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Advisory committee flags website upload error, explains why AOTA documents were referenced as 'best practices' in rules
Summary
Committee members found that the board website had an incomplete upload of recently amended OT rules and discussed why referencing external AOTA documents in the administrative code was changed to 'best practices' during rulemaking.
At its Sept. 12 meeting, the Occupational Therapy Advisory Committee identified an apparent upload error on the Louisiana State Board of Medical Examiners’ website and discussed why language referencing American Occupational Therapy Association (AOTA) documents was changed to the phrase “best practices” in the adopted rules.
Members noted that certain rule sections (for example rules the committee did not edit, cited during the meeting as 1915 and 1917) were not included in the version posted on the board website, though they remain in the administrative code. Lauren Sudduth, LSBME attorney, explained the distinction during the meeting: rules that were not edited were not reprinted in the notice of intent and therefore might not appear in the register excerpt that staff uploaded. “So just because you don’t see them in the NOI … doesn’t mean … they’re deleted,” she said, urging staff to correct the online posting so the full administrative code is available.
Committee members also asked why the draft language had originally referenced AOTA guidance. Sudduth explained the procedural reason: when rule text incorporates an external document by reference, the administrative-code process requires filing and fixing that external document’s version in the register. To preserve flexibility and avoid having to re‑notice rule changes each time AOTA updates its materials, the register recommended the board use a generic term such as “best practices” rather than incorporate a specific outside document verbatim.
The committee asked staff to update the posted rules on the board website to reflect the full administrative code and to note the board’s intent that “best practices” references point practitioners to relevant outside guidance without locking the code to a single document version.
No formal rule changes were voted at the meeting; committee members treated the website correction and drafting clarification as administrative follow‑up.
