ABC Therapeutics Occupational Therapy Weblog

The New York Department of State's Division of Administrative Rules (DAR) publishes the weekly State Register.  This document contains newly proposed amendments to state agency rules and provides interested parties an opportunity to comment on actions before an agency adopts each rule. The July 1, 2015 Register contains a new rule that will authorize the conferral in New York State of the degree of Doctor of Occupational Therapy (O.T.D.).  There is a 45 day comment period that will soon come to a close. The Register states that  The purpose of the proposed amendment is to authorize the conferral in New York State of the degree, Doctor of Occupational Therapy (O.T.D.). The proposed amendment arose from a request to confer this degree by one of the institutions of higher education in New York.  The O.T.D. degree is recognized by the Accreditation Council for Occupational Therapy Education (ACOTE) and is an authorized degree in 26 states, which include Californ...

Different people are interested in the things that I do each day, and they are interested in them for different reasons. The people who come to me asking for help with a problem are interested in whether or not I will be able to summon the requisite knowledge to address their concern (Competency Test A).  They are also interested in whether or not I am a 'nice guy who cares' while engaging in that process (Competency Test B).  As an example, this morning a mom wanted my opinion on how to solve a problem with the positioning of her child's head and neck, because of being tilted over to one side.  I have seen hundreds of cases of torticollis, but none of them are "routine" to me.  Every one of them is treated with as much seriousness and concern and diligence that I can muster. If I treated them as 'routine' then I probably wouldn't take the time to meet the parent's Competency Test B (the 'nice guy who cares' test).  Fortunately I was...

The American Occupational Therapy Association has a Commission on Continuing Competence and Professional Development (CCCPD).  The CCCPD is conducting a 5 year review of its standards on continuing competence.  This is a good opportunity to assess the AOTA efforts in this area. Links to the draft document and a survey can be found here: http://www.aota.org/Publications-News/AOTANews/2014/CCCPD-standards-review.aspx Here are my concerns with the document: 1. I find the document to be rather vague, and the standards are not evidence-based.  There is no citation that provides information on how these standards were established or how they were developed.  In comparison, NBCOT develops practice standards that are based on a Practice Analysis and they can be viewed here: http://www.nbcot.org/practice-standards 2. The standard on Knowledge is vague and self-referential: "OTs and OTAs shall demonstrate understanding and comprehension of the information req...

The subtitle to this should be: A Wisconsin case study of how the system REALLY feels about the value of therapist training, licensing, and certification. I am going to pick on Wisconsin today, but this is a problem that people need to be aware of because it stretches beyond the borders of that state. What does a municipality do when there are rules to follow and they can't meet the mandates of the rules? Make up their own new rules, of course! Wisconsin bureaucrats demonstrate their true Machiavellian nature when they allow otherwise unqualified teachers in the classroom in the presence of personnel shortages.   They are not alone; there are several other states that have such 'emergency' routes to teacher certification - although now they have been largely replaced by programs called 'alternative' teacher certification.  When we use words like 'alternative' instead of 'emergency' then the spotlight is taken off of the bureaucrats who faile...

As I blogged about earlier this year, there were some problems with the changes to the NY State occupational therapy law that placed significant barriers to non traditional fieldwork settings.   OTA fieldwork educators in New York State and NYSOTA saw these problems and there was a last minute rush to file a technical amendment to the law so that they would not have to operate under such restrictive conditions. It is true that the way the law was written could have contributed to a decreased pool of practitioners able to accept fieldwork students; OTA students would have had to compete with OT students for licensed occupational therapy supervisors.  Fieldwork educators already struggle to find 'slots' for their students and the law certainly did not help by imposing restrictive limits on WHO could supervise a student. However, restrictions are in place for a reason - namely to protect the public - and both Medicare and Medicaid have rather severe restrictions that function...

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 t...

Background fact: occupational therapy assistant (OTA) means someone who has not passed a NBCOT certification examination or who has not renewed their certification. NY State allows these people to practice. certified occupational therapy assistant (COTA) means someone who HAS passed a NBCOT certification examination and who HAS renewed their certification. NY State does not require this for occupational therapy assistants. ****************************** The recent NYS Department of Health ruling on qualified professionals to provide OT in NYS schools originally stated that one qualification for practice was: A certified occupational therapy assistant (COTA) “under the direction of” such a qualified licensed and registered occupational therapist, acting within his or her scope of practice under New York State Law. This sent quite a few people into a panic because there are many OTAs in NY practicing without ever haven taken the NBCOT examination. After someone takes and passes the N...

From: OT Student Sent: Sunday, November 15, 2009 11:55 AM To: info@abctherapeutics.com Subject: OT student needs help Hi, I just visited your website and found your blog section very interesting. I am a current MOTS student from XXX that is working on a project looking at whether COTAs should be required to have a bachelors degree rather then just an associates. I am wondering if you are able to post this question on your blog as I need feedback from OTRs and COTAs on how they feel about this issue. I would be most grateful. Thank you in advance, OT Student ************************************************************************** Dear OT Student, If you create an online survey (there are several free survey tools available) I will be happy to put the link on my blog. I am not aware of any evidence that supported graduate degrees for OTRs - and this is an important question that should be raised. If more schooling is required and this feeds competence that is fine - but I don't kno...

We have been advertising for physical therapist assistants recently, and I have been a little shocked at the high volume of calls we received from non-licensed people who believe they are qualified for the position. It is quite common to hear callers state "Well I worked as a physical therapist assistant and am not licensed but I am qualified for your position." I have never received similar calls when we advertise for occupational therapist assistants. New York State regulations that govern PT practice on this issue are quite clear. They state: New York State law restricts the practice of physical therapy to licensed physical therapists or certified physical therapist assistants. Individuals who are not licensed or certified may not provide physical therapy services. Aides may perform non-patient related activities such as secretarial, clerical and housekeeping tasks. Additionally, aides may act as an extra set of hands for the physical therapist or physical therapist as...

I received an excellent response from Jeff Tomlinson about the recent continuing competency issues. I didn't want his response to get lost in comments, so I am posting it as an entry. There is a lot of good information here. I would really like to hear more about the direct access issue and problems in securing scripts for school aged children - sounds like something that could benefit from roundtable conversation. Anyway, here is Jeff's response: I have also been encouraged by another occupational therapist to check out this discussion. We were certainly surprised by the speed with which the physical therapists were able to pass their mandatory continuing education bill. It was quite an accomplishment in a legislative session that passed very few bills that regulated the professions. I will be talking to the lobbyist and the leadership at NYPTA about how they got this done. At the same time, it should also be noted that the PTs continuing education law is not like the NYSOT...

We are making strides in promoting continuing competence and ongoing professional development in the occupational therapy profession but there is still work to be done. The current theme running through my head has to do with quacksalvers and quality in continuing education offerings. As far as I can tell, there are few if any standards for the quality in continuing education courses as it relates to the CONTENT of the offering. I read the IACET standards and was disappointed that Standard 7 didn't really delve deeply into the issue of regulation of the QUALITY and CONTENT of continuing education courses. So if the primary standard-setter of quality in continuing education does not address quality of CONTENT, what should be done? As an aside, I don't know that I blame IACET - how could they possibly address quality across so many diverse topic areas? Does this leave the professional associations to make statements about quality of content? Or is this left to certification...

I recently posted on the status of continuing competency requirements for occupational therapists in NY State . In summary, my concern is that the bill for these requirements has been stalled in senate committees but a very similar requirement for physical therapists just passed. I wrote to NYSOTA asking about an update on this issue and have not received any response. Of course this is an issue that I have all kinds of historical interest in - and it is no secret to anyone that I am a long-term volunteer for the National Board for Certification in Occupational Therapy. This is where my passion over the issues of competence and competency was born and bred. Still, my feelings on this matter also have a lot to do with the perceived legitimacy of occupational therapy as a profession and broad protection of the public. Regulation is sometimes unnecessary and stifling - I am not a believer in the nanny-state. However, health professions are historically unable to police themselves app...

Over two years ago I wrote this article about continuing competency regulations for occupational therapists in New York State. Based on a review of the status of proposed regulations for continuing comptency as reported by the New York State Assembly website - there has been no action on this bill and it seems to be 'stuck' in the Higher Education Committee. The idea behind this proposed legislation would be to improve consumer protection by mandating that occupational therapy practitioners in New York State participate in some mandatory continuing education. As of right now, the therapist who is treating YOU in New York State may have graduated thirty years ago and never taken a continuing education course. Interestingly, a law requiring physical therapy continuing education in New York State was signed by Governor Patterson only a month ago. Since that time I have scoured the Internet and NYSOTA website for word on the OT continuing education bill and have not found anything...

I received my "certification" to administer and interpret the Sensory Integration and Praxis Tests in 1992. I believe that the test battery was published in 1989 so it was still fairly new at the time I was certified. At that time there was a certification examination that you had to pass. I don't know how psychometrically sound the SII program was - but they claimed that it was a certification program. SII never wanted me to 'recertify' though - which is a little scary. In the past twenty years the Sensory Integration and Praxis Tests have not been updated and there are no new norms. I have never heard of an occupational therapist talking about the Flynn Effect or heterosis so I don't know if anyone believed that there is a useful lifespan of an assessment tool. Some OTs still use the old Bruininks-Oseretsky test that has 25 year old norms - they just got around to updating those norms recently but I still see a lot of reports with the old test given. Persona...

I entered my profession in 1987 and at that time a bachelor’s degree was required to practice as an occupational therapist. At the American Occupational Therapy Association's Annual Conference in 1999, the Representative Assembly passed Resolution J, mandating post-baccalaureate education for entry into the profession. I still have not seen any study that indicates that baccalaureate-trained professionals are in any way less effective than people who enter the profession at the master’s level. The marketplace also never acknowledged the alleged benefit of the master’s degree, as people with advanced credentials did not make any more money than people with bachelor’s degrees. I summarize from this set of facts that the move to post-baccalaureate education served the needs of educational institutions who were able to get more tuition from students who were trying to enter the profession. Students stay in school longer and educational institutions benefit by collecting more tuition. I...

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...

Goals of the policy Regulation of continuing competence is an important current issue for the public consumers of occupational therapy services in New York State. Two bills were introduced by New York State legislators in 2005 to address this issue. Assembly bill A.5160 and Senate bill S.1388 are identical companion bills that establish requirements for occupational therapists and occupational therapy assistants to complete continuing education as part of their triennial license renewal. The proposals also mandate continuing competency fee be paid to help support the administration of this additional requirement. This proposed policy is being decided in the New York State Legislature and has been referred to the Committee on Higher Education for their review and feedback. No legislative action was taken on either bill during 2005. There is no uniform licensure or continuing competence requirement among the states. Forty-one jurisdictions currently have continuing competence requiremen...