Update on OT Practice Act and new regulations re: COTAs and supervision

Feb.6 letter from Doug Lentivech to the Professional Practice Committee of the NYS Board of Regents re: emergency regulations relating to OT Assistants, OT Students, and Limited Permittees.

Here is the revised language of the regulation that allegedly will not be available to the public until after it is published in the New York State Administrative Register.

This information was sent all over NY State today and was released by an Albany law firm who I assume must represent someone in the know.

I can't state definitively that these are the final versions, but the state or national associations aren't releasing anything and this came from a reputable source so I am going on the assumption that these will be the final regulations.

I encourage OT practitioners to contact the NYS Board for OT if they have questions about these (proposed??/accepted??) regulations. They presumably will be retroactive to today so OTs around the state will want to be aware of new requirements with as much advance notice as possible.

Of particular note is that the State Board for OT values public protection so little that they are removing a provision that stops people with limited permits from practicing when they have failed their certification examination.

The maximum number of COTAs that an OTR can now supervise is 5 FTE. If they are employed less than full time the total number of COTAs can not exceed 10. That means that some employers will need to hire more OTRs because there are many places around the state who are employing COTAs in excess of the current OTR to COTA ratio.

There are new requirements for supervision in general as well as documenting the supervision of COTAs, OT students, and limited permittees that will have a major impact on OTR time.

Finally, there was some deft tap dancing around the statutory language that required COTA students to be supervised by OTRs. The regulations as written seem to allow for COTA students to be supervised by a COTA fieldwork educator but the requirement for OTR supervision of the whole process remains. That places a new wrinkle in requirements for COTA student placements which previously did not always include direct OTR oversight.

Public participation regarding these regulations has been hijacked because they are being proposed as emergency regulations.


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