Notes on the AOTA Continuing Competence Standards Draft

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:

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:

2. The standard on Knowledge is vague and self-referential: "OTs and OTAs shall demonstrate understanding and comprehension of the information required for the multiple roles and responsibilities they assume."  That is saying that they need to know what they need to know, which is not a standard.  That is an empty statement.  The bullet points that follow are similarly vague: "Mastery of the core of the practice and profession of OT," "expertise in client centered OT practice and related primary responsibilities," etc.  These have no meaning.  The purpose of standards is to have something to hold performance up to in comparison.  There are no specifics because it is apparent that these standards were not based on any evidence.  Again, reference the NBCOT document in comparison, that lists specific Domain and Task knowledge needed for competent practice.

3. The section on critical reasoning is incomplete and does not reference the multiple ways that OTs engage in reasoning processes.  Notably lacking is any reference to Mattingly's (1994) work on narrative reasoning, which seems to be a rather unique and distinctive method employed by OTs.

4. The section of the Draft document that relates to Ethics references a 2015 Code of Ethics source that has not even been approved by the RA or presented in any final form.  It is irresponsible to cite documents that do not even exist.


I am trying to understand why AOTA is in the continuing competency business.  These standards are vague, self-referential, not evidence based, and cite documents that have not even been written yet. 

The AOTA website states that it represents 50,000 members.  BLS data indicates that there are over 100k+ practicing OTs.  According to the AOTA website ( approximately 230 people have pursued the specialty or board certification programs.  That is a barely measurable less than 1 percent participation rate when you measure it against AOTA members.  The percentage of participation in the whole population of practicing OTs is even less.   In my opinion that is rather strong indication that the AOTA continuing competency program is a waste of resources.

It is obvious from that kind of evidence that AOTA does not belong in the continuing competency business.  I suggest that AOTA should use our member resources more responsibly and leave continuing competency to NBCOT who has developed evidence based standards and administers a robust program that already addresses this concern and are used by the vast majority of practitioners. 


(see links above)

Mattingly, C., & Fleming, M. H. (1994). Clinical reasoning: Forms of inquiry in a therapeutic practice. Philadelphia, PA: F. A. Davis Press.


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