Supervision Requirements

Both the Physical Therapy Board of California and California Board of Occupational Therapy require that PTAs and COTAs receive adequate supervision from licensed PTs and OTs.  Supervision does not mean visiting the patient in-person alongside the PTA/COTA.  Rather, supervision is accomplished by evaluating and establishing a care plan to be carried out by the PTA/COTA, reviewing and co-signing notes, visiting the patient every 30 days, and discharging or re-assessing the patient as appropriate.  

What is the responsibility of the PT/OT?

Within the industry there are several things done to ensure compliance, including:

1. All PTA/COTA notes are cosigned by a licensed PT/OT. This provides written evidence that the PT/OT is involved in the care being furnished by a PTA/COTA.  

2. A PT/OT is assigned to all cases involving a PTA/COTA. PTAs/COTAs cannot function autonomously, so there will always be a PT/OT to evaluate, re-assess, discharge, and to provide clinical guidance to the PTA/COTA.

3. The PT/OT must review the care furnished by the PTA/COTA every week at a minimum.  This is easily fulfilled by co-signing notes in a timely manner.  

4. The PT/OT must visit the patient every 30 days. While Medicare-based plans require that this be coded as a re-assessment (the 30 day re-assessment) the PT/OT board does not care how the visit is coded, but the PT/OT must visit the patient every 30 days. This prevents the PTA/COTA from operating autonomously. 

5. If a PT/OT reassigns a case to another PT/OT, there should be a documented note on the record (Communication Report) detailing this transition so as to show that there has always been adequate supervision of PTA/COTA activity. 

What can PTAs/COTAs not do?

PTAs and COTAs cannot take over the tasks of a PT/OT. This includes:

• Measurement or data collection prior to evaluation of the patient

• Documenting patient evaluations or reevaluations

• Establishing or changing a plan of care preparing a discharge summary

• Writing non-chart note summaries to other professionals; 

• Being the sole therapy representative in any meeting with other health care professionals assessing or modifying patient care