Sunday, January 29, 2012

'Non Traditional Fieldwork' runs face first into proposed New York State regulations

My sensitivity for the challenges of being an Academic Fieldwork Coordinator runs quite deep; I held that position at a college for three years and experienced the difficulty with finding student placements. There never seems to be enough fieldwork placements, there are challenges with finding places that will provide a quality experience for the student, and although there have been efforts to incentivize practitioners to take students that does not overcome the practical obstacles.

The repeating theme that the occupational therapy profession is not yet grasping is that there has to be some kind of understanding that services provided by students are not the same as services that are provided by licensed professionals. This has been a recurring theme for Medicare reimbursement of services provided by students. Fieldwork educators are very familiar with AOTA's efforts to establish clarity in these rules.

There is a parallel pushback against allowing student provided services to be reimbursed in the Medicaid system. In NY State there are restrictive rules about OT students providing Medicaid services to children. This has a large impact on practitioners willingness to accept students.

Large systems like Medicare and Medicaid are obviously motivated by creating high standards that promote public trust. If public dollars are going to pay for skilled services - then the services need to be skilled. This is understandable.

Now we are seeing new legislative perspective on this issue. While NY State tightens up regulation of OTA practice this has opened up the issue of student supervision as well. Current proposed regulations are getting much more restrictive for students - and now it is being proposed that OTA students can only be supervised by OTs and not OTAs. Furthermore, the degree of supervision that is being proposed in NY for a person who has a limited permit is more restrictive than what is generally being practiced for OT students - and there is no logic in the position that any student requires LESS supervision than someone with a limited permit. This means that if the current proposals for supervision of people who have limited permits is applied downward to students - there are going to be huge problems with models of 'non-traditional' fieldwork education. Also, removing OTAs from the equation and not allowing them to supervise OTA students will place a tremendous pressure on OTA fieldwork opportunities.

The pickle that NY State is in gets even worse - part of the proposed regs allows 'physicians' (which are not statutorily defined) to provide supervision of OTAs. This is a rather large concern because it might remove OTs from the loop and encourage optometrists or foot doctors (much less regular MDs) to hire OTAs in their offices, provide 'supervision,' and begin billing for OT services. Of course most people oppose this, but the State Board of OT comeback is 'you can't be AGAINST physician supervision and be FOR supervision by non-OTs for 'non traditional' fieldwork at the same time.

The concept of 'non traditional fieldwork' is interesting but we have not had enough discussion that relates to whether or not it 'constitutes OT' or is 'just something an OT can do with their education.' These are important legal distinctions. This also raises the issue of whether or not these 'non traditional' sites provide appropriate preparedness for taking the certification examination and practicing OT. Apparently, if we don't tackle this issue ourselves we will see regulatory boards step in like in NY.

My very strong suggestion to AOTA and ACOTE is to PUT ON THE BRAKES when talking about 'non traditional fieldwork.' The notion that "one-to-one supervision, a hallmark of traditional placement models, is replaced by alternative supervision practices such as collaborative learning or distance supervision" (Hanson, 2011) is starting to look like an idea that might have some pretty big legal problems associated with it in some contexts.

The current crisis in NY should be examined and studied CLOSELY by all other states. Opening up a practice act is a can of worms, and now we are seeing some major unintended consequences. There were issues to address in NY but this is an amazing study in why it is important to open up ONE ISSUE AT A TIME - or at least to have enough eyes on the ball when multiple issues are opened that unintended consequences are held to a minimum.

(links in text)

Hanson, D. (2011, Nov.14) Expanding practice borders: The value of nontraditional fieldwork models, OT Practice, pp.6-8.

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