Board adopts continuing-competency changes requiring jurisprudence, ethics and culturally relevant practice PDUs

The California Board of Occupational Therapy on June 13 approved a regulatory package amending continuing-competency requirements to require a minimum number of professional development units (PDUs) in ethics, jurisprudence and culturally relevant practice for license renewal.

Board members voted to insert Option 1 as a new subsection and to move and clarify language so that, for licenses renewed on or after Jan. 1, 2027, licensees must complete specified minimum PDUs as part of the total required for renewal. The motion, as amended in the meeting, authorizes staff to submit the regulatory text to the Department of Consumer Affairs and the Business, Consumer Services and Housing Agency for review and to begin the rulemaking process if no adverse comments are received; the vote was unanimous.

Key requirements adopted

Under the new language the board adopted at the meeting, of the PDUs required for each renewal period licensees shall complete a minimum of:

- 2 PDUs related to ethics and health care; - 1 PDU pertaining to laws and regulations (jurisprudence); - 1 PDU addressing culturally relevant practice, sociocultural factors, working with diverse populations and/or bias.

Board members and staff agreed to clarify placement and wording so the obligations are prominent and consistent with the remainder of the continuing-competency regulation. The board also approved edits to clarify when meeting attendance or short open-session meetings would not qualify for PDUs, and to address credit for supervision of students and doctoral capstone supervision.

Why the change

Discussion at the meeting referenced prior board and sunset-review concerns that licensees demonstrate knowledge of California law and professional responsibilities. Board Vice President Christine Whitlisbach said, “I will also speak in favor of option 1 because... I don't like the idea of people having a choice to opt out of that. So option 1 just says you have to study the law. You have to know the law.” Members described Option 1 as clearer and more enforceable than a version that would have given licensees an option to substitute diversity training for jurisprudence.

Public comment and course development

Public speakers and stakeholders urged clarity and accessibility of course offerings. Ada Boone Hurl, program director at Sacramento City College’s OTA program, and the Occupational Therapy Association of California offered to develop jurisprudence education materials for California licensees. Board staff reiterated the regulatory timeline and noted the package includes a public-notice and comment period (45 days) during which course providers and stakeholders can propose changes.

First-renewal and credit details

The draft also clarifies credit for initial-license renewals that fall more than one year after licensure: a first renewal that occurs more than one year after issuance would require half of the normal PDU total (12 units) and those 12 units would be expected to include the same required PDU categories where applicable. The regulation retains the broader requirement that a minimum of one-half of a licensee’s required PDUs be directly related to delivery of occupational therapy services and lists example activities that qualify for direct-care credit.

Actions taken

The board approved the proposed regulatory text for section 4161 as modified at the meeting (Option 1), directed staff to submit it for agency review, and authorized the executive officer to proceed with rulemaking steps including public notice and response to comments. If no adverse comments or hearing requests are received, staff may complete the rulemaking and adopt the regulations.

Ending note

Staff and board members said they will work with professional associations and education providers to develop accessible jurisprudence and culturally relevant practice offerings and to prepare clear guidance for licensees before the requirement goes into effect.