Board signals preference for continuing education over a jurisprudence exam

The California Board of Occupational Therapy spent extended time at its March 7 meeting weighing how to ensure licensees understand state law and board regulations, with most members favoring continuing education over a mandatory jurisprudence exam.

The discussion began when staff presented options ranging from a jurisprudence exam to continuing education units (PDUs) or an attestation. "I think it's really important that people take responsibility for learning the law and keeping up to date," said one board member experienced in enforcement, who described seeing licensees who did not understand applicable law. That member said she had long supported a jurisprudence exam but acknowledged the cost and administrative burdens of a formal exam process.

Other board members and commenters argued a continuing education requirement would be a lighter, more practical approach. "I would be in support of continuing education," one board member said. Several members proposed a middle ground: require a small number of PDUs specifically addressing California law and ethics, or initially allow an attestation as an interim step while CE content is developed.

Association representatives said they would help develop courses. "OTAC would love to be the go-to for this continuing education and partner with the board to make these happen," Sami Rafidi, OTAC president, told the board. Board staff and the associations discussed alternatives for delivery, including online modules, summaries with links to statutes, or vendor-developed courses. Board regulatory counsel reminded members that the board cannot vote on a regulation at the meeting if the language has not been noticed and published in a regulatory package, and that OAL (Office of Administrative Law) review and the rule-making timeline would determine when any new requirement could take effect.

Board direction: Staff was asked to draft regulatory language reflecting the board's preference for continuing education (with possible sub-options such as one unit in ethics and one in California law) and to return the language at a future meeting for further consideration. Several board members said they preferred the continuing education approach because of costs and administrative complexity associated with adopting an exam administered through the state—xamination services.

Ending: The board did not vote on regulatory language but gave staff authority to develop CE-based options and to include a jurisprudence/California-law option in a regulatory package for subsequent meetings and public comment. Associations and staff will collaborate on course development and timing, and staff will report back at a future meeting.