LSBME occupational therapy advisory committee adopts minor rule edits, approves three licensure waivers

The Louisiana State Board of Medical Examiners (LSBME) Occupational Therapy Advisory Committee met via Zoom on Jan. 31, 2025 and moved forward on a series of technical changes to proposed occupational therapy rules and on three individual licensure waivers decided in executive session.

The committee reviewed public comments submitted during the rule-comment period and voted on several specific items raised by clinicians and organizations. Committee members approved adding the abbreviation "DROT" (doctor of occupational therapy) to the list of allowed written credentials. The committee also voted to remove the option for a licensed and registered occupational therapist to use "OTR" without an indication of licensure; licensed practitioners must indicate licensure in their credentialing (for example, "OTR/L" or the statutory equivalent). For occupational therapy assistants the committee agreed to allow both the statutory form ("LCOTA") and the alternative formatting "COTA/L." The committee also directed staff to propose corresponding statutory language changes to align the statute with the rules (including replacing references to AOTA with NBCOT where appropriate).

Why it matters: these edits clarify how practitioners may present professional credentials in written communications and prepare the rules to conform with statutory language the committee plans to seek from the legislature. Committee members said the changes are largely technical and intended to modernize terminology and reduce confusion when Louisiana practitioners interact with national credentialing bodies.

What the committee reviewed and decided - Abbreviations: After reviewing multiple public comments, the committee approved adding "DROT" to the list of approved written initials and took votes to standardize how licensed practitioners indicate licensure. Committee discussion noted that other states commonly use "OTR/L" and that keeping consistent formatting helps reduce confusion for out-of-state colleagues and certifying bodies. The committee recorded support for pursuing a statutory update so the rules and law match.

- Credential formatting for licensed practitioners: The committee voted to remove the option that would allow a person who is both licensed and registered to use just "OTR" (without indicating licensure). The committee concluded licensed practitioners should indicate licensure in their abbreviation.

- Credential formatting for assistants: The committee voted to allow both "LCOTA" and "COTA/L" as acceptable options for licensed certified occupational therapy assistants.

- Education, supervision, and other public comments: The committee reviewed public comments requesting minimum face-to-face supervision hours for OT assistants, questions about continuing education itemization, TOEFL thresholds tied to NBCOT requirements, and whether continuing-education approvals (including ethics courses) would be monitored. Committee members and LSBME staff noted many of those points were clarifications rather than items requiring an immediate rules change and recommended addressing them in future revisions or guidance. The committee affirmed it will continue to accept nationally accredited course approvals (via CE Broker/NBCOT/AOTA/LOTA as applicable) rather than approving individual courses in rule text.

- Reimbursement and participation: LSBME staff confirmed travel or conference reimbursement is available when the board determines it necessary. As LSBME staff said during the meeting, "We will reimburse you all. For example, if we feel it's important to send one or two of you to a national OT meeting ... we have the money to pay for it," indicating the board funds committee travel when approved.

Executive session actions After moving into executive session for investigative/licensure matters, the committee approved three case-specific motions: a waiver of continuing-education requirements for 2024 for one file (identification 75001); a waiver and recommendation for licensure for applicant file 123618; and a conditional waiver for case 288858 requiring completion of 30 additional continuing-education units (six of which must be live) and two weeks of supervised shadowing. Each motion was seconded and approved in executive session.

Next steps and administration Committee staff will prepare the final report and submit the rules package to the Office of the Attorney General for review (the committee was told that AG review commonly takes several weeks). The committee instructed staff to draft and circulate proposed statutory text changes (including replacing AOTA with NBCOT where appropriate and the narrow change from "shall" to "may" in the cited statutory line) so that LSBME counsel can pursue an omnibus legislative bill. The committee set its next meeting for March 7, 2025 at 10 a.m.

The committee's actions were procedural and technical; members repeatedly emphasized that more substantive or controversial changes would be reserved for a later rule cycle or for explicit statutory change. No new statewide supervisory minimums or fee amounts were adopted at this meeting.

Ending: The meeting adjourned at 12:14 p.m. after the executive-session votes and scheduling follow-up work on statutory language and final rule submission.