Thank you for the opportunity to comment.  I am thrilled that OTAs are now licensed in the State of Virginia.  We had hoped that this licensure would actually demonstrate to the public that OTAs are qualified, educated, and provide great care to clients.  However, when the temporary regulations came out, we found them to be more restrictive for the OTA than when they were certified.  In our acute care setting, we have found the statements under 18VAC85-80-110 Section D to be more burdensome for the OTs and the OTAs as it relates to co-signatures.  Please consider allowing the documentation that the "plan of care has been discussed between the OT and the OTA" to be sufficient to meet the needs of Section D, rather than requiring the OT to physically be present to co-sign the note.  In our setting the OT and OTA are conversing each day regarding the patients, to then ask them to co-sign the notes as well, becomes overly burdensome for the OTs.  Please consider revising Section D.  Thank you!