Thank you for the opportunity to comment on the new regulations regarding OTA licensure.  I am a Director of Rehab for an acute care hospital and would like to address a concern with the wording of  18VAC85-80-110 Section D, specifying  "other notes on patient care performed by the assistant".  With the new regulations for the elevated status of licensure for OTAs, there seem to be, in my opinion,  unnecesary requirements for daily co-signatures by the Occupational Therapists.  This co-signature in a hospital setting is extremely burdensome for the Occupational Therapists and is actually taking valuable time away from our patients.   Staffing patterns and ratios have been effected by this stringent requirement, which I do not believe was the intention of the change in regulation.   I do feel that  opportunities for communication are essential and that the co-signatures at the 10th treatment session or at the 30 day mark do allow for this oversight and communication.   My OTA staff already have the opportunity to discuss their patients with the primary OT via telephone if there are any questions regarding the patient or the plan of care.  They are adequately trained and can follow the specified plan of care as directed by the OT.  I am also in support of and do feel it is appropriate for co-signatures to be required for the initial evaluations and discharges in which the OTA are involved in.  I would ask that the regulations be changed to reflect this.  Thank you for considering my comments.