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Michigan Occupational Therapy Supervision and Delegation

Supervision Definitions

“General supervision” means that the occupational therapist is not required to be physically present on site, but shall be continuously available at the time the limited assessment, task, or intervention is performed. Continuously available includes availability by telecommunication or other electronic device.

“Direct supervision” means that the occupational therapist is physically present with the occupational therapy assistant or immediately available for direction and onsite supervision at the time the limited assessment, task, or intervention is performed, and that the occupational therapist has direct contact in the physical presence of the patient or client during each visit.

Actions that Cannot be Delegated

An occupational therapist shall not delegate the performance of either of the following to an occupational therapy assistant:

  • The sole development of a treatment plan.
  • The sole evaluation and interpretation of evaluation results.

Citations

Mich. Admin. Code R. 338.1229

Occupational Therapy Assistants

Definition of a OTA

“Occupational therapy assistant” means an individual who holds a current license to practice as an occupational therapy assistant and delivers occupational therapy services under the supervision of and in partnership with an occupational therapist.

What are OTAs allowed to do?

As used in this rule, “limited assessment” means those parts of an evaluation that an occupational therapy assistant is qualified by education and training to perform while under the supervision of an occupational therapist.

What activities are expressly prohibited?

An occupational therapist shall not delegate the performance of either of the following to an occupational therapy assistant:

  • The sole development of a treatment plan.
  • The sole evaluation and interpretation of evaluation results.

What are the responsibilities of the OT when delegating to a OTA?

An occupational therapist who delegates limited assessments, tasks, or interventions to an occupational therapy assistant shall ensure the qualifications of the occupational therapy assistant under the occupational therapist’s supervision, including verification of the occupational therapy assistant’s training, education, and licensure.

An occupational therapist who delegates limited assessments, tasks, or interventions shall also comply with all of the following:

  • Examine and evaluate the patient or client before delegating limited assessments, tasks, or interventions to be performed by an occupational therapy assistant.
  • Supervise an occupational therapy assistant to whom limited assessments, tasks, or interventions have been delegated.
  • Provide predetermined procedures and protocols for limited assessments, tasks, or interventions that have been delegated.
  • Monitor an occupational therapy assistant’s practice and provision of assigned limited assessments, tasks, or interventions.
  • Maintain a record of the names of the occupational therapy assistants to whom limited assessments, tasks, or interventions have been delegated.
  • Meet using live, synchronous contact at least once per month with the occupational therapy assistant to whom limited assessments, tasks, or interventions have been delegated to evaluate the assistant’s performance, review client or patient records, and educate the occupational therapy assistant on the limited assessments, tasks, or interventions that have been delegated to facilitate professional growth and development. The occupational therapist shall maintain documentation of the meeting that has been signed by both the occupational therapist and the occupational therapy assistant. Compliance with this subdivision shall not be used as a substitute for the ongoing supervision.

What type of therapist supervision is required?

An occupational therapist who delegates limited assessments, tasks, or interventions to an occupational therapy assistant shall determine and provide the appropriate level of supervision required for the occupational therapy assistant’s performance of the delegated limited assessment, task, or intervention. The appropriate level of supervision shall be determined based on the occupational therapy assistant’s education, training, and experience and includes either General Supervision or Direct Supervision.

What is the ratio between supervising OTs and OTAs?

An occupational therapist shall not supervise more than four (4) occupational therapy assistants who are providing services to patients at the same time.

Documentation

The occupational therapist shall maintain documentation of the meeting that has been signed by both the occupational therapist and the occupational therapy assistant.

Citations

Mich. Comp. Laws ยง 333.18301

Mich. Admin. Code R. 338.1211

Mich. Admin. Code R. 338.1229

Aides

What is the definition of an aide?

“Unlicensed individual” means an individual who does not hold an occupational therapist license, an occupational therapy assistant license, or any other health professional license and who may be able to perform the tasks identified in this rule.

What is an aide expressly prohibited from doing?

An occupational therapist shall not delegate the performance of an occupational therapy intervention to an unlicensed individual.

What are the responsibilities of the OT when delegating to an aide?

An occupational therapist who delegates tasks shall also comply with all of the following:

  • Ensure the qualifications of the unlicensed individual under the occupational therapist’s direct supervision, including verification of the unlicensed individual’s training and education.
  • Examine and evaluate the patient or client before delegating tasks to be performed by an unlicensed individual.
  • Supervise an unlicensed individual to whom tasks have been delegated.
  • Provide predetermined procedures and protocols for tasks that have been delegated.
  • Maintain a record of the names of the unlicensed individuals to whom tasks have been delegated.
  •  Monitor an unlicensed individual’s practice and provision of assigned tasks.

What type of supervision is required?

An occupational therapist who delegates tasks to an unlicensed individual shall provide direct supervision of the unlicensed individual. “Direct supervision” means that the occupational therapist is physically present with the unlicensed individual or immediately available for direction and onsite supervision when patients or clients are present at the time the task is performed, and that the occupational therapist has direct contact with the patient or client during each visit.

What is the ratio between supervising OTs and aides?

An occupational therapist shall not supervise more than three (3) unlicensed individuals who are providing services to patients or clients at the same time.

Citations

Mich. Admin. Code R. 338. 1229a


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