Board approves continuing‑competency requirement including jurisprudence and culturally relevant practice

The California Board of Occupational Therapy voted unanimously on June 13 to initiate rulemaking that will add a specific continuing‑competency requirement to the board’s renewal rules: for licenses renewed on or after Jan. 1, 2027, licensees must complete a minimum of 24 professional development units (PDUs) per renewal period, with a required minimum of 2 PDUs in ethics and health care, 1 PDU pertaining to laws and regulations (jurisprudence), and 1 PDU addressing culturally relevant practice/sociocultural factors or working with diverse populations.

The board approved the version labeled "Option 1," amended during the meeting to clarify the wording and to relocate related provisions so requirements are easy for licensees and auditors to find. The final amended motion directs staff to submit the proposed text to DCA for review and, if no adverse comments appear during the 45‑day public comment period, to initiate formal rulemaking. The vote was 4–0.

Why it matters Board members said the measure responds to earlier discussion about whether to require a jurisprudence exam or a continuing‑education requirement. The board and staff concluded a continuing‑education requirement including a jurisprudence component is clearer to administer and allows time for course development. Board members also sought language that helps licensees and course providers readily identify qualifying coursework.

Key points from debate and public comment Staff explained two draft options at the meeting: Option 1 (the adopted approach) requires all three named topics; Option 2 would have required ethics and allowed licensees to choose between jurisprudence and a culturally relevant practice module. Several board members said they preferred Option 1 because it ensures all licensees receive instruction on California law and on ethics. Regulations counsel and staff worked through several wording edits to reduce ambiguity — for example, moving the phrase "a minimum of" to the header for the subsection and adding "and" to make the list of required PDUs explicit.

Members of the public and representatives of the Occupational Therapy Association of California (OTEC) supported the change and offered to develop jurisprudence coursework. "OTEC is very happy to do that," Samia Rafidi, OTEC president, said during public comment. Educational program representatives stressed the need for clear, accessible descriptions so licensees can find qualifying courses offered by common continuing‑education vendors.

Other regulatory clarifications The board also approved clarifying language stating that short open‑session meetings that are principally closed session (for example, limited open time followed by a closed‑session executive‑officer appointment) will not qualify for PDUs; staff will place a notice on agendas for such meetings. The board clarified how partial credit and prorated first renewals will work: if a first renewal occurs more than one year after initial licensure, the licensee must complete half the PDUs (12) for that first renewal period.

Next steps and timing Staff will submit the amended text to the director of DCA and the Business, Consumer Services, and Housing Agency for review. If the package proceeds without adverse comment and no hearing is requested, the board authorized its executive officer to finalize the rulemaking. The package will be subject to a 45‑day public comment period and, if revised, a subsequent 15‑day comment period for technical changes.

Ending Board members said the requirement gives licensees time to complete needed coursework before the 2027 effective date and that the public comment process will allow course providers and stakeholders to suggest refinements.