.  I am writing to express my concern with wording in the proposed regulations re: licensure of Occupational Therapy Assistants.  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 Therapist shall review and countersign within 10 days of such information being recorded".  My concern is with the specific wording of "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", as this proposal indicates a more restrictive level of supervision than required by current regulations.  COTA/ OTR supervisory visits have been changed from every 5th COTA visit or 21 calendar days to every 10th COTA visit or 30 calendar days, whichever comes first.  Therefore, the requirements for countersigning by the OTR should correlate to the same timeframe.  More specifically, the wording "other notes on patient care performed by the assistant" is extremely vague and could entail any notes or documentation which would ultimately require the OTR/ COTA to meet more frequently and in a manner that is not consistent with the current requirements, nor is this feasible, reasonable or necessary for quality patient care. I strongly recommend that the wording, "other notes on patient care performed by the assistant", be removed from the proposed regulations.