I have concerns regarding the wording of sections B and D under 18VAC85-80-110.  Section B states that supervision is to occur "at least every tenth treatment or 30 calendar days."  Section D states that the supervising OTR must review and countersign all documentation done by the COTA within ten days.  In order to co-sign documentation, the supervising OTR would have to provide supervision at that time.  These two requirements appear to be confusing and contradictory of each other.  It would be very difficult to provide the needed supervision, in order to countersign notes/ documentation every 10 days, in a school system.  It is not necessary for good patient care in school settings.   It would also be inefficient,  considering high caseloads, travel time, varying locations of treatment settings, and varying documentation requirements between different schools/ school systems.

Please consider reviewing these requirements and revising them to require documentation by the supervising OTR every 30 days or tenth visit. 

Thank you for your consideration of this matter.