AOTA Approved Provider Program: Compliance Policies and Procedures

Annual reports, due at the end of each annual reporting term, provide an overview of the previous year’s providership activities and compliance status. The following outlines the process for managing annual report compliance, including submission requirements, late fees, and consequences of non-compliance, such as potential revocation of provider status.

• Legacy Providers (providers approved before December 31, 2019) must submit their annual report by September 30th each year.
• Post-2020 Providers must submit their annual report on their annual approval anniversary date minus 1 day.

AOTA Approved Providers have a 30-day grace period after the due date to submit their report without facing penalties.

Procedure:

1. Annual Report: Initial Submission

• If the report is not received within 30 days of the due date, providers will receive an email notification and a late fee will be added to the account.
• Failure to submit the report within 45 days of the due date will result in the suspension of the provider’s APP recognition status, which will prevent the processing of PD activity applications.
• If the report is not submitted within 60 days, the provider will receive additional communication and an additional late fee will be applied.
• Failure to submit the report within 90 days will result in an additional late fee and an official letter outlining the revocation process and timeline.
• If the annual report is not submitted within 120 days, the APP will send a formal USPS letter outlining the process and timeline for revocation of the provider’s recognition status if compliance is not achieved.

1. Annual Report: Clarification Request for Additional Information

Upon submission of the annual report, the APP will conduct a review to identify any areas of non-compliance.

• If areas of non-compliance are not resolved within 45 days of submission, the provider will receive a reminder from the APP outlining the need to submit clarifications.
• If the non-compliance issues remain unresolved within 90 days of submission, the APP will issue a reminder of the outstanding issues and the need for prompt resolution.
• If the areas of non-compliance are still not resolved within 120 days of the original submission date, the APP will send a formal letter outlining the process and timeline for revocation of the provider's recognition status if compliance is not achieved.

Providers wishing to continue in the AOTA Approved Provider Program after their 7th year must complete a 7-Year Renewal application. The following defines the process for managing the renewal, including submission requirements, late fees, and potential consequences of non-compliance, such as discontinuation or revocation of provider status.

• Legacy Providers (approved before December 31, 2019) must submit their annual renewal at the end of their 7th year on September 30th.
• Post-2020 Providers are on a 12-month cycle, with their renewal due at the end of their 7th year, on their anniversary date minus 1 day.

If a provider wishes to terminate their Applicant Agreement and voluntarily withdraw from the AOTA Approved Provider Program (APP), they must notify the APP at least 30 days before the end of their Recognition Term. If advance notice is not received, the provider will be expected to submit a renewal application. AOTA Approved Providers are granted a 30-day grace period after the renewal due date to submit their application without penalty.

Procedure:

• If the renewal is not received within 30 days of the due date, the provider will receive an email notification.
• Failure to submit the renewal within 45 days of the due date will result in the suspension of the provider’s APP recognition status, which will prevent the processing of PD activity applications. A renewal late fee will also be applied to the account.
• If the report is not submitted within 60 days, the provider will receive additional communication, and an additional late fee will be applied.
• Failure to submit the renewal within 90 days will result in an additional late fee and an official letter outlining the revocation process and timeline.
• If the renewal is not submitted within 120 days, the APP will send a formal USPS letter outlining the process and timeline for revocation of the provider’s recognition status if compliance is not achieved.

1. Renewal: Clarification Request for Additional Information

Upon submission of the renewal, the APP will conduct a review to identify any areas of non-compliance.

• If areas of non-compliance are not resolved within 45 days of submission, the provider will receive a reminder from the APP outlining the need to submit clarifications.
• If the non-compliance issues remain unresolved within 90 days of submission, the APP will issue a second reminder and the need for prompt resolution.
• If the areas of non-compliance are still not resolved within 120 days of the original submission date, the APP will send a formal letter outlining the process and timeline for revocation of the provider’s recognition status if compliance is not achieved.

The AOTA Approved Provider Program (APP) is committed to safeguarding occupational therapy practitioners (OTPs) by upholding rigorous standards for all professional development (PD) activities that qualify for AOTA CEUs. To enable AOTA to effectively monitor compliance and support providers, an annual fee is required.

Legacy Providers (approved before December 1, 2019) must pay their annual fees by October 1st each year. Providers approved after January 1, 2020, must pay their annual fee on the yearly anniversary of their approval date.

Procedure:

1. Late Fees. If the annual fee is not paid on time, a $35 late fee will be applied. An additional $35 late fee will be charged every 30 days until payment is made.
   
   
2. Revocation. If payment is still not received within 90 days, the provider will receive a formal letter outlining the specific date by which their approval status will be revoked if payment is not made. Upon revocation, the provider will receive formal notice, via email and USPS mail, of revocation and will no longer be recognized under the APP. During this time, the provider will be given 30 days to remove any references to AOTA’s Approved Provider status, including the AOTA name, logo, and CEU designation ('Marks'), from all promotional materials and PD activities. No previously paid APP fees will be refunded or prorated.
   
   
3. Collections. Even in the event of revocation, fees paid will not be prorated or refunded. If the fee remains unpaid, it will be forwarded to collections for further action.

An audit of a provider’s PD activity or activities may occur at random or when a concern is raised related to an activity’s non-compliance with the APP Criteria and Guidelines. Concerns may be identified by various parties, including but not limited to AOTA staff, volunteer reviewers, recipients of PD activities, and OTPs.

Procedure:

A. Identifying Non-Compliance. To identify potential non-compliance with the APP Criteria and Guidelines, AOTA staff or designated volunteer reviewers may audit a PD activity in its entirety. This audit may include:

• A comparison of the PD activity application to the PD activity.
• An assessment of relevant artifacts, including but not limited to marketing materials, PD activity content, instructional aides, and resources, post-evaluations, learning outcome assessments, and summary evaluations.

B. Notification of Audit

1. Secondary to Complaint
   1. If a complaint prompts an audit, AOTA staff will notify the Approved Provider within 10 days of receiving the complaint or concern. The notification will inform the provider of the specific concern related to the PD activity and provide a timeframe for completing the audit. This timeframe will be determined by AOTA staff based on the audit’s scope, available staffing, and resources, ensuring that the audit is conducted and completed in a timely manner appropriate to the level of detail required.
   2. The provider must inform current and future PD activity participants that the PD activity is under review for compliance with Approved Provider Program Criteria and Guidelines.
   3. The provider may be asked to provide PD activity login information, relevant documentation and artifacts, such as marketing materials, PD activity content, instructional aides, and evaluation summaries, to facilitate the audit process.
   4. Within 30 days of the complaint, AOTA staff will assign an individual(s) to complete the audit of the PD activity.
2. Notification of Random Audit
   1. AOTA staff will notify the provider of an upcoming audit at least 10 days in advance. The notification will inform the provider of the timeframe for completing the audit. This timeframe will be determined by AOTA staff based on the audit’s scope, available staffing, and resources, ensuring that the audit is conducted and completed in a timely manner appropriate to the level of detail required.
   2. The provider may be asked to provide PD activity login information, relevant documentation and artifacts, such as marketing materials, PD activity content, instructional aides, and evaluation summaries, to facilitate the audit process.
   3. Within 30 days, AOTA staff will assign an individual(s) to complete the audit of the PD activity.

C. Auditing the PD Activity. Utilizing the approved AOTA APP Audit Template, the reviewer will clearly document the APP Criteria and Guidelines that were met and not met by the provider. When possible, supporting evidence, such as screenshots or documents, should be included.

D. Decision. Based on the audit, and within the timeframe indicated, AOTA staff will communicate the decision to the provider via email and USPS letter. The decision will include a written explanation detailing the reasons for the outcome and specifying each unmet criterion and guideline.

• Pass: All areas of the audit meet APP Criteria and Guidelines—continue to assign AOTA CEUs to the PD activity.
• Request for more information: Some areas of the audit do not meet APP Criteria and Guidelines.
  • Opportunity for Corrections: The provider will be given one opportunity to correct the areas of non-compliance within 30 days.
  • Review of Corrections: AOTA staff or volunteers will conduct a thorough review of the corrections to determine whether the non-compliance issues have been adequately corrected and meet APP Criteria and Guidelines.
    • Pass: All corrected areas meet APP Criteria and Guidelines:
    • Deny: All corrected areas do not meet APP Criteria and Guidelines. Immediately stop assigning AOTA CEUs to the PD activity, and must remove the AOTA name, logo, and CEU designation ('Marks'), from all the PD activity’s promotional materials. No previously paid APP fees will be refunded or prorated. APP staff will change the status of the activity to ‘Fail’ in the application management system.

E. Additional Concerns. If there are additional concerns about the provider’s other PD activities meeting the APP Criteria and Guidelines staff should follow SOP 308.

An audit of a provider may occur at random or when a concern is raised related to a provider’s general non-compliance (e.g., disclosures, certificates of completion) with the APP Criteria and Guidelines. Concerns may be identified by various parties, including but not limited to AOTA staff, volunteer reviewers, recipients of PD activities, and OTPs.

Procedure:

1. Notification of Audit

• AOTA staff will notify the provider of the audit within 10 days of its initiation, sending an email and USPS letter that detail the specific areas of concern.
• The audit will include a thorough review of selected artifacts from multiple PD activities to assess compliance with the specified area of concern.
• The provider may be asked to supply, within 7 days, access to relevant documentation and artifacts, such as marketing materials, instructional aids, and certificates of completion to support the audit process.

1. Audit Review Process

Within 30 days of receiving relevant documentation, a staff member or volunteer will be assigned to conduct the Provider Audit.

1. Decision

Based on the audit and within the timeframe provided, AOTA staff will communicate the decision to the provider via email and USPS letter. The decision will include a written explanation detailing the reasons for the outcome and specifying each unmet criterion and guideline.

• Pass: All areas of the audit meet APP Criteria and Guidelines—continue to assign AOTA CEUs to the PD activity.
• Request for more information: Some areas of the audit do not meet APP Criteria and Guidelines.
  • Opportunity for Corrections: The provider will be given one opportunity to correct the areas of non-compliance within 30 days.
  • Review of Corrections: The APP will conduct a thorough review of the corrections to determine whether the non-compliance issues have been adequately corrected and meet APP Criteria and Guidelines.
    • Pass: All corrected areas meet APP Criteria and Guidelines:

Probation: All corrected areas do not meet APP Criteria and Guidelines. Follow SOP 308.

Verification of non-compliance with APP Criteria and Guidelines may arise from any combination of annual report/renewal reviews and audits. Non-compliance may result in probation and revocation, and any provider who meets the criteria for probation a second time during their 7-year approval period will have their AOTA Approved Provider recognition status terminated.

Potential non-compliance indicators include:

• Repeated Non-Compliance: Patterns of recurring non-compliance with the same AOTA APP Criteria and Guidelines during the provider’s seven-year approval period, as documented in annual reports or renewal applications, PD activity audits, or Provider Audits. This includes the rejection and failure of Annual Reports and Renewal applications.
• False Information: Submission of inaccurate or misleading information on any application form, including initial applications, PD activity applications, reports, or renewal applications, or change-in-scope requests.
• Audit Findings: Repeated findings during audits of PD activities that indicate a failure to adhere to AOTA APP Criteria and Guidelines.
• Provider Audit: Evidence of non-compliance identified through various sources, including assessments of the provider’s website, promotional materials, or certificates of completion issued for PD activities.

Procedure:

• Notification and Probation. When repeated indicators of non-compliance are identified, AOTA staff will formally notify the provider. This notice, sent via email and USPS, will detail the areas of the areas of non-compliance and place the provider on probation. The notice will detail the indicators of non-compliance and outline the timeline of any additional investigation that will occur.
• Probationary Period. The provider will enter a 6-month probationary period and may not submit any new PD activities for approval during that time. Additionally, the provider is required to clearly indicate on their website that they are in probationary status. Throughout the probationary period, the provider is expected to address and resolve all identified issues to comply with APP Criteria and Guidelines.
• Corrective Plan. After all investigations are complete the provider will receive written notification via email and USPS mail detailing the areas of non-compliance found through additional investigation and will be required to submit a plan of correction within 30 days. The plan must include specific steps, timelines, and responsible parties for addressing and rectifying each issue. It must also include a timeline for ongoing follow-up communication indicating the provider’s progress toward compliance.
• Final Review. At the end of the probationary period, a final review will determine if the provider has achieved compliance.
• Revocation of Status. If the provider fails to resolve the non-compliance issues by the end of the probationary period, their APP recognition status will be revoked. The provider will receive formal notice, via email and USPS mail, of revocation and will no longer be recognized under the APP. During this time, the provider will be given 30 days to remove any references to AOTA’s Approved Provider status, including the AOTA name, logo, and CEU designation ('Marks'), from all promotional materials and PD activities.

Appeals Process:

• If the provider's recognition status is revoked, they may submit a written appeal to app@aota.org within 10 days of receiving the revocation notice. The appeal must include a clear explanation and supporting documentation addressing each area of previously identified non-compliance with the APP Criteria and Guidelines.
• Within 15 days of receiving the appeal, AOTA staff will assign an independent reviewer to evaluate the appeal and accompanying documentation to determine compliance with APP Criteria and Guidelines.
• Within 60 days of written notice of the appeal a final decision will be made and communicated to the provider, detailing reasons for upholding or denying the appeal. If the appeal is upheld, the provider may resume their APP recognized status with specific conditions as needed. If denied, the revocation will remain in effect, and no further appeals will be granted.

Re-application: Providers whose APP recognition status is revoked may reapply for Recognition as an AOTA Approved Provider after 180 days after the initial revocation or appeal has passed.

Refunds: No refunds or prorated fees will be issued in the case of probation and revocation.

Former providers may be eligible for reinstatement following revocation due to late submission of annual fees, reports, or renewal applications, or voluntary withdrawal from the program.

Procedure:

A. Eligibility for Reinstatement

If eligible, a former AOTA Approved Provider may request reinstatement of their Approved Provider Recognition Status within 90 calendar days of revocation or voluntary withdrawal. Reinstatement is available only to providers who meet one of the following criteria:

• AOTA APP Recognition status was revoked due to:
  • Late submission of annual fees
  • Late submission of annual reports
  • Late submission of renewal applications

OR

• Voluntarily withdrawal from the APP.

Providers whose recognition status was revoked for any other reason, or who exceed the 90-calendar-day reinstatement window, are not eligible for reinstatement and must submit a new Recognition as an AOTA Approved Provider application to re-enter the program.

If eligibility is confirmed, reinstatement may be granted provided all of the following conditions are met:

• Payment of Fees. All applicable nonrefundable reinstatement and outstanding fees must be paid in full.
• Submission of Outstanding Documentation. Any overdue annual report(s) or renewal application(s) must be submitted and must receive a “pass” decision upon review.
• Corrective Action Plan. If applicable, a written action plan must be submitted outlining the steps the provider will take to ensure timely submission of future reports, renewals, and payments.
• Timeline Compliance. All required materials must be submitted within the timeline specified by the APP.

B. Failure to Meet Reinstatement Requirements
If the provider does not meet the above requirements, reinstatement will not be granted. In such cases, the provider must submit a new Application for Recognition as an AOTA Approved Provider.

Revocation: If the provider fails to resolve the non-compliance issues, the Approved Provider recognition status will be revoked and the Applicant Agreement terminated. The provider will receive formal notice, via email and USPS mail, of revocation and will no longer be recognized under the APP. During this time, the provider will be given a maximum of 30 days to remove any references to AOTA’s Approved Provider status, including the AOTA name, logo, and CEU designation ('Marks'), from all promotional materials and PD activities. No previously paid APP fees will be refunded or prorated.

Disclaimer: The AOTA Approved Provider Program (APP) makes every reasonable effort to meet established timelines and provide timely decisions regarding provider status and compliance. However, due to unforeseen circumstances or situations beyond the control of APP, delays may occur. In such instances, APP reserves the right to extend deadlines or grant grace periods at its discretion. The extension of any such deadlines does not imply a waiver of any policies, fees, or requirements outlined in the program. The APP shall not be held liable for any damages, losses, or disruptions resulting from delays or extended timelines, and Approved Providers are responsible for ensuring compliance with all program requirements, regardless of any such extensions.