Question: I am a PT director of rehabilitation services and have some questions concerning the OTA whom I have on staff doing reassessments and making clinical decisions concerning the plan of care, writing progress notes, and making recommendations.
Is it in the occupational therapy practice act and within the scope of practice for an OTA to do a formal reassessment, write the progress note to the physician, and make the clinical decisions of whether to discharge the patient, continue with the patient, or change the patient’s plan of care?
Answer: As a first step, check the state licensure law to see what language may exist related to OTA scope of practice and supervision requirements. Some states are quite specific, but others are fairly general. In addition, two AOTA official documents (which reflect professional standards but do not have the legal force of a state practice act or regulations) can provide helpful guidance: The Guidelines for Supervision, Roles, and Responsibilities During the Delivery of Occupational Therapy Services and the Standards of Practice for Occupational Therapy. The first provides guidance about decision making for appropriate delegation and levels of supervision, and the second delineates the role of the OT vs. the OTA. Of course, the Occupational Therapy Code of Ethics also includes language about competency, working within applicable regulations, and scope of practice, as well as supervision (see Principle 5).
Only OTs can evaluate (they can delegate selected assessments to the OTA based on competency and if permitted by state law, but the OT is responsible for developing the plan of care, goals, etc.), change the plan of care, make recommendations, and discharge the patient. OTAs always work under the supervision of an OT although they can treat and document independently and contribute to the progress note, evaluation (as noted above), re-evaluation, and discharge plan; again, if permitted by state law and other applicable regulations.