I think that it is a good idea to have COTA licensure.  The only difficulty that I am having within my practice is the stipulation that every COTA note has to be cosigned by a licensed OTR.  I work in acute care and it becomes quite difficult to track down every chart (we have paper documentation) and sign the note.  I spend quite a bit of time out of my day away from patient care to abide by the rules/regs.  Many times the patient will be discharged from the facility and I will have to go to medical records and have the item pulled for me to sign.  After the note is signed then the medical records staff have to rescan the document and update the patients file.  I agree that there has to be routine/everyday communication between the OTR and the COTA.  What we have found useful/acceptable is to have the note signed at least every 10 visits or 30 days whichever comes first.  However we have ensured that every note is signed despite the above.  In our hospital we have also made sure that the OTR who evaluates the patient writes whether or not the patient is appropriate for COTA treatment.