It will be interesting to see how far and wide this issue travels - I expect that my answer will make some people angry and other people very happy - but either way I view this as a question that comes along that is just too good for me to ignore -
Today I was asked for my opinion on the following question:
"I am a COTA and I have attended a couple of workshops on Anadyne Therapy. It is an infrared treatment modality used to treat patients with peripheral neuropathy. Treatment will initially consist of a pre-sensory test (Semmes-Weinstein monofilaments), treatment with the Anadyne and fine motor exercises. The question is: Does an OTR have to do the initial evaluation which would be the pre-sensory test prior to the treament? I am able to conduct the test and the treatment but I don't know if legally I can."
Here is my response:
According to the NY State Board of Regents, occupational therapy assistants as a rule have not demonstrated competence to perform evaluations, so they generally do not perform them. All licensed individuals must practice within their personal scope of competence. However, the occupational therapy supervisor may delegate performing an evaluation to the occupational therapy assistant if the occupational therapy assistant has demonstrated competence to perform evaluations. That leaves professional responsibility for errors of commission or omission between the OTR and COTA who decide to have the COTA complete an evaluation. So whether or not you are capable of completing evaluations is entirely between you and your supervising OTR.
In any event, the individual practitioner is subject to Part 29 Rules of the Board of Regents which requires that licensees practice within their personal scope of competence. If you are not competent to provide a service that you are legally allowed to provide, then you may not provide that service. As a licensed professional, it is your responsibility to practice within the scope of your abilities and expertise. If you practice outside your personal scope of competence, you can be charged with professional misconduct.
Under the Regulations of the Commissioner, Part 76, it states that OT interventions include, where appropriate for such purposes, and under appropriate conditions, modalities and techniques based on approaches taught in an occupational therapy curriculum and included in a program of professional education in occupational therapy registered by the department, and consistent with areas of individual competence. These approaches are based on:
The neurological and physiological sciences as taught in a registered occupational therapy professional education program. Modalities and techniques may be based on, but not limited to, any one or more of the following:
sensory integrative approaches;
neurophysiological treatment approaches;
superficial heat and cold; or
cognitive and perceptual remediation.
Infrared or phototherapy is not mentioned at all in the regulations. I am not aware that this is a standard part of any occupational therapy curriculum and I do not know that it really falls within the occupational therapy scope of practice. I would highly doubt that infrared biophysiology is taught in the typical OTA curriculum, as it involves high level educational background in both chemistry and physics.
As the use of infrared can cause severe harm if inadvertently applied over a malignancy or a pregnancy, and as there is reason to debate if it is even an appropriate OT modality, and particularly given the fact that attending a couple inservices certainly doesn't qualify someone to use a potentially dangerous modality - I would strongly suggest that a COTAs use of this modality in these circumstances could potentially constitute professional misconduct.
Unless you have background in chemistry and physics, and unless you can understand and articulate and explain the biophysical changes that are occurring at the tissue level as a result of the IR (e.g. nitric oxide microcirculation effects), and unless you have had formal training that involves evaluation and competency assessment - I would recommend that you steer clear of this intervention modality.
As an OTR with a clinical doctorate and 20 years of experience and who has taken chemistry and physics courses and who has a basic understanding of how IR works - I still don't believe it is an appropriate OT modality and I would never use it. That is my professional opinion.
This has nothing to do with the potential efficacy of IR interventions - this is just a statement on competency and appropriateness of this modality for OT in general and by COTAs in particular.
As an aside, I am continually shocked and amazed at what some OTs think they are qualified to do. I hope that PTs far and wide smack down any OTs who use modalities that they are not appropriately educated and trained to use. Training also has to include competency assessment.
A final thought for OTs: if you look at a problem and all you can see is a peripheral neuropathy and that perhaps the best intervention is to mediate the problem with a physical agent modality and exercise - are you really still an occupational therapist?
Check your state's licensure laws - here is the link to the NY info: