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OTAC flags wording ambiguity on who may modify intervention plans; will define term in next rule review
Summary
The committee discussed ambiguous proposed rule language about whether occupational therapy assistants may modify intervention plans on the spot and agreed not to delay the rules now but to add a definition of "intervention plan" in the next rule revision cycle.
Committee members spent substantial time on March 7 reviewing proposed rule language about who may modify an intervention or treatment plan and concluded that current draft language is inconsistent and could confuse practitioners about the roles of occupational therapists (OTs) and occupational therapy assistants (OTAs).
The draft rules include passages stating both that "an OT has the overall responsibility for the development, the documentation, the implementation, and the modification" of the intervention plan and that "when modifying the intervention plan, the OTP selects, implements, and makes modifications to interventions consistent with demonstrated competence levels and client goals." Committee members said the two passages read as contradictory when combined.
"That part does say to me that just the OT is gonna review and modify," said Kathleen Norcross, an advisory committee member, describing how one passage reads. Other members said that OTAs commonly adjust interventions during a session to meet goals already set by an OT, and that the rules should make that distinction clear.
"I guess it almost comes back down to what Kelly said is, what is the definition of intervention plan," said one committee member. Several members suggested the committee define "intervention plan" to mean higher-level items such as frequency, duration, session length and short- and long-term goals, while allowing OTAs discretion to grade or change specific interventions within their competency to meet those goals.
Committee members agreed not to delay finalizing the rules during the current rulemaking cycle. Instead, they instructed staff to include a clear definition of "intervention plan" in the next scheduled rules review. "We put in the rules that we were gonna modify the rules every 3 years. So that we were gonna review them every 3 years. So, I'm going to, include that for our next go round that we define intervention plan in all the definitions," Ingrid Frank said.
No formal change to the proposed rule language was made during the public session; the committee's approach was to refine definitions at the next revision to reduce ambiguity without slowing the current rule process.
Sources: committee discussion recorded at the March 7, 2025 meeting; excerpts from proposed rule language read into the record.
