From TOTA President Jeanne Sowers:   "Here are the changes to the State Practice Act regarding Supervision. The Tennessee Occupational Therapy Association anticipated this change. Unfortunately, we were not aware of when it was to be implemented. The changes to the Supervision rule was activated in January 2010. For more information about these changes, please contact the OT Board http://health.state.tn.us/boards/OT/legislative.htm or go to http://tennessee.gov/sos/rules/1150/1150-02.20100119.pdf to read the entire document."



1150-02-.10 SUPERVISION. The Board adopts, as if fully set out herein, and as it may from time to

time be amended, the current “Guidelines for Supervision, Roles, and Responsibilities During the Delivery

of Occupational Therapy Services” issued by the American Occupational Therapy Association but only to

the extent that it agrees with the laws of the state of Tennessee or the rules of the Board. If there are

conflicts with state law or rules, the state law or rules govern the matter. Information to acquire a copy

may be obtained by contacting either of the following:

American Occupational Therapy Association

GENERAL RULES GOVERNING THE PRACTICE OF CHAPTER 1150-02

OCCUPATIONAL THERAPY

(Rule 1150-02-.10, continued)

January, 2010 (Revised) 20

4720 Montgomery Lane

Bethesda, MD 20824-1220

Telephone: (301) 652-2682

T.D.D.: (800) 377-8555

Fax: (301) 652-7711

Fax On Request: (800) 701-7735 (for a specific document)

Internet: www.aota.org

Board of Occupational Therapy

227 French Landing, Suite 300

Heritage Place, MetroCenter

Nashville, TN 37243

Telephone: (615) 532-3202 ext. 25135

Telephone: (888) 310-4650 ext. 25135

Fax: (615) 532-5164

Internet: www.state.tn.us/health

(1) Supervision of an Occupational Therapist on a limited permit must include initial and routine

inspection of written evaluations, written treatment plans, patient/client notes and routine

evaluation of performance. The supervision must be conducted in person, by a licensed

occupational therapist and must be as follows:

(a) Routine supervision with direct contact every 2 weeks at the site of treatment, with

interim supervision occurring by other methods such as the telephone, conferences,

written communication, and E -mail.

(b) Supervision must include observation of the individual treatment under a limited permit

in order to assure service competency in carrying out evaluation, treatment planning

and treatment implementation.

(c) The frequency of the face to face collaboration between the person treating under a

limited permit and the supervising therapist should exceed direct contact every 2 weeks

if the condition of the patient/client, complexity of treatment, evaluation procedures, and

proficiencies of the person practicing under the limited permit warrants it.

(d) Therapists must maintain documentation of each supervisory visit, and must identify a

plan for continued supervision. Records must include, at a minimum, the following

information:

1. Location of visit; a method of identifying clients discussed

2. Current plan for supervision (daily, weekly, bi-monthly)

3. Identification of type(s) of interventions observed. These include but are not

limited to:

(i) Interventions

(ii) Training

(iii) Consultations

4. Other supervisory actions. These include but are not limited to:

(i) Discussion/recommendation for interventions and/or goals

GENERAL RULES GOVERNING THE PRACTICE OF CHAPTER 1150-02

OCCUPATIONAL THERAPY

(Rule 1150-02-.10, continued)

January, 2010 (Revised) 21

(ii) Discussion/training in documentation

(iii) Demonstration/training in intervention techniques

(iv) Assessment/re-assessment/discharge

(v) Additional Comments

5. An agreement statement signed and dated by both parties, that the supervisory

visit did occur and met the needs of the supervisor and supervisee.

6. It is the responsibility of the supervising occupational therapist to provide and the

limited permit holder to seek a quality and frequency of supervision that ensures

safe and effective occupational therapy service delivery. Both parties (supervisor

and supervisee) must keep copies of the supervisory records. Visit records must

be maintained for three (3) years, and must be provided to the Board and/or its

representative, upon request.

(e) A co-signature by supervising Occupational Therapist is required on evaluations,

treatment plans, and discharge summaries.

(2) Supervision of an Occupational Therapy Assistant on a limited permit means initial direction

and routine inspection of the service delivery and provision of relevant in-service training.

The supervising occupational therapist must provide additional supervision, if the patient’s

required level of care is beyond the level of skill of an entry level Occupational Therapy

Assistant on a limited permit. This decision is based on client’s level of care, OTA caseload,

experience and demonstrated performance competency. Supervision of an Occupational

Therapy Assistant on a limited permit must include initial and routine inspection of patient

notes and routine evaluation of performance. The supervision must be conducted in person

by a licensed occupational therapist and must be as follows:

(a) The Occupational Therapist shall be responsible for the evaluation of the patient and

development of the patient/client treatment plan. The Occupational Therapy Assistant

on a limited permit may contribute information from observations and standardized test

procedures to the evaluation and the treatment plans.

(b) The Occupational Therapy Assistant can implement and coordinate intervention plan

under supervision of a licensed Occupational Therapist.

(c) The Occupational Therapy Assistant can provide direct services that follow a

documented routine and accepted procedure under the supervision of the licensed

Occupational Therapist.

(d) The Occupational Therapy Assistant can adapt activities, media, environment

according to needs of patient/client under supervision of the licensed Occupational

Therapist.

(e) Documentation provided by the Occupational Therapy Assistant while on a limited

permit must be co-signed by a licensed Occupational Therapist.

(f) Therapists must maintain documentation of each supervisory visit, and must identify a

plan for continued supervision. Records must include, at a minimum, the following

information:

GENERAL RULES GOVERNING THE PRACTICE OF CHAPTER 1150-02

OCCUPATIONAL THERAPY

(Rule 1150-02-.10, continued)

January, 2010 (Revised) 22

1. Location of visit; a method of identifying clients discussed

2. Current plan for supervision (daily, weekly, bi-monthly)

3. Identification of type(s) of interventions observed. These include but are not

limited to:

(i) Interventions

(ii) Training

(iii) Consultations

4. Other supervisory actions. These include but are not limited to:

(i) Discussion/recommendation for interventions and/or goals

(ii) Discussion/training in documentation

(iii) Demonstration/training in intervention techniques

(iv) Assessment/re-assessment/discharge

(v) Additional Comments

5. An agreement statement signed and dated by both parties, that the supervisory

visit did occur and met the needs of the supervisor and supervisee.

6. It is the responsibility of the supervising occupational therapist to provide and the

limited permit holder to seek a quality and frequency of supervision that ensures

safe and effective occupational therapy service delivery. Both parties (supervisor

and supervisee) must keep copies of the supervisory records. Visit records must

be maintained for three (3) years, and must be provided to the Board and/or its

representative, upon request.

(3) Supervision of an Occupational Therapy Assistant with permanent licensure means initial

direction and inspection of the service delivery and provision of relevant in-service training,

according to the level of supervision the occupational therapy assistant requires. It is the

responsibility of the occupational therapist and the occupational therapy assistant to seek the

appropriate quality and frequency of supervision that ensures safe and effective occupational

therapy service delivery. This decision is based on client’s level of care, OTA caseload,

experience and demonstrated performance competency.

(a) The frequency of the face to face collaboration between the Occupational Therapy

Assistant and the supervising Occupational Therapist should not exceed direct contact

of once a month if the condition of the patient/client, complexity of treatment, evaluation

procedures, and proficiencies of the person practicing warrants it.

(b) The Occupational Therapist shall be responsible for the evaluation of the patient and

the development of the patient/client treatment plan. The Occupational Therapy

Assistant may contribute information from observations and standardized test

procedures to the evaluation and the treatment plans.

(c) The Occupational Therapy Assistant can implement and coordinate intervention plan

under the supervision of the licensed Occupational Therapist.

GENERAL RULES GOVERNING THE PRACTICE OF CHAPTER 1150-02

OCCUPATIONAL THERAPY

(Rule 1150-02-.10, continued)

January, 2010 (Revised) 23

(d) The Occupational Therapy Assistant can provide direct services that follow a

documented routine and accepted procedure under the supervision of the Occupational

Therapist.

(e) The Occupational Therapy Assistant can adapt activities, media, environment

according to the needs to the patient/client, under the supervision of the licensed

Occupational Therapist.

(f) Therapists must maintain documentation of each supervisory visit, and must identify a

plan for continued supervision. Records must include, at a minimum, the following

information:

1. Location of visit; a method of identifying clients discussed

2. Current plan for supervision (daily, weekly, bi-monthly, monthly, other)

3. Type of supervision provided. These include but are not limited to

(i) in person

(ii) phone contact

(iii) electronic contact

4. Identification of type(s) of interventions observed. These include but are not

limited to:

(i) Interventions

(ii) Training

(iii) Consultations

5. Other supervisory actions. These include but are not limited to:

(i) Discussion/recommendation for interventions and/or goals

(ii) Discussion/training in documentation

(iii) Demonstration/training in intervention techniques

(iv) Assessment/re-assessment/discharge

(v) Additional Comments

6. An agreement statement signed and dated by both parties, that the supervisory

visit did occur and met the needs of the supervisor and supervisee.

7. It is the responsibility of the supervising occupational therapist to provide and the

occupational therapy assistant to seek a quality and frequency of supervision

that ensures safe and effective occupational therapy service delivery. Both

parties (supervisor and supervisee) must keep copies of the supervisory records.

Visit records must be maintained for three (3) years, and must be provided to the

Board and/or its representative, upon request.

GENERAL RULES GOVERNING THE PRACTICE OF CHAPTER 1150-02

OCCUPATIONAL THERAPY

(Rule 1150-02-.10, continued)

January, 2010 (Revised) 24

(4) Supervision of an unlicensed person shall be as follows:

(a) There shall be close supervision with daily, direct contact at site of treatment, which

demands the physical presence of a licensed physician, Occupational Therapist or

Occupational Therapy Assistant, whenever the unlicensed person assists in the

practice of Occupational Therapy.

(b) There shall be personal instruction, observation and evaluation by the licensed

physician, Occupational Therapist or Occupational Therapy Assistant.

(c) There shall be specific delineation of tasks and responsibilities by the licensed

physician, Occupational Therapist or Occupational Therapy Assistant who is

responsible for reviewing and interpreting the results of care. The licensed physician,

Occupational Therapist or Occupational Therapy Assistant must ensure that the

unlicensed person does not perform duties for which he is not trained.

1. A licensed physician, Occupational Therapist or Occupational Therapy Assistant

may delegate to unlicensed persons specific routine tasks associated with

nontreatment aspects of occupational therapy services which are neither

evaluative, assessive, task selective, or recommending in nature, nor which

require decision-making or making occupational therapy entries in official patient

records, if the following conditions are met:

(i) The licensed physician, Occupational Therapist or Occupational Therapy

Assistant accepts professional responsibility for the performance of that

duty by the personnel to whom it is delegated. In the case of duties

delegated by a OTA, the licensed physician, Occupational Therapist or

Occupational Therapy Assistant who supervises the technician will be

responsible; and

(ii) The unlicensed personnel do not perform any duties which require

licensure under this act; and

(iii) The licensed physician, Occupational Therapist or Occupational Therapy

Assistant ensures that the unlicensed personnel have been appropriately

trained for the performance of the tasks.

2. Tasks which may be delegated may include:

(i) Transporting of patients;

(ii) Preparing or setting up a work area or equipment;

(iii) Routine department maintenance or housekeeping activities;

(iv) Taking care of patients’ personal needs during treatments; and

(v) Clerical, secretarial or administrative duties.

(d) Appropriate records must be maintained to document compliance.

(e) The intensity of the supervision is determined by the nature of the task to be

performed, the needs of the consumer, and the capability of the unlicensed person.

GENERAL RULES GOVERNING THE PRACTICE OF CHAPTER 1150-02

OCCUPATIONAL THERAPY

(Rule 1150-02-.10, continued)

January, 2010 (Revised) 25

(5) Supervision parameters

(a) Supervision is a collaborative process that requires both the licensed occupational

therapist and the licensed occupational therapy assistant to share responsibility.

Appropriate supervision will include consideration given to factors such as level of skill,

the establishment of service competency (the ability to use the identified intervention in

a safe and effective manner), experience and work setting demands, as well as the

complexity and stability of the client population to be treated.

(b) Supervision is an interactive process that requires both the licensed occupational

therapist and the licensed occupational therapy assistant or other supervisee to share

responsibility for communication between the supervisor and the supervisee. The

licensed occupational therapist should provide the supervision and the supervisee

should seek it. An outcome of appropriate supervision is to enhance and promote

quality services and the professional development of the individuals involved.

(c) Supervision of occupational therapy services provided by a licensed occupational

therapy assistant is recommended as follows:

1. Entry level occupational therapy assistants are persons working on initial skill

development (less than 1 year of work experience) or who are entering new

practice environments or developing new skills (one or more years. of

experience) and should require close supervision.

2. Intermediate level occupational therapy assistants are persons working on

increased skill development, mastery of basic role functions (minimum one -

three years of experience or dependent on practice environment or previous

experience) and should require routine supervision.

3. Advanced level occupational therapy assistants are persons refining specialized

skills (more than 3 years work experience, or the ability to understand complex

issues affecting role functions) and should require general supervision.

4. Licensed occupational therapy assistants, regardless of their years of

experience, may require closer supervision by the licensed occupational

therapist for interventions that are more complex or evaluative in nature and for

areas in which service competencies have not been established.

5. Certain occupational therapy assistants may only require minimal supervision

when performing non-clinical administrative responsibilities.

Authority: T.C.A. §§4-5-202, 4-5-204, 63-13-102, 63-13-103, 63-13-108, 63-13-202, 63-13-203, 63-13-

205, 63-13-206, 63-13-207, and 63-13-216. Administrative History: Original rule filed March 15, 1996;

effective May 29, 1996. Amendment filed September 11, 1998; effective November 25, 1998.

Amendment filed July 31, 2000; effective October 14, 2000. Amendment filed April 17, 2007; effective

July 1, 2007. References to Board of Occupational and Physical Therapy Examiners has been changed

by The Secretary of State to the Applicable entity; Board of Occupational Therapy and/or Board of

Physical Therapy pursuant to Public Chapter 115 of the 2007 Session of the Tennessee General

Assembly. Amendments filed October 21, 2009; effective January 19, 2010.