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Board debates supervision caps and fieldwork language in proposed CCR §4180–4181 changes

California Board of Occupational Therapy · March 2, 2026
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Summary

The board reviewed proposed regulatory amendments to supervision parameters for occupational therapists and assistants, clarifying that supervisors may oversee no more than three individuals 'at any one time', debating how that limit applies to level 1 (observational) vs. level 2 (direct care) fieldwork students and whether to adopt ACOTE language for 'direct supervision.' The board agreed to refine definitions and return with final language.

The California Board of Occupational Therapy devoted substantial time Feb. 27 to refining proposed amendments to California Code of Regulations §4180–4181 that would clarify supervision limits for occupational therapists (OTs) and occupational therapy assistants (OTAs).

Board members and staff reviewed draft language that would cap the number of supervisees — aides, level 1 and level 2 fieldwork students, limited permit holders and other categories — that a licensed OT or OTA may supervise. Members coalesced on framing the limit as “no more than a total of three individuals from the following categories at…

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