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Public commenters press board to exclude OT assistants from new supervision cap
Summary
At a March 7 meeting of the California Board of Occupational Therapy, association leaders urged the board to keep occupational therapy assistants (OTAs) off a proposed supervision cap, citing existing statute that already limits OTA supervision and concerns it would reduce access to services.
Leaders of occupational therapy associations and program directors urged the California Board of Occupational Therapy on March 7 to exclude occupational therapy assistants from a proposed numeric supervision cap in state regulations.
The comment came during the board—onference at Keck Graduate Institute and the meeting—ollowed up on discussion the board held in November 2024 about proposed changes to supervision language in the California Code of Regulations. "Section G, occupational therapists may supervise no more than a total of 3 of the following," said Sami Rafidi, president of the Occupational Therapy Association of California (OTAC), describing the regulation under consideration and saying OTAC had asked that occupational therapy assistants be omitted from that list.
OTAC and the American Occupational Therapy Association (AOTA) told the board they had reached agreement in November that OTAs should not be included. "Putting that cap on the number of people that an OT could supervise would limit access to service," Rafidi said, adding that a statutory limit already exists: board members and commenters reiterated that current statute allows occupational therapists to supervise no more than three OTAs at one time.
Ada Boone Horrell, program director for the Sacramento City College occupational therapy assistant program, told the board she had served on the supervision-standards committee and supported removing OTAs from the additional capped list. "It was our intention to have the assistant removed from the list because they were already licensed," Horrell said.
Kristin Neville, state affairs manager for AOTA, attended virtually and expressed support for the associations—ollow-up. "I appreciate the opportunity to attend virtually...this is a fabulous opportunity, not just for the public, but for other stakeholders," Neville said, and she told the board AOTA would continue to follow the item.
Board members and staff said the matter would be handled through the agency's regulatory process rather than at public comment. The board—xecutive officer and regulatory counsel explained that detailed discussion of regulation language must take place only after the text is published as part of a regulatory package; until then staff can report status but not deliberate on changes in public comment. Board counsel confirmed that the topic would be revisited at the regulatory update and future agendas once the package is published for public comment.
The board later listed supervision parameters among priority regulatory items staff are preparing; during the regulatory update staff said the package addressing supervision parameters (regulation section in the 4100s range) remains in development and is a priority for submission to legal and the budget office.
Board action: No formal vote was taken on regulation text at the March 7 meeting. Staff said they would include the supervision parameters language in forthcoming regulatory work and notify stakeholders when the package is published for public comment.
Ending: The associations asked the board to preserve the existing statutory limitation on OTA supervision and to avoid adding a separate regulatory cap that would apply to licensed OTAs. Staff and counsel reiterated the item will advance through the formal regulatory process and be posted online before the board can take regulatory action.
