OTD 45 day comment period coming to a close next week


This post represents continuing analysis of the process to change the entry level educational requirements for practicing occupational therapy from the masters level to the doctoral level.  The analysis is offered as a public critique of the occupational therapy profession's methodology for enacting such a change.

The 45 day comment period on a new rule that will authorize the conferral in New York State of the degree of Doctor of Occupational Therapy (O.T.D.) will come to a close at the end of next week.

The American Occupational Therapy Association reports:

In June 2015 AOTA staff also surveyed the 152 accredited master’s-degree-level programs, with 131 (86%) responding to the survey. Of the 131 programs that responded, 106 (81%) indicated that they had started working on a transition to the doctorate and planned to have this completed within 10 years (86 within 5 years). 

As I stated recently, "In my opinion the American Occupational Therapy Association Board of Director's 'recommendation' to move to the entry level doctorate is a dog whistle call to academicians to begin readying for a change to an entry level doctorate."  Looks like my analysis was spot on.

The American Occupational Therapy Association also reports:

What is clear from the data collected is that overall, the occupational therapy community is split on this issue, and that the overwhelming majority of participants in the dialogues see both potential threats and opportunities in moving the entry-level degree requirement to the clinical doctorate. 

I note the careful use of the word 'split,' which casually implies equal or near equal parts - but we are living in Orwellian times where words are carefully used this way.  A more accurate representation of this 'split' opinion in OT is probably near 75% in opposition and 25% in support.  Most of the support comes from academicians.

I based this on my own reading of the OT Connections forums and other social media sites and from the expression of opinion in the Town Hall at the AOTA National Conference.

The word-crafting does not end with the word "split."  It is also notable that in the Representative Assembly discussions nearly all the commentary from reps was negative.  On March 31 I posted the following in the RA feedback forums: (link is restricted to AOTA members)

AOTA members should take careful note of the strategies employed in the discussions about the move to an entry level doctorate. In several of the threads discussion was started - and that discussion was almost universally negative or hesitant about the move to an entry level doctorate. Then the Task Group Leaders in a couple threads suggested that Reps use a SWOT analysis in order to express their opinions, because "It will help when gathering and organizing the comments from the four task groups." Use of a SWOT analysis format FORCES reps into making statements that they were not naturally making. Prior to the directive, reps were responding naturally with perceptions of weakness and threats associated with the change. Now their comments are being naturally counterbalanced because they are being asked to include Strengths and Opportunities. Someone made the decision to ask for SWOT, and reps should all wonder where that request came from and why it was made. SWOT does not make data gathering any easier - all it does is balance out the feedback and artificially promote positive comments. That is how the thumb is placed on the scale and influences feedback. It is a detail that does not escape the notice of the membership who is watching this process closely. 

ACOTE will release the results of a survey of 3000 respondents sometime later this month.  It will be interesting to see the results of that poll, and an analysis will be posted here.

One refreshing point of honesty from AOTA was mentioned in their latest statement when they reported "It is likely that student debt will increase, and that continues to be a concern"

The debt issue alone should mobilize some students and parents to write a letter to NY State Department of Education and offer some feedback about the rising cost of higher education and whether or not there is evidence to continue escalating degree requirements and subsequent costs.

I posted a question on the NYSOTA Facebook page two weeks ago asking for their public comment on the OTD proposal.  That question remains unanswered.  According to NYSOTA documents from a couple months ago, there were 1308 student members, which constitutes approximately 65% of their membership.  Perhaps that is why they don't want to answer this question?

This change will probably happen anyway primarily at the whim of academics who have decided the issue for everyone else.  Readers have until next week to register an opinion with the NY State Department of Education.  Write to:

Office of the Professions,
Office of the Deputy Commissioner
State Education Department 
State Education Building 2M
89 Washington Ave.
Albany, NY 12234
(518) 486-1765
email: opdepcom@nysed.gov

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