As Pediatric Manager in our facility, we have both OT and PT assistants.  I have reviewed the new regulations re licensure of OT assistants.  My one concern is about the wording of Section D under Supersvisory responsiblities of an OT.  The way it is currently worded, the OT assistant would document  ".......notes on patient care performed by the assistant, and the superivising occupational therapist shall review and countersign within 10 days of such information being recorded." The first part of the statement is regarding aspects of the initial evaluation, treatment plan or discharge summary which the OT assistant may have participated in.  It makes sense for those activities to be countersigned quickly by the OTR/L.  We provide OT in clinic, in multiple school systems, in early intervention and the feasibility of having each note countersigned by the OTR/L within ten days would not be feasible.  This is MORE restrictive than the current supervision.  With the new regulation supervision would happen every 10th visit or 30 days whichever came first.  The language in secion D referenced above states that ".. The occupational therapy assistant shall document in the patient record.....or other notes on patient care performed by the assistant, and the supervising OT shalll reveiw and countersign within 10 days of such information being recorded."  Was this the intent of this statement or should the 10 days apply to activities which the OT assistant performed related to evaluation and/or discharge?  Please consider changing this wording.The current wording will be a huge burder to health care providers, school therapists and may affect the use of COTA's by therapy practices and school systems.  Thank you for your attention to this concern of mine.

I am an OT who works within a variety of settings including outpatient pediatrics, early intervention, and school systems.  I have been responsible for supervising COTA's in these environments and would like to address a concern about the wording of 18VAC85-80-110 Section D.  It reads "The Occupational Therapy assistant shall document in the patient record any aspects of the initial evaluation, treatment plan, dischagre summary, or other notes performed on patient care performed by the assistant, and the supervising occupational therapist shall review and countersign within 10 days of such information being recorded."  I am concerned about the wording of the bold section.  Realistically if the frequency of meeting with COTA's is begin decreased to once every 10th visit or every 30 days, then the signing of the notes for daily visits should be in accordance to this timeline as well.  Please consider seperating the countersigning of daily notes from the signing of evaluation, treatment plan, and discharge information.  Thank you for your attention to this matter.

I have been a practicing COTA in Virginia since 1995.  I currently work in the Roanoke County School system.  I  have concerns regarding the wording of Section D under the  proposed COTA supervision guidelines.  My concern is with the wording that  includes "other notes" to be reviewed and signed by the OTR within 10 days.  Since most COTA's complete daily therapy notes on each client, this would require supervision on each client almost weekly.  It is understandable for evaluation material to be completed with the supervision of the OTR and signed within a ten day frame period, but would be significantly more restrictive than the guidelines set forth by AOTA requiring supervision of a COTA's treatment and the signing off of their notes every tenth visit or thirty days.  This would cause a significant increase in time spent performing supervision and decrease the viability of COTA's  in general.  I would ask that this section and wording be reconsidered to ensure that licensed COTA's can continue to perform the skills that they have been trained to do efficiently.

 

As an experienced COTA working in the public schools I was very excited to hear that Virginia has agreed to license OTA's. However, I am concerned that we are taking one step forward and two steps backwards with the wording of the proposed 18VAC85-80-110 Section D. It reads:The occupational 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. The phase "or other notes on patient care performed by the assistant"  would include daily notes performed by the OTA. This is more restrictive then it was before the licensure as the new proposal states the supervising OTR would need to sign within 10 days. Since supervison is occuring once every 10th visit or every 30 days all notes should be signed then. Daily notes should be separated from the other areas listed on the proposal. OTA's are valuable to the practice of Occupational Therapy, and this proposal could jeapordize their  jobs. Please consider rewording this proposal.

18VAC85-80-110  Supervisory responsibilities of an occupational therapist.  Section B states that supervision is to occur "at  least every tenth session or 30 calendar days".  Section D states that the supervising therapist must  "review and countersign within 10 days recordings" in the patient record.  If you have to countersign a note within 10 days then you have to provide supervision at that time.  This would be very difficult to acheive in a school setting.  Please consider documentation by the suprevising OTR every 30 days or 10th visit that supervision has occured.

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I am a pediatric Occupational Therapist with 23 years experience and supervisor of two COTA/Ls in the public school system, serving over 10 schools and 120 students. 

I am very concerned about the wording under 18VAC85-80-110 Section D.  where it states , “ The Occupational 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 therapists shall review and countersign within 10 days of such information being recorded.  

The bolded portion is of great concern as this is more restricting than the current regulation. The supervisory visits have been changed from every 5^th visit or 21 days to every 10th visit or every 30 calendar days whichever comes first, thus the countersigning should follow that timeframe as well. The statement including “other notes” is vague and implies any patient documentation which could be daily, weekly, etc.

The requirement of countersigning “the other notes” every 10 days is not feasible as this would mean that the COTA/L and OTR/L would need to meet every week for note cosigning. This does not follow the regulation timeline for supervision stated above. This is not feasible and not necessary for good patient care. High caseloads, travel time, different office location and in house documentation requirements are just a few impacting factors to consider, especially for those who do not work in the same facility.

I strongly urge that the wording of or other notes on patient care performed by the assistant be removed from the regulation VAC85-80-110 section D.

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I am the Lead OT for Roanoke City Public Schools. There are 3 OTRs including myself who work with and supervise 2 COTA/Ls in over 20 schools.  I am writing to express my concern with wording in the proposed regulations re: licensure of Occupational Therapy Assistants.  Under 18VAC85-80-110 Section D, where it states,“ The Occupational 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".  My concern is with the specific wording of "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", as this proposal indicates a more restrictive level of supervision than required by current regulations.  COTA/ OTR supervisory visits have been changed from every 5th COTA visit or 21 calendar days to every 10th COTA visit or 30 calendar days, whichever comes first.  Therefore, the requirements for countersigning by the OTR should correlate to the same timeframe.  More specifically, the wording "other notes on patient care performed by the assistant" is extremely vague and could entail any notes or documentation which would ultimately require the OTR/ COTA to meet more frequently and in a manner that is not consistent with the current requirements, nor is this feasible, reasonable or necessary for quality patient care. I strongly recommend that the wording, "other notes on patient care performed by the assistant", be removed from the proposed regulations.

While we are grateful to have the OTAs licensed in the state of Virginia, it seems that the regulations are more restrictive than seems appropriate.   As both a treating clinician as well as a clinical manager of therapists and therapy assistants in acute care, inpatient rehabilitation, and outpatient rehabilitation, OTAs are an essential part of the rehabilitation team in today’s healthcare system.   What is disconcerting is the wording in 18VAC85-80-110 D “The occupational 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.”   Please consider changing this requirement.  If the OT and OTA are following 18VAC85-80-110 B and meeting and discussing  every 10^th treatment session or 30 days, then I do not understand the need for the co-signature on every note.  The current wording/regulation has been burdensome and costly to health care providers in the last 6 months without offering any benefits to patient-care.  In fact it may even be taking away from patient care by the supervising OTs because more time needs to be spent reviewing and signing notes.  Could it be enough that the communication requirement above be documented?  If the OTAs do participate in the initial assessment and/or discharge assessment I do think it is reasonable to ask for a co-signature.  My fear with the current wording is that it may be less cost effective in the end to employ these fine clinicians.  Thank you for considering a change.

My comment is on this particular statement: 

The occupational 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.

Providing excellent quality patient care is my and my facility's priority.  In supporting OTA licensure, I wanted to provide these highly trained persons with increased autonomy and individuality.  We provide patient care in hospital acute care, inpatient rehab, outpatient rehab, and day rehab.  We document both via computerized documentation in our inpatient rehab, outpatient rehab and day rehab and on paper in acute care.  Co-signing every note is not an unreasonable requirement and time-commitment when there is computerized documentation, but when all you have is a paper chart that is utilized by all disciplines and services in an acute care hopsital and medical status and discharge status is always rapidly changing all hours of the day, an excessive burden lies on the primary OT, and patient care is compomised as a result of this time consuming responsibility.  I support direct OTA supervision to foster improved patient care; however, I believe cosigning every note is unnecessary.  I recommend that OTA notes should be cosigned everytime they are documenting on the patient's initial evaluation, re-evaluation, and discharge evaluation and every 10th treatment visit or 30 days, whichever comes first, not every time a OTA documents on a patient.

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.

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.    

My comments are brief.  I disagree with the decision that all COTA/L notes need to be signed.  I do think that signing re-evals is a good idea to keep communication of the patient and treatment open.  Please reconsider. 

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.

As a COTA in the state of VA for the past 20 years, I am concerned with the wording in 18VAC85-80-110D.  Please consider changes to this requirement.  The current need for daily cosignatures creates more paperwork and less time for patient care. I agree with cosignatures for information in the evaluation, discharge, and treatment plan, but as a healthcare professional, do not think daily signatures are necessary.

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!

My comment is on this particular statement: 

The occupational 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.

In supporting OTA licensure, it is important to have documented communication between staff to maintain excellent patient care.  However, as an OT  from an acute care environment I believe that the above bolded text should be modified. In the acute care setting we document on paper charts which are utilized by all disciplines and services. With rapidly changing medical and discharge status all hours of the day, an excessive burden lies on the primary OT, and patient care is compomised as a result of this time consuming responsibility. I believe cosigning every time an OTA doucments on a patient is unnecessary.  A possible solution to this problem would be to cosigned OTA notes everytime they are documenting on the patient's initial evaluation, re-evaluation, and discharge evaluation and every 10th treatment visit or 30 days, whichever comes first. Thank you for considering this perspective and the suggested option.

My comment is on this particular statement:

The occupational 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.

Co-signing every note is not an unreasonable requirement and time-commitment when there is computerized documentation.  However, when all you have is a paper chart that is utilized by all disciplines and services in an acute care hopsital and medical status and discharge status can rapidly change all hours of the day, an excessive burden lies on the primary OT, and patient care is compomised as a result of this time consuming responsibility.  I support direct OTA supervision to foster improved patient care; however, I believe cosigning every note is unnecessary.  I recommend that OTA notes should be cosigned everytime they are documenting on the patient's initial evaluation, re-evaluation, and discharge evaluation and every 10th treatment visit or 30 days, whichever comes first, not every time a OTA documents on a patient.  By rewording this section, more time can be spent on direct patient care instead of searching for charts.  Thank you for your consideration in this matter.

As an employer of occupational therapists and occupational therapy assistants, I am pleased that the OTA's in Virginia are now licensed.  I am writing to express my concern about the requirement for an OT co-signature on each note written by an OTA.  This regulation seems over burdensome, especially in light of the requirements for communication betwen the OT and OTA on a regular basis.  It seems that documentation of the communication required (every 10th treatment of 30 days) and co-signatures on any initial assessments or discharge summaries to which an OTA has contributed could provide appropriate documentation of oversight.  I respectfully request that you consider changing the co-signature requirement.

Thank you -

Shawne E. Soper, PT, DPT

Director of Contract Services

Sheltering Arms

Thank you for the opportunity to comment on proposed legislation 18VAC-85-110.  I am happy the state has passed licensure for COTAs.  I am concerned about  Section D requiring all notes to be co-signed by an OTR/L.  I am in support that COTA/Ls and OTR/Ls need to be in communication to provide the best patient care possible.  I feel its appropriate requiring co-signature when a COTA/L assists with information on an evaluation, re-evaluation and at discharge.   I feel it places an unnecessary burden on the OTR/L that supervises and the agency that hires COTA/Ls to require every note to be co-signed. COTA/Ls have successfully completed a degree program and have passed a national exam qualifying them for this position.  The state also mandated letters of recommendations when applying for licenses.  COTA/Ls are professionals and should be held to the same high standards that LPTAs are held.  By placing more stringent regulations won't increase good patient care but decreases the time OTR/Ls have to provide for patient care.  If passes as is, this regulation could jepardize jobs and careers for COTA/Ls.

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.