What Is Your Role As The New OTR in Determining The Level of Competency With Evaluation Skills by The OTA You Supervise

1.
What is your role as the new OTR in determining the level of competency with evaluation
skills by the OTA you supervise?
As a supervising OTR, it is my responsibility to observe OTA performance to ensure that clinical

judgement is accurate and appropriate and that they demonstrate competency needed to provide
high-quality care to clients. This also ensures that documentation and medical records are accurate
to reduce risk of denied reimbursement for services.
2. How much and what type of supervision will you provide once you have determined the OTA’s
level of competency? What else do you need to know to determine this?
Given the OTA’s level of competency, ongoing supervision for this specific skill set will be
general with monthly direct face-to-face observation and conferencing as needed.
3. How do you document the level of competency? What if you and the OTA do not agree on the
level of competency?
Documentation of level of competency should include observations that were made,

discussion/teaching that was completed, and the OTR’s determination of the level of competency
displayed. If the OTA and the OTR do not agree on the level of competency, further discussion needs
to be had. Both parties should clearly understand the expectations of performance, the rationale for
the OTRs determination of level of competency, the OTAs rationale for why they disagree with the
OTRs determination. Together, both parties can come up with a plan of action to facilitate continued
observation of competency and address concerns on both sides.
4. What are the NC supervision requirements? Review supervision requirements from at

least one other state (CA, GA, MD, SC, VA...etc.) and compare the guidelines. Would the
level of supervision required in this scenario be different for one state versus another?
Why or why not?
North Caroline Supervision guidelines:

Regulations: North Carolina Administrative Code Title 21, Chapter 38, Section .0900 Supervision,
Supervisory Roles, and Clinical Responsibilities of Occupational Therapist and Occupational Therapy
Assistants:
.0901 NOTIFICATION OF SUPERVISION CHANGE

Occupational therapy assistants and supervising occupational therapists must notify the Board office
in writing of any change in ceasing or assuming supervision. The occupational therapist is responsible
for supervision of the occupational therapy assistant until official notice that supervision has ceased is
received at the Board office. Failure to notify the Board may subject both the occupational therapist
and occupational therapy assistant to disciplinary action. Notices must be signed. Telephone or email
notices shall not be accepted.
.0902 SUPERVISION IS AN INTERACTIVE PROCESS.

The occupational therapist and the occupational therapy assistant are each responsible for
supervision to ensure safe and effective service delivery of occupational therapy services and to foster
professional competence and development. The supervising occupational therapist shall provide
supervision. The occupational therapy assistant shall obtain supervision. Evidence of supervision must
be recorded on a supervisory log or in the documentation.
.0903 TYPES OF SUPERVISION

(a) Occupational therapy assistants at all levels shall require general supervision by an occupational
therapist pursuant to Rule .0103(21)(a) of this Chapter.
Virginia Supervision guidelines:

18 VAC 85-80-110 Supervisory Responsibilities of an Occupational Therapist.
A. Delegation to an occupational therapy assistant.

1. An occupational therapist shall be ultimately responsible and accountable for patient care
and occupational therapy outcomes under his clinical supervision.
2. An occupational therapist shall not delegate the discretionary aspects of the initial
assessment, evaluation, or development of a treatment plan for a patient nor shall he
delegate any task requiring a clinical decision or the knowledge, skills, and judgment of a
licensed occupational therapist.
3. Delegation shall only be made if, in the judgment of the occupational therapist, the task or
procedures do not require the exercise of professional judgment, can be properly and safely
performed by an appropriately trained occupational therapy assistant, and the delegation
does not jeopardize the health or safety of the patient.
4. Delegated tasks or procedures shall be communicated to an occupational therapy assistant on
a patient-specific basis with clear, specific instructions for performance of activities, potential
complications, and expected results.
B. The frequency, methods, and content of supervision are dependent on the complexity of patient
needs, number, and diversity of patients, demonstrated competency and experience of the assistant,
and the type and requirements of the practice setting. The occupational therapist providing clinical
supervision shall meet with the occupational therapy assistant to review and evaluate treatment
and progress of the individual patients at least once every tenth treatment session or 30 calendar
days, whichever occurs first. For the purposes of this subsection, group treatment sessions shall be
counted the same as individual treatment sessions.
C. An occupational therapist may provide clinical supervision for up to six occupational therapy
personnel, to include no more than three occupational therapy assistants at any one time.
D. The occupational therapy assistant shall document in the patient record any aspects of the initial
evaluation, treatment plan, discharge summary, or other notes on patient care performed by the
assistant. The supervising occupational therapist shall countersign such documentation in the patient
record at the time of the review and evaluation required in subsection B of this section
The differences between supervision requirements for North Carolina and my state of Virginia
are significant. As per the AOTA state guidelines for OTA supervision (2021), it does not appear that
OTAs need to have a supervision with their OTR every “x” number of visits. However, in Virginia, and
OTA must undergo supervision every 10 visits or every 30 days, whichever comes first. In my personal
setting of home health, OTRs see patients every 30 days for a re-assessment visit and supervision is
completed over the phone or text with discussion of client progress and performance.
As well, the North Carolina guidelines dictate that supervision of an OTA cannot begin or end
without notification to the licensing board (OTA Supervision, 2021). I thought this requirement was very
strange, likely because I just have never heard of it before. In Virginia, an OTR can begin and cease
supervision of an OTA at any time dependent on employment status or transference to another
supervising OTR.
Document a supervision plan to include:
 Frequency of supervisory contact

o Once monthly or every 30 days, whichever comes first.
 Method(s) or type(s) of supervision
o Direct, face-to-face, discussion and teaching
 Content areas addressed
o Administration of assessment items to determine progress with visual motor and visual
perceptual skills
 Name and credentials of the persons participating in the supervisory process
o Devon W., COTA/L, MOT/S, CFWE
o Morgan R., OTA/S
Reference
AOTA State Affairs Group. (2021). OTA Supervision. American Occupational Therapy Association.

What Is Your Role As The New OTR in Determining The Level of Competency With Evaluation Skills by The OTA You Supervise

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1.

As a supervising OTR, it is my responsibility to observe OTA performance to ensure that clinical

Documentation of level of competency should include observations that were made,

4. What are the NC supervision requirements? Review supervision requirements from at

North Caroline Supervision guidelines:

.0901 NOTIFICATION OF SUPERVISION CHANGE

.0902 SUPERVISION IS AN INTERACTIVE PROCESS.

.0903 TYPES OF SUPERVISION

Virginia Supervision guidelines:

A. Delegation to an occupational therapy assistant.

Document a supervision plan to include:

 Frequency of supervisory contact

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