I am an occupational therapist with over 12 years of experience, primarily in pediatrics.  Working in a variety of settings I find that the proposed regulations would be very limiting for COTA's.  Under section 18VA85-80-110 Supervisory responsibilities of an occupational therapist section 4-D it is stated "The occupaitonal 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."  Having every treatment note countersigned would be even more limiting than the current regulations.  This would make it very difficult for OT assistants to continue to work in any setting.  Please reconsider this statement.  Thank you for your time in this manner.