Louisiana OT advisory committee raises privacy, cost concerns about national compact data plan

The Louisiana State Board of Medical Examiners Occupational Therapy Advisory Committee on March 7 discussed objections to parts of the Occupational Therapy Compact proposal, including a plan the compact commission is drafting to host a central dataset containing licensing information for every occupational therapist and occupational therapy assistant licensed in Louisiana.

The committee said the proposal raises privacy and data-quality concerns and could increase costs for Louisiana practitioners. Committee members and LSBME staff said they will press the compact commission to revise its approach, pursue secure application programming interface (API) solutions and try to limit mass uploads of practitioner data.

"They want to have every OT licensed in Louisiana and every OTA licensed in Louisiana for us to send up their data whether they want to be in a compact or not and it's held by them," said Doctor Vann, a member of the advisory committee, describing the compact commission's current draft. "My legal team and I have grave concerns about privacy rights."

Vann told the committee the compact commission is building APIs to move data between state licensing boards and the compact's system, and that the commission currently plans to hold the central dataset. "Application program interface," she said, when asked to clarify the acronym. She said LSBME staff would prefer to send a practitioner's data only when that practitioner requested a compact privilege rather than uploading statewide records proactively.

Patricia Wilton, LSBME executive counsel, and other staff warned the committee that a centrally held data set risks becoming stale, which could allow someone with an outdated record to receive a compact privilege without a current background check. "We may have somebody that we would not give a license to in Louisiana," Vann said, describing a scenario in which another state issued a license without an updated criminal background check.

The committee also discussed fee parity between occupational therapists (OTs) and occupational therapy assistants (OTAs). The compact commission reportedly favors a single compact fee for both OTs and OTAs; committee members said that could raise costs for some licensees. Vann said LSBME might invoke an existing reciprocity licensing fee of $75 if the data-exchange requirements become costly to implement; the board currently charges a lower fee for some reciprocal licensing.

Jennifer Lucky, president of the Louisiana Occupational Therapy Association, told the committee she was reaching out to the American Occupational Therapy Association (AOTA) and state associations to gauge practitioners' views and said she would help gather member input for a possible joint survey.

Committee members said they would try to persuade the compact commission to limit initial uploads to only those practitioners who request compact privileges and to rely on APIs that keep data current. Vann added that the commission invited her to join its rules committee and she planned to press for stronger privacy protections there: "They asked me to be on the rules committee for the compact, and that's where I hope to be able to exercise some influence to protect your data."

The committee noted the Department of Defense is funding software development for some interstate compacts but said that DoD funding does not mean the department will operate or control compact systems. "The Department of Defense is funding the development. They are not operating the computer systems or designing the programs," Vann said.

Committee members asked LSBME staff to coordinate outreach to practitioners and state associations and to return with a proposed practitioner survey and communications plan. No formal vote was recorded on any compact rule during the public session.

Short-term next steps cited at the meeting included LSBME staff continuing to push for API-based data exchanges, collecting practitioner feedback, and using legal channels and the rules committee to try to limit wholesale uploads of Louisiana practitioners' records to the compact database.

Sources: remarks by Doctor Vann, Patricia Wilton and Jennifer Lucky at the March 7, 2025 LSBME Occupational Therapy Advisory Committee meeting.