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Standards of Practice

Note. This outline contains information about documentation, insurance reimbursement, management,
AOTA (2009a) standards of practice, and the OTR®–COTA® working relationship.

Documentation
I. General Information
A. Each occupational therapy practitioner documents the occupational therapy services
provided and “abides by the time frames, formats, and standards established by practice
settings, federal and state law, other regulatory and payer requirements, external
accreditation programs, and AOTA documents” (AOTA, 2010d, p. S108).

B. The facility or practice setting and the payer source may have an effect on documentation
frequency, type of required documentation, and name of the documentation reports
(Gateley & Borcherding, 2012).

C. Payers for occupational therapy services, such as Medicare, note that the services
received by the client must be “skilled” and “medically necessary” for services to be
reimbursed (Gateley & Borcherding, 2012, p. 13).

D. “Medically necessary means that services are consistent with accepted standards of
practice for the client’s condition” (Gateley & Borcherding, 2012, p. 13).

E. “Skilled means that the services provided require the decision making and highly
complex competencies of an occupational therapist or occupational therapy assistant”
(Gateley & Borcherding, 2012, p. 13).

II. Purpose and Importance of Documentation


A. Provide a rationale for occupational therapy services (AOTA, 2008a).

B. Describe how the occupational therapy services assist in meeting client outcomes (AOTA,
2008a).

C. Communicate pertinent information about clients to other health care professionals


working with the same clients (AOTA, 2008a; Sames, 2010).

E. “Create a chronological record of client status, occupational therapy services provided to


the client, and client outcomes” (AOTA, 2008a, p. 684).

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F. Assist with reimbursement of services by documenting their effectiveness and the
occupational therapy practitioner’s clinical reasoning and professional judgment (AOTA,
2008a; Sames, 2010).

G. Provide a legal record (Sames, 2010).

III. Documentation Basics


A. Document the following items (AOTA, 2008a; Sames, 2010):
1. Client’s name (on each page)
2. Medical record or case number (on each page)
3. Name of facility or setting
4. Name of department (e.g., occupational therapy)
5. Type of documentation (e.g., progress note, evaluation report)
6. Pertinent information obtained during occupational therapy session
a. Contraindications and precautions (e.g., total hip precautions)
b. Skilled occupational therapy intervention provided, functional changes, and progress toward
goals
c. Education provided, home programs, training (e.g., care of splint, instruction in adaptive
equipment, caregiver training)
d. Client’s response to intervention (Did he or she understand the education? What was the result
of the intervention?); caregiver response as appropriate
e. Plan for next session (e.g., instruct parent in positioning of child for eating; instruct client in
joint protection techniques)

B. Use the following guidelines for documentation.


1. Use standardized abbreviations for the setting (AOTA, 2008a).
2. Use appropriate terminology for the setting (AOTA, 2008a).
3. Make documentation legible, with appropriate spelling and grammar.
4. Correct errors per facility requirements (AOTA, 2008a).
5. Use at least your first name or initial, last name, and credentials (AOTA, 2008a).
6. “Adhere to professional standards of technology, when used to document occupational therapy
services” (AOTA, 2008a, p. 689).
7. Comply with legal, facility, and reimbursement requirements (AOTA, 2008a; Sames, 2010).
8. Be sure signatures of occupational therapy students and occupational therapy assistants are
cosigned “when required by law or the facility” (AOTA, 2008a, p. 689).
9. Complete documentation in a timely manner, as close to the time the services were provided as
possible (Sames, 2010).
10. Write documentation clearly and concisely, providing accurate and relevant information about the
session (Sames, 2010).

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11. Document any “unusual circumstances, noncompliance, or changes” (Sames, 2010, p. 47; e.g., client
was sick and was not seen, changes in intervention plan).
12. Ensure documentation complies with confidentiality and privacy regulations, including record
storage and disposal (AOTA, 2008a).

C. Hints for correct documentation are as follows:


1. Acronym: CARE (Sames & Berkeland, 1998, as cited in Sames, 2010)
a. Clarity: Documentation should be written clearly so that the audience reading your
documentation understands what you are talking about.
b. Accuracy: Documentation should be factual and describe events that occurred during the
provision of occupational therapy services.
c. Relevance: Documentation should be purposeful and describe the occupational therapy services
performed but omit any unnecessary information not related to the services.
d. Exceptions: Documentation should include unusual occurrences during the intervention session
(e.g., client developed an upset stomach) or changes in the plan of care.
2. Strategies to document change in client’s status over time (not an inclusive list; Moyers & Dale,
2007, as cited in Sames, 2010):
a. How often or consistently the client performs the desired behavior (e.g., fed self 50% of the meal
independently)
b. The length of time or duration (e.g., attended to a task for 15 seconds)
c. The amount of assistance the client needs (e.g., client required maximal assistance of one to
transfer from the wheelchair to the bed)
d. Performance quality (e.g., able to don shirt with one error when aligning buttons)
e. Complexity of task or activity (e.g., number of steps; number and type of cues given during task
performance)

IV. Types of Documentation


A. Order: A physician may write an order or referral for occupational therapy services. A
physician referral is not always necessary. However, some reimbursement sources or
payers and state licensure regulations may require a physician referral before initiating
occupational therapy services (Sames, 2010).

B. Screening: The purpose of screening is to identify whether a person may benefit from
occupational therapy services and an occupational therapy evaluation is necessary.
Screenings are usually conducted using chart review and client observations (Sames,
2010).

C. Evaluation report: An evaluation is “the process of obtaining and interpreting data


necessary for intervention. This includes planning for and documenting the evaluation
process and results” (AOTA, 2010d, p. S107).
1. Typical information to include in an evaluation report

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a. Date of report, date of evaluation (Sames, 2010)
b. Type of report and discipline (e.g., occupational therapy evaluation report; Sames, 2010)
c. Identifying data (e.g., client’s name, date of birth, age, diagnosis, gender, name of facility;
Sames, 2010)
d. Information about the referral (e.g., date of referral, who referred client, reason for referral, the
type and amount of services requested on the referral; AOTA, 2008a)
e. Insurance or reimbursement source (AOTA, 2008b)
f. History of present condition, illness, or diagnosis (Sames, 2010)
g. Client’s pertinent past medical history (Sames, 2010)
h. Contraindications and precautions pertinent to the occupational therapy services (Sames, 2010)
i. Occupational profile: “The initial step in the evaluation process that provides an understanding
of the client’s occupational history and experiences, patterns of daily living, interests, values,
and needs. The client’s problems and concerns about performing occupations and daily life
activities are identified, and the client’s priorities are determined” (AOTA, 2008b, p. 646).
j. Discussion of assessments used to gather data, results of assessments performed (Sames, 2010)
i. Assessment: “Specific tools or instruments that are used during the evaluation process” (AOTA,
2010d, p. S107)
k. Analysis of occupational performance (“description of and judgment about performance
skills, performance patterns, contexts and environments, features of the activities, and client
factors that facilitate and inhibit performance”; e.g., ability to perform ADLs, strength, range of
motion), analysis of evaluation data, client’s strengths (AOTA, 2008a, p. 685)
l. Report summary and recommendations (AOTA, 2008a)
m. Printed as well as signed name and credentials of therapist, date of signature (AOTA, 2008a)

D. Intervention plan: This document may be included in the initial evaluation report or
written as a separate document (Sames, 2010). Depending on the practice setting and
the payer source, the intervention plan may be revised at certain intervals or as needed
because of changes in a client’s condition (Sames, 2010).
1. Typical components of an intervention plan (Sames, 2010)
a. Summary of evaluation results with recommendations if it is the initial plan
b. Summary of progress toward goals if it is a revised plan
c. Intervention goals (long-term goals or outcomes, short-term goals or objectives, or both)
d. Intervention approaches and strategies (e.g., ADL training, instruction in joint protection
techniques, caregiver education)
e. Expected duration of occupational therapy services (e.g., 2 weeks)
f. Expected intensity of occupational therapy services (e.g., 60-minute sessions)
g. Expected frequency of occupational therapy services (e.g., 3 times a week)
h. Expected location of intervention (e.g., daycare, home, clinic)
i. Date of anticipated discharge from occupational therapy

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j. Information about probable discharge setting or environment and plan for client’s discharge
k. Rehabilitation potential to reach the stated goals
l. Recommendations for other services (e.g., physical therapy)
m. Hindrances to client reaching the goals and client’s motivation
n. If written as a separate report, also include date of report and date of evaluation, type of report
and discipline, identifying data, and client’s pertinent past medical history (Sames, 2010)
o. Date plan was written or revised
p. Printed and signed name and credentials of OTR®, date of signature (AOTA, 2008a; Sames,
2010)

E. Write goals.
1. Generally written in collaboration with client, significant others, or both (Gateley & Borcherding,
2012)
2. Short- versus long-term goals
a. Short-term goals or objectives: Steps to reach the long-term or overarching goal of occupational
therapy services. These goals are modified and changed as the client improves. The time frame
for short-term goals varies depending on the client, practice setting, and payer source (Sames,
2010).
b. Long-term goals or discharge goals: Goals the client is expected to achieve on discharge from
occupational therapy services (Sames, 2010).
i. Formats for writing measurable goals: Numerous acronyms can help occupational therapists
write client goals (Sames, 2010), for example, the COAST method (Gateley & Borcherding,
2012):
• C: Client (Gateley & Borcherding, 2012)
• O: Occupation (e.g., cut meat; Gateley & Borcherding, 2012)
• A: Assistance level (e.g., independently; Gateley & Borcherding, 2012)
• S: Specific conditions (e.g., using a rocker knife and an inner-lip plate; Gateley &
Borcherding, 2012)
• T: Timeline (e.g., within 1 week; Gateley & Borcherding, 2012)
• Example of goal written using the COAST method: Client will be able to cut meat
independently using a rocker knife and an inner-lip plate within 1 week (Gateley &
Borcherding, 2012).

F. Include contact and progress notes; note that the names of reports an occupational
therapy practitioner writes may vary from setting to setting (AOTA, 2008a; Morreale,
2011).
1. Contact note
a. Documents the occupational therapy practitioner’s contact with a client; interventions used
during the session; client’s response to the intervention; instruction, training, and education
given; and telephone calls or meetings that relate to the client (AOTA, 2008a). Nonattendance

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or missing an occupational therapy session is generally documented with a contact note (AOTA,
2008a; Morreale, 2011).
2. Progress notes or reports
a. Typical contents of a progress note or report (AOTA, 2008a)
i. Identifying data (e.g., client’s name, date of birth, gender)
ii. Intervention provided during session (e.g., environmental modifications, ADL retraining,
orthotics fitting)
iii. Length of session; where session occurred (e.g., home)
iv. Precautions followed during intervention session
v. Contraindications or reasons why particular interventions were not completed
vi. New assessments completed or information obtained
vii. Client’s current functional level and progress made toward goals
viii. Intervention plan modifications
ix. Whether occupational therapy services should continue and rationale for continuing
intervention or for discharging client
x. Referrals to other services
xi. Recommendations with rationale; plan for next session
b. Formats for progress notes or reports
i. SOAP
• S: Quoted or paraphrased subjective information from client (e.g., client reported he was
able to undress himself before bed last night; “I didn’t sleep well last night”; Gateley &
Borcherding, 2012)
• O: Objective information from intervention session, such as measurements, observable
data, and any quantifiable data such as goniometric or strength measurements (Gateley
& Borcherding, 2012)
• A: Assessment; includes the occupational therapy clinician’s interpretation or analysis
of the information in the previous sections of the note, therapist’s judgment (Gateley &
Borcherding, 2012)
• P: Plan; includes the estimated duration and frequency of occupational therapy services,
anticipated intervention strategies to be used. Should relate to previous sections of the
note (Gateley & Borcherding, 2012).
ii. DAP (description, assessment, and plan); similar to SOAP except that the S and O sections of
the note are collapsed together in the D section (Gateley & Borcherding, 2012)
iii. Narrative: May include pertinent information in a logical order of the writer’s choosing but
not in a specific format as in SOAP or DAP notes (Gateley & Borcherding, 2012).
iv. BIRP, PIRP, SIRP: Formats are similar to each other; sometimes used in a behavioral health
setting (Gateley & Borcherding, 2012)
• BIRP: Behavior of client, intervention provided, response of client to intervention, plan
for continued intervention (Gateley & Borcherding, 2012)

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• PIRP: Purpose or reason for the intervention, intervention provided, response of client
to intervention, plan for continued intervention (Gateley & Borcherding, 2012)
• SIRP: Situation, intervention provided, response of client to intervention, plan for
continued intervention (Gamely & Borcherding, 2012)

G. Reevaluation or reassessment report: This report is written on the basis of the results of
the reevaluation or reassessment (AOTA, 2008a).
1. Frequency: May need to be written at required intervals, which may vary depending on payer
source, intervention setting, or the amount of progress the client has made (AOTA, 2008a; Gateley
& Borcherding, 2012).
2. Typical information included in a reevaluation report (AOTA, 2008a)
a. Client or facility identifying data (e.g., name of facility, discipline, client’s name, date of birth,
gender, diagnoses or medical issues affecting intervention, precautions, and contraindications)
b. Updated information related to client’s occupational profile
c. Reevaluation results including the rationale for completing the reevaluation, assessments
completed, assessment results, updated information on client’s performance, and client’s
response to intervention
d. Summary and interpretation of reevaluation findings
e. Recommendations

H. Transition plan: This report “documents the formal transition plan and is written when
client is transitioning from one service setting to another within a service delivery
system” (AOTA, 2008a, p. 687).
1. Typical information included in a transition plan (AOTA, 2008a)
a. Client or facility identifying data (e.g., name of facility, discipline, client’s name, date of birth,
gender, diagnoses or medical issues affecting intervention, precautions, and contraindications)
b. Client’s current abilities
c. Information related to client’s current intervention setting, where client will be transitioning to,
when the transition is expected to occur, and preparation for transition
d. Recommendations for type and amount of occupational therapy services, special requirements
at transition site, and reason for recommending these services or providing these suggestions

I. Discharge or discontinuation report and summary: This report provides a summary


of the occupational therapy services including services provided, client’s response to
services, progress toward goals and since initial evaluation, and recommendations for
discharge (AOTA, 2008a)
1. Typical information included in a discharge or discontinuation summary (AOTA, 2008a):
a. Client or facility identifying data (e.g., name of facility, discipline, client’s name, date of birth,
gender, diagnoses or medical issues affecting intervention, precautions, and contraindications)
b. Synopsis of occupational therapy services provided, including frequency of services, number of
sessions completed, types of interventions used during the provision of services, progress since

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initial evaluation and toward goals, response to interventions, equipment or training provided,
and recommendations for discharge (e.g., home programs).

VI. Setting-Specific Documentation


A. Pediatric settings
1. School-based settings
a. Individualized Education Program (IEP): Occupational therapy practitioners working
in school-based settings must relate their documentation to the student’s IEP, a written
document detailing the student’s academic needs and functional goals in that setting (Gateley
& Borcherding, 2012; Jackson, 2007; U.S. Department of Education, 2006). The occupational
therapy intervention and goals in the school system setting should relate to the child’s functional
abilities to perform school-related tasks (Morreale, 2011).
2. Early intervention settings
a. Individualized Family Services Plan (IFSP): Occupational therapy practitioners working in early
intervention services that are federally mandated will also need to be familiar with the IFSPs of
children they are treating (Gateley & Borcherding, 2012).
b. Documentation is generally written in lay terms to increase a parent’s ability to understand it
(Gateley & Borcherding, 2012).

B. Mental health settings


1. Documentation may be multidisciplinary, and intervention may be provided in groups (Gateley &
Borcherding, 2012).

C. Skilled nursing facility and long-term care settings


1. Occupational therapy practitioners working in these settings should familiarize themselves with
the Medicare requirements because it is a primary payer for occupational therapy services in these
settings (Gateley & Borcherding, 2012).
2. Occupational therapy practitioners may also have to provide information for the “multidisciplinary
evaluation called the Minimum Data Set (MDS) [which] is used to determine the specific level of
care needed” (Gateley & Borcherding, 2012, p. 176).

D. Inpatient rehabilitation settings


1. Occupational therapy practitioners may have to provide information for the interdisciplinary
evaluation titled the Inpatient Rehabilitation Facility Patient Assessment Instrument (IRF–PAI) by
scoring the client on the FIM™ (Centers for Medicare and Medicaid Services [CMS], 2013; Gateley
& Borcherding, 2012).

E. Outpatient practice settings


1. The type and amount of documentation will vary in these settings depending on the client’s age,
payer source and requirements, facility requirements, and any outside accrediting bodies (Gateley &
Borcherding, 2012).

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F. Home health settings
1. Home health clients who have Medicare or Medicaid must have the Outcome Assessment
Information Set (OASIS) completed (CMS, 2011b). This assessment helps provide guidance for the
services the client requires and helps determine the client’s eligibility to receive home health (CMS,
2011b; Morreale, 2011).
2. In certain instances, occupational therapy clinicians may complete the OASIS (CMS, 2011b).
3. Occupational therapy home health documentation generally focuses on the client’s ability to
perform functional tasks as well as safety or environmental concerns (Morreale, 2011).

VII. Legal and Ethical Issues Regarding Documentation (Sames, 2010)


A. Privacy and confidentiality
1. Health Insurance Portability and Accountability Act (HIPAA) of 1996 (Pub. L. 104–191): The
privacy regulations part of this legislation gives clients certain rights regarding the privacy and
release of their medical information (U.S. Department of Health and Human Services, 2012).
a. Occupational therapy practitioners should familiarize themselves with the HIPAA regulations
and their facility’s specific policies for meeting these requirements (Gateley & Borcherding,
2012).
b. Examples of strategies for meeting HIPAA’s privacy requirements when completing
documentation
i. Ensure that a client’s record remains private by positioning computer screens or hard charts
out of others’ view when completing documentation or reading others’ documentation
(Gateley & Borcherding, 2012).
ii. Avoid leaving hard charts or electronic charts open for others to read if you need to step
away from your desk (Sames, 2010).
iii. Avoid discussing clients in public areas where others may hear what you are saying (Sames,
2010).
iv. Keep hard-copy records locked in a secure area (Sames, 2010).
v. Password-protect electronic client records (Fremgen, 2006, as cited in Sames, 2010).
2. Family Educational Rights and Privacy Act of 1974 (20 U.S.C. § 1232g): This act “identifies the
confidentiality requirements of a student’s educational record” (Sames, 2010, p. 61), including
occupational therapy documentation completed on students (Sames, 2010).
3. Individuals With Disabilities Education Improvement Act of 2004 (Pub. L. 108–446): This
legislation also discusses privacy of information for children with disabilities (ages 0–21; Sames,
2010).
4. AOTA Code of Ethics and Ethics Standards (2010): The Code of Ethics and Ethics Standards also
stresses the importance of occupational therapy practitioners’ maintaining the confidentiality and
privacy of clients (AOTA, 2010a). “The principle of autonomy and confidentiality expresses the
concept that practitioners have a duty to treat the client according to the client’s desires, within the
bounds of accepted standards of care and to protect the client’s confidential information” (AOTA,
2010a, p. S20).

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B. Relationship of documentation to payer source: Third-party payers (e.g., Medicare,
Medicaid, private insurance companies) may request, review, and audit occupational
therapy practitioners’ documentation to determine whether it meets their specific
guidelines for reimbursement and whether the occupational therapy services should be
paid for by the third-party payer (Gateley & Borcherding, 2012).
1. Occupational therapy clinicians should familiarize themselves with each payer’s guidelines for
reimbursement of occupational therapy services (Sames, 2010).
2. Therapists should also familiarize themselves with each payer’s appeals process and consider
appealing any inappropriate occupational therapy service denials by payer sources (Sames, 2010).
3. Documentation must be accurate and truthful to avoid misrepresenting the client’s status, the
occupational therapy services provided, or both (Sames, 2010).
4. Note: For further information on insurance reimbursement, please refer to the insurance part of the
study outline.

Insurance Reimbursement for Occupational Therapy Services


I. General Information
A. In all settings, occupational therapy practitioners must be aware of the reimbursement
guidelines for occupational therapy services to ensure that the services they will provide
are coverable (Thomas, 2011).

B. Therapists must also be knowledgeable about specific documentation requirements of


each payer source (Morreale, 2011).

C. The Centers for Medicare and Medicaid Services (CMS) “is the largest single payer of
health care services in the United States” (Thomas, 2011, p. 389).

D. Many other payers of occupational therapy services follow Medicare’s guidelines for
payment of services, making it essential for occupational therapy practitioners to
understand these regulations (Thomas, 2011).

E. Some payer sources may limit the monetary amount of reimbursement, and others will
limit the number of visits, the types of services, and the location or site where services
can be provided (Thomas, 2011).

II. Medicare
A. Medicare is a federal program initiated in 1965 as part of the Social Security Act (U.S.
Social Security Administration, 2012).

B. This program is administered by the CMS (2012b).

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C. General eligibility requirements: Medicare covers most adults age 65 years or older;
some people with disabilities younger than age 65 years, and people who have end-stage
renal disease (CMS, 2012b).

D. Reimbursement for occupational therapy services under Medicare falls under Part A and
Part B, considered “original” Medicare, and Part C (Thomas, 2011).

E. General requirements for occupational therapy reimbursement under Medicare


(Thomas, 2011) are as follows:
1. A physician must provide a referral.
2. Services are provided following a written care plan that is approved and signed by the physician.
3. Services are performed by qualified occupational therapy providers (OTRs® or COTAs® under
appropriate supervision).
4. Services must be skilled and require the knowledge and expertise of occupational therapy
practitioners.
5. The amount, duration, and intensity of the services must be “reasonable and necessary” for the
client’s condition (CMS, 2012e, p. 26).

F. Medicare contractors help process claims for original Medicare services and can provide
additional information and guidance to occupational therapy practitioners regarding
Medicare coverage of services (Thomas, 2011).

G. Medicare requirements for reimbursement of services may vary from setting to setting
(Thomas, 2011).

H. Medicare Part A is considered the “hospital insurance” part of Medicare. It covers part of
the expenses for inpatient stays in hospitals, short-term stays at skilled nursing facilities
(SNFs) for more acute conditions, hospice, and some services in home health (CMS,
2012b). It generally does not require individuals to pay a monthly premium because
payroll taxes for individuals or their spouse have already paid for it (CMS, 2012b).
1. Hospital setting
a. Medicare hospital services are paid through a “prospective payment system (PPS) based on the
range of services expected to be provided to each patient on the basis of established diagnosis-
related groups” (Thomas, 2011, p. 390). Medically necessary occupational therapy is covered
under this system (Thomas, 2011).
2. Inpatient rehabilitation facility (IRF)
a. This type of facility treats clients who require rehabilitation services and admits specific
percentages of clients with certain rehabilitation conditions (Thomas, 2011).
b. Medicare IRF services are paid through a PPS (Thomas, 2011). “Information from a patient
assessment instrument [is used] to classify patients into distinct groups based on clinical
characteristics and expected resource needs” (Thomas, 2011, p. 390). Medically necessary
occupational therapy is covered under this rate.

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3. SNF
a. Medicare Part A covers up to 100 days of the SNF stay, including skilled nursing and therapy
services in an SNF if the person meets certain criteria, such as requiring skilled services a
minimum of 5 days a week (Thomas, 2011). Occupational therapy services are paid as part of the
per diem PPS (Thomas, 2011).
b. “A patient’s need for services and the prospective per diem rate are established by a Resident
Assessment Instrument (RAI) which classifies patients into resource utilization groups”
(Thomas, 2011, p. 390).
c. One part of the RAI is called the Minimum Data Set (Thomas, 2011).
d. “The therapy resource utilization groups are based on the number of minutes of therapy per
week required by the client” (Thomas, 2011, p. 390).
4. Psychiatric hospital
a. Psychiatric hospitals are paid by Medicare under an IPF–PPS, including a per diem rate using a
client classification system (Thomas, 2011).
5. Home health agency
a. A client must be considered homebound and require skilled services (nursing, physical
therapy, or speech–language pathology) to qualify for home health. At the time of this writing,
occupational therapy can be covered after the person qualifies for home health (Thomas, 2011).
b. The Outcome and Assessment Information Set helps classify clients’ needs for the home health
agency and helps determine payment for services (Thomas, 2011).
6. Hospice
a. A person qualifies for Medicare Part A coverage for hospice when he or she meets the criteria
of being terminally ill and has a prognosis of fewer than 6 months as determined by a physician
(Thomas, 2011).
b. If occupational therapy services are required, they are focused on helping clients maintain their
functioning or symptoms (e.g., pain control; Thomas, 2011).

H. Medicare Part B is considered the “supplementary medical insurance” part of Medicare.


It covers some of the costs for outpatient care, such as physician visits and occupational
therapy services, some home health services, and some supplies and equipment
(Thomas, 2011).
1. Generally, most people must pay a premium each month to cover the cost of Medicare Part B (CMS,
2012b).
2. Medicare Part B covers 80% of the cost for medically necessary outpatient physical therapy,
occupational therapy, and speech–language pathology. The client pays any deductible not met and
20% of the Medicare-approved costs (CMS, 2012c).
3. Outpatient occupational therapy
a. Outpatient therapy is covered at a “comprehensive outpatient rehabilitation facility,
rehabilitation agency, clinic, hospital outpatient department, home health agencies, [or] private
practice” and in physicians’ offices (Thomas, 2011, p. 391).

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b. Payment is based on the Medicare Physician Fee Schedule, which takes into account CPT™
codes used during the provision of services (American Medical Association, 2013; Thomas,
2011).
c. Medicare Part B–covered occupational therapy services are not to exceed a certain dollar
amount or “cap” for services (Thomas, 2011). Sometimes legislation is passed that allows an
exemption process, which allows occupational therapy practitioners to exceed the capped
amount when medically necessary and justifiable by documentation (Thomas, 2011).
d. Outpatient occupational therapy practitioners can also provide services in clients’ homes and to
“a beneficiary who is an inpatient in another institution” under Medicare Part B (Thomas, 2011,
p. 391).
4. Durable medical equipment (DME), safety equipment, and adaptive equipment
a. DME is defined as “reusable medical equipment such as walkers, wheelchairs, or hospital beds”
(CMS, 2008b). Medicare generally covers about 80% of the approved cost of DME, and the
client generally pays the remaining 20% of the cost (CMS, 2008b).
b. Occupational therapy practitioners sometimes recommend DME, adaptive equipment, and
safety equipment to improve clients’ safety and function.
c. Most adaptive equipment such as reachers or dressing sticks, bathtub seats, and grab bars are
not (as of the time of this writing) covered or reimbursed by Medicare (Thomas, 2011).

I. Medicare Part C is the Medicare Advantage Plan “offered by a private company that
contracts with Medicare” (CMS, 2012d, p. 1).
1. A variety of Medicare Advantage plans are available, each of which has different guidelines and
coverage requirements (Thomas, 2011). Occupational therapy practitioners will need to check
specific policy requirements to determine coverage for their services.

J. Medicare Part D added “prescription drug coverage to Original Medicare, some Medicare
Cost Plans, some Medicare Private-Fee-for-Service Plans, and Medicare Medical Savings
Account Plans” (CMS, 2012d, p. 1).

III. Federal Employees Health Benefit Program


A. This health insurance covers numerous federal workers (retired and active; Thomas,
2011).

B. “Coverage of individual types of service such as occupational therapy, the settings


in which they may be provided, out-of-pocket expenses, and limitations on coverage
are determined by each of the private plans with which the government contracts to
administer health care services” (Thomas, 2011, p. 392).

IV. U.S. Department of Defense health care: TRICARE


A. TRICARE is part of the Military Health System and provides “coverage for active-duty
service members, retirees, their families, survivors, and certain former spouses”
(Thomas, 2011, p. 392).

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B. Nonmilitary and military providers are able to provide services under TRICARE
(Thomas, 2011).

C. Coverage for occupational therapy services may vary depending on the specific regional
plans (Thomas, 2011).

V. Medicaid
A. This program involves a partnership with the state and federal government. Although
Medicaid has general eligibility requirements, the specific requirements for eligibility
and coverage may vary from state to state (U.S. Department of Health & Human Services,
2012).

B. The general eligibility requirement is income under a certain level (U.S. Department of
Health and Human Services, 2012).

C. Eligibility: People with disabilities are eligible in every state. In some states, people with
disabilities qualify automatically if they get Supplemental Security Income (SSI) benefits.
In other states, a person may qualify depending on income level and resources (financial
assets; U.S. Department of Health and Human Services, 2012).

D. Medicaid covers “early and periodic screening, diagnosis, and treatment for people
younger than 21 years of age (which includes access to occupational therapy)” (Thomas,
2011, p. 393).

E. Medicaid covers services provided in nursing facilities, including occupational therapy


for individuals age 21 and older (Thomas, 2011).

F. Some states may opt to have occupational therapy as a covered service for adults
(Thomas, 2011).

VI. State Children’s Health Insurance Program (CHIP)


A. This program is funded by both the federal and the state governments but is
administered by each state (CMS, 2012a).

B. CHIP “provides health coverage to nearly 8 million children in families with incomes too
high to qualify for Medicaid, but [who] can’t afford private coverage” (CMS, 2012a, p. 1).

C. Occupational therapy coverage under CHIP may vary from state to state.

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VII. Individuals With Disabilities Education Act (IDEA)
A. IDEA, originally enacted in 1990 but most recently reauthorized in 2004 as the
Individuals With Disabilities Education Improvement Act of 2004, “is a law ensuring
services to children with disabilities throughout the nation. IDEA governs how states
and public agencies provide early intervention, special education and related services
to more than 6.5 million eligible infants, toddlers, children and youth with disabilities”
(U.S. Department of Education, n.d., p. 1).

B. IDEA Part B covers children and young adults with disabilities ages 3–21 (U.S.
Department of Education, n.d.).

C. IDEA Part C covers infants and toddlers ages 0–2 (U.S. Department of Education, n.d.).

D. Occupational therapy is listed under and considered a related service under IDEA for
both Parts B and C (National Dissemination Center for Children With Disabilities, 2012).
The services “must be provided according to an individualized education plan (IEP) or an
individualized family service plan (IFSP) by a qualified therapist” (Thomas, 2011, p. 394).

E. The Medicare Catastrophic Coverage Act allows related services, such as medically
necessary physical or occupational therapy, to be billed to Medicaid through the school
system under certain conditions (Thomas, 2011).

VIII. Workers’ Compensation


A. “Workers’ compensation laws provide money and medical benefits to an employee
who has an injury as a result of an accident, injury or occupational disease on-the-job”
(WorkersCompensation.com, n.d., p. 1).

B. Occupational therapy practitioners may work with clients who have been injured on the
job and are covered by workers’ compensation insurance (Thomas, 2011). The focus of
occupational therapy for these clients is often trying to help them recover so they can
return to their former job if at all possible (Thomas, 2011).

C. Guidelines for reimbursement for occupational therapy services for people who are
covered under workers’ compensation may vary from employer to employer (Thomas,
2011).

IX. Private Insurance


A. Numerous types of private insurance plans exist in the United States (Thomas, 2011).

B. Each plan has its own requirements for coverage and reimbursement of occupational
therapy services (Thomas, 2011).

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X. Coding and Billing
A. Claims for occupational therapy services at most facilities are billed electronically
following appropriate guidelines and regulations (Thomas, 2011).

B. Occupational therapy practitioners need to become familiar with coding and billing to
ensure services are properly coded and billed (Thomas, 2011).
1. Diagnosis codes (International Classification of Diseases, Ninth Revision, Clinical Modification;
National Center for Health Statistics, 2011): “It is appropriate for an occupational therapist to
provide a treatment diagnosis that reflects the reason for occupational therapy services” (AOTA,
2007).
2. Procedure codes (CPT): Occupational therapy providers in certain settings may use the CPT
codes to denote services they provided for billing (Thomas, 2011). However, not all payers accept
all CPT codes (Thomas, 2011). Occupational therapy practitioners are encouraged to check with
reimbursement sources to learn each one’s specific regulations and procedures for reimbursement.

XI. Denials, Audits, and the Appeals Process


A. Medicare Recovery Audit Program: Medicare may audit records of those who bill
services to them. The Medicare Recovery Audit Program was started “to identify
improper payments made on claims of health care services provided to Medicare
beneficiaries. Improper payments may be overpayments or underpayments” (CMS,
2008a, p. 1)

B. Sometimes, a client’s occupational therapy services may be denied reimbursement by the


payer source (Sames, 2010). The occupational therapy clinician, the facility, or both are
able to go through the appeals process for the payer to see whether any technical errors
can be corrected or to provide justification for payment of the services (Sames, 2010).

C. Frequent causes for denial of occupational therapy services include using an


experimental intervention, writing documentation that does not demonstrate that
the skills of an OTR® or a COTA® under the supervision of an OTR® were needed, and
exceeding the number of visits allowable (Sames, 2010).

D. Occupational therapy practitioners should become familiar with the appeals process for
their major payer sources because the appeals process may vary from payer to payer.

XII. Medicare Fraud and Abuse and Other Pertinent Regulations


A. Fraud is “making false statements or representations of material facts to obtain some
benefit or payment for which no entitlement would otherwise exist” (CMS, 2011a, p. 1).
1. Example of Medicare fraud: “knowingly billing for services that were not furnished and/or supplies
not provided” (CMS, 2011a, p. 1)

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B. Abuse “describes practices that, either directly or indirectly, result in unnecessary costs
to the Medicare Program” (CMS, 2011a, p. 2).
1. Examples of Medicare abuse: “billing for services that were not medically necessary,” “misusing
codes on a claim” (CMS, 2011a, p. 2)

C. False Claims Act: Sections of this act protect “the Government from being overcharged or
sold substandard goods or services” (CMS, 2011a, p. 2). Criminal penalties such as fines,
imprisonment, or both may result if this act is violated (CMS, 2011a).

D. Anti-kickback statute: This statute “makes it a criminal offense to knowingly and willfully
offer, pay, solicit, or receive any remuneration to induce or reward referrals of items or
services reimbursable by a Federal health care program” (CMS, 2011a, p. 3). Violators
may have to pay fines, may be imprisoned, or both (CMS, 2011a).

Management
I. Introduction to Management
A. Definition of management: “A process of how one works with others in order to achieve
desired goals or stated outcomes” (Royeen, 2011, p. 62)

B. Relationship of management to occupational therapy practice


1. Occupational therapy managers require similar sets of skills as occupational therapy clinicians, such
as effective time management, supervision and management of staff, and allocation of resources
(McCormack, 2011a).
2. Service delivery transformations: A variety of factors affect the way in which occupational therapy
is practiced and managed. Where and how occupational therapy practitioners deliver health care
continues to gradually change. Some examples of current delivery systems for health care (Jacobs,
2011) are as follows:
a. Hospitals with vertical organization: “Clients can be readmitted for necessary procedures, and
the hospital is able to keep clients in its market by placing them in affiliated systems” (Jacobs,
2011, p. 41).
b. Health networks: Larger hospital systems take over smaller hospitals or facilities to create a
large health care delivery system network (Jacobs, 2011).
c. Alternative or integrated delivery systems: The major types include health maintenance
organizations (HMOs), preferred provider organizations (PPOs), and point-of-service plans
(POS; Jacobs, 2011).
i. An HMO is “a prepaid organized delivery system where the organization and the primary
care physicians assume some financial risk for the care provided to its enrolled members”
(Weiner & De Lissovoy, 1993, as cited in Jacobs, 2011, p. 37).
ii. In a PPO system, the people who belong to it are able to go directly to a specialist without
going through the primary care physician (Anderson et al., 2001, as cited in Jacobs, 2011).

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iii. A POS health care plan is similar to some of the HMOs, but it sometimes allows people to
refer themselves to physicians who do not belong to the network (Anderson et al., 2001, as
cited in Jacobs, 2011).
d. Underinsured: Many individuals in the United States do not have insurance and are often
limited in the type of health care they receive (Jacobs, 2011).
i. The Patient Protection and Affordable Care Act (Pub. L. No. 111–148) was signed into
legislation in March 2010 and will provide greater access to affordable health care insurance
starting in 2014 (Healthcare.gov, n.d.).
e. Public health programs: Individuals who lack close proximity to health care or private health
care coverage, or who are unable to afford private health care, may receive health care in a
public health system (Jacobs, 2011).
f. State health programs: Some states have their own health care programs (Jacobs, 2011).

C. Service delivery trends


1. Growing older adult population: “By 2030, the number of Americans aged 65 years and older is
estimated to be 71.5 million, more than double what it is now” (Centers for Disease Control and
Prevention [CDC], 2011, p. 1). This trend has implications for occupational therapy services for older
adults (e.g., aging in place; Jacobs, 2011).
2. Increasing number of people living with chronic conditions: According to the CDC, “chronic diseases
and other chronic conditions are a leading cause of death and disability in the United States” (CDC,
2012, p. 1).
a. Examples of chronic disease are cancer, arthritis, heart disease, and diabetes (CDC, 2012)
b. Examples of chronic conditions are obesity, high blood pressure, and high cholesterol (CDC,
2012)
3. Increasingly stringent health care and payer requirements: In an effort to contain costs, payer
sources have made their requirements for reimbursement of services much more stringent,
including an increasing emphasis on adequate documentation to justify the need for services
(Jacobs, 2011).
4. Increasing emphasis on prevention and wellness: Because of the burgeoning number of older adults,
the increasing number of people living with chronic conditions, and the need for cost containment,
an increased emphasis has been placed on prevention and wellness (Jacobs, 2011), one of the
emerging practice areas for occupational therapy (Yamkovenko, 2012).
5. Technological advances: Technology will continue to play a key role in occupational therapy service
delivery in the future (Jacobs, 2011). This role may include items such as the use of electronic
ADLs, telemedicine and telehealth (Jacobs, 2011), the use of Web-based electronic documentation
programs, and computer and smartphone applications.

II. Management, Leadership Principles, and Theory


A. Leadership and management theory: Management has evolved over the years and has
moved from a hierarchical (top down) to a heterarchical process (bottom up; Royeen,
2011). The heterarchical process involves using resources and input from everyone in the
organization (Royeen, 2011).

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B. Management has also evolved from a linear model (proportionate cause–effect) to a
more nonlinear model, such as provided through Dynamical Systems Theory (DNS;
Royeen, 2011).
1. DNS is an “analysis of systems or organizations that change” (Royeen 2011, p. 61). This theory is
said to be “based upon chaos, complexity, and dynamical systems” (Royeen & Luebben, 2003, as
cited in Royeen, 2011, p. 63).
a. Chaos theory: This theory relates to mathematics and discusses how minute changes can cause
large outcomes or effects (Royeen, 2011).
b. Complexity theory: This theory involves the “knowledge and understanding that transcend
linear systems to include a multifaceted worldview” (Royeen, 2011, p. 61).
2. Occupational therapy managers are involved in facilitating and creating changes within the
organization or department (Royeen, 2011).

C. Management and leadership principles and development are important concepts for
occupational therapy managers to understand.
1. Effective occupational therapy managers also need to develop leadership skills (Snodgrass, 2011).
a. Leadership can be defined as the “process of motivating people to perform to their full potential
with a focus on effectiveness” (Snodgrass, 2011, p. 265).
b. Popular types of leadership style include the transformational and transactional leadership
styles (Snodgrass, 2011).
i. Transformational leadership is a style of leadership characterized by motivating others to
reach their highest potential and providing inspiration to others to work effectively together
to meet the goals of the organization or group (Snodgrass, 2011).
ii. Transactional leadership is a “leadership style in which leaders clarify role and task
requirements and provide followers with positive and negative rewards contingent on
successful performance” (Snodgrass, 2011, p. 265).
2. Skills of effective leaders (Snodgrass, 2011)
a. Being goal oriented
b. Being respectful
c. Communicating effectively
d. Planning effectively
e. Using a variety of leadership styles
f. Challenging, motivating, and inspiring others
g. Being a valuable role model
h. Continuing to enhance their leadership skills
3. Strategies to develop leadership skills (Snodgrass, 2011)
a. Leadership training (e.g., at work site, mentoring, continuing education, leadership courses)
b. Networking and building relationships with others
c. Modeling appropriate behavior

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d. Taking risks and challenges
e. Building trust and cooperation with others

III. Staff Management


A. Occupational therapy managers are involved in recruitment and retention of employees.
1. Recruitment: The primary steps in recruitment (Fisher, 2011) are as follows:
a. Determine what positions you want to recruit people for; create or modify a job description.
b. Advertise and let others know about the position.
c. Screen applicants’ resumes to identify qualified applicants.
d. Interview prospective employees.
e. Check references.
f. Extend the job offer to the appropriate candidate.
g. Follow up to determine whether the candidate wants to accept the position.
2. Retention: Retaining excellent employees is as important as initially hiring qualified employees.
Several factors affect whether employees will be satisfied with their job and remain at their current
place of employment (Fisher, 2011). The following factors may help increase job satisfaction:
a. Effective communication (Fyock, 2001, as cited in Fisher, 2011)
b. Job expectations (Fyock, 2001, as cited in Fisher, 2011)
c. Performance review procedure (Fyock, 2001, as cited in Fisher, 2011)
3. Employee termination: Termination may occur if employees are not satisfactorily meeting
performance expectations and do not have the potential to improve their performance or if the
employee follows unethical or unsafe practices (Fisher, 2011).

B. Occupational therapy managers must understand their roles and responsibilities in


supervision of occupational therapy and non–occupational therapy personnel.
1. The Reference Manual of the Official Documents of the American Occupational Therapy
Association, Inc. (AOTA, 2013) includes several documents that identify the roles and
responsibilities of occupational therapists and occupational therapy assistants as well as of how to
manage nonprofessional staff (e.g., aides).
2. Two important documents for understanding the roles, responsibilities, and supervision of
occupational therapy personnel are the Guidelines for Supervision, Roles, and Responsibilities
During the Delivery of Occupational Therapy Services (AOTA, 2009a) and the Standards of
Practice for Occupational Therapy (AOTA, 2010d)
3. State regulations: In addition to understanding AOTA documents, occupational therapy managers
must understand state regulations that guide occupational therapy practice, such as state licensure
requirements, state practice acts, and state regulations (Fisher, 2011).
4. Payers and reimbursement sources: Additionally, occupational therapy managers must be aware of
requirements for payer sources (1) for the reimbursement of services, (2) for supervision, and (3) for
documentation of services (Fisher, 2011).

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C. Communication is a key component of occupational therapy management.
1. Key terms and their definitions
a. Communication refers to communication that occurs in person and virtually. It includes
written communication such as letters, business plans, e-mails, social media, and face-to-face
communication such as Web conferencing, presentations, and meetings (Braveman, 2011).
b. Paralinguistics is “the study of nonverbal communication” (Braveman, 2011, p. 196).
c. Kinesics relates to body language (Braveman, 2011).
d. Proxemics is “the study of space, including the use of personal space during communication”
(Braveman, 2011, p. 195).
e. Dyad relates to in-person communication with a second person (Braveman, 2011).
2. Levels of communication (Barker, 2006, as cited in Braveman, 2011)
a. The reason or rationale why the communication occurs
b. The actual information that is being communicated or discussed between individuals
c. The relationship between the people who are doing the communicating (e.g., peers)
3. Occupational therapy managers can use several strategies for effective communication (Braveman,
2011).
a. Determine the best time for communication.
b. Determine the length of the communication process (e.g., 15 minutes, 1 hour).
c. Identify strategies for communication (e.g., in person, e-mail, Web conference).
d. Contemplate and put thought into the communication.
e. Plan ahead for pertinent communication (e.g., use notes to remind you of important points).
f. Take notes as needed during communication.
4. Nonverbal communication is just as important as verbal communication. The primary components
of nonverbal communication (Braveman, 2011) are as follows:
a. Voice volume, pitch, tone, emphasis on certain words
b. Use of silence
c. Gestures
d. Body positioning, distance between people communicating
e. Eye contact
f. Facial gestures
5. Motivating staff: Occupational therapy managers need to be aware of what motivates their
employees (Phipps, 2011b). General strategies for improving motivation in employees (Phipps,
2011b) are as follows:
a. Provide positive reinforcement, praise, rewards.
b. Treat employees fairly.
c. Listen to employees’ concerns.
d. Delegate appropriate tasks and responsibilities to employees.
e. Include employees in decision making.

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f. Consider incorporating team-building activities.
g. Provide mentoring programs for employees.
6. Resolving conflicts: Conflicts may occur in the occupational therapy work environment, and
managers must be aware of strategies to resolve conflicts in an efficient and effective manner
(Phipps, 2011a). Evidence-based strategies for resolving conflicts (Phipps, 2011a) include the
following:
a. Encourage active communication.
b. Use “I” statements.
c. Use effective listening.
d. Use joint problem solving.
e. Achieve a solution mutually agreeable to all.
f. Stay positive.
g. Avoid uncontrolled emotions.
h. Comment on the idea rather than attacking people personally.
i. Try to come to a resolution.
j. Stay focused on the topic at hand.
k. Be aware of nonverbal communication.
7. Adapting to changes: Occupational therapy managers need to be ready to create change and adapt
to changes that occur in the practice setting (Loveland & Thompson, 2011).
a. Many possible barriers exist to implementing change within the workplace (Mackenzie, 2007, as
cited in Loveland & Thompson, 2011):
i. Inability to trust the senior managerial staff
ii. Staff inadequately prepared for the change
iii. Ineffective communication about the change
iv. Employees not part of the change process
v. Decreased worker motivation
vi. Feelings of incompetence as a result of change
b. Four key ways to assist with organizational change (Longest, Rakich, & Darr, 2000, as cited in
Loveland & Thompson, 2011):
i. Recognize when change needs to occur.
ii. Take steps to plan for the needed change.
iii. Begin to implement the change.
iv. Spend time evaluating the change and the results of the change.

D. Occupational therapy managers are involved in staff professional development and


continuing competence.
1. “Continuing competence is a process involving the examination of current competence and the
development of capacity for the future. It is a component of ongoing professional development”
(AOTA, 2010c, p. S103).

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a. The Standards for Continuing Competence is an official document from AOTA (2010c) that
describes the standards for continuing competence for occupational therapy practitioners.
“Occupational therapists and occupational therapy assistants use these standards to assess,
maintain, and document continuing competence” (AOTA, 2010c, p. S103). It includes the
following standards (AOTA, 2010c):
i. Standard 1: Knowledge
ii. Standard 2: Critical reasoning
iii. Standard 3: Interpersonal skills
iv. Standard 4: Performance skills
v. Standard 5: Ethical practice
2. The rationale for continuing competence (Moyers Cleveland & Hinojosa, 2011) is as follows:
a. It reduces the risk of providing ineffective or harmful services to clients.
b. It improves client quality of care.
c. It improves job promotion opportunities.
d. It facilitates personal professional growth.
e. It meets regulations and requirements.
i. NBCOT® requirements: At the time of this writing, occupational therapy practitioners must
accrue 36 professional development units every 3 years as one component of maintaining
their certification (NBCOT®, 2012).
ii. Payer and reimbursement regulations: Payers of occupational therapy services expect
positive outcomes and may not pay for low-quality services (Moyers Cleveland & Hinojosa,
2011).
iii. State regulatory board regulations: Most occupational therapy state regulatory boards
require a certain amount of continuing education to continue to practice in the state (Moyers
Cleveland & Hinojosa, 2011).
iv. Accreditation regulations: Certain accrediting bodies stress the need for staff development
and continuing competence (Moyers Cleveland & Hinojosa, 2011).
v. Employers: Most employers expect that professionals will remain competent in their field
and may assess competency during a performance review (Moyers Cleveland & Hinojosa,
2011).
3. Occupational therapy practitioners can assess their skills and develop a professional development
plan (Moyers Cleveland & Hinojosa, 2011). The typical steps in developing a professional
development plan (Moyers Cleveland & Hinojosa, 2011) are as follows:
a. Using self-assessment to identify areas of weakness
b. Determining learning that needs to occur on the basis of the results of the self-assessment
c. Reviewing current goals and objectives and determining progress toward prior personal
professional development goals
d. Determining available resources for meeting future goals
e. Changing or modifying prior goals and objectives or determining new goals and objectives

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E. Managers may also be fieldwork educators.
1. The purpose of fieldwork education is to transform occupational therapy students into occupational
therapy clinicians (AOTA, 2009c).
a. Fieldwork education has two levels.
i. The purpose of Level I fieldwork is “to introduce students to the fieldwork experience, to
apply knowledge to practice, and to develop understanding of the needs of clients” (ACOTE®,
2012, p. S61).
ii. The purpose of Level II fieldwork is “to develop competent, entry-level, generalist
occupational therapists” (ACOTE®, 2012, p. S62).
b. For a student to attend Level I or II fieldwork, “a contract must be established between the
site and the academic institution” (Costa, 2011, p. 595). The contract includes items such as
responsibilities of the school and fieldwork site, liability coverage, and maintenance of the
students’ confidentiality and discusses under what conditions the removal of a student may
occur (Costa, 2011).
c. Timing of fieldwork: Level I fieldwork occurs while the student simultaneously takes courses at
the university; Level II fieldwork occurs closer to the end of the occupational therapy curriculum
(AOTA, 2009c).
2. Fieldwork educators and supervisors must have certain attributes. In the official AOTA document
Specialized Knowledge and Skills of Occupational Therapy Educators of the Future (AOTA,
2009b), desired attributes for academic faculty, academic fieldwork coordinators, and occupational
therapy practitioners who are clinical fieldwork educators are as follows:
a. Being visionary (e.g., is a forward thinker)
b. Being a scholar and explorer (e.g., helps search for, use, and produce new knowledge and
disseminate it)
c. Being a leader (e.g., helps to influence other people)
d. Being an integrator (e.g., makes connections and analyzes information)
e. Being a mentor (e.g., facilitates growth in others)
3. Who may conduct fieldwork supervision varies by fieldwork level.
a. Level I fieldwork supervision: Occupational therapy students may be supervised by a licensed
OTR® or credentialed OTR®, as well as by other health care professionals noted in the ACOTE®
(2012, pp. S61–S62) guidelines.
b. Level II fieldwork supervision: Supervision at this level is conducted by a “currently licensed
or otherwise regulated occupational therapist who has a minimum of 1 year full-time (or its
equivalent) of practice experience subsequent to initial certification and who is adequately
prepared to serve as a fieldwork educator” (AOTA, 2012, pp. S63–S64).
c. Level II occupational therapy students have an OTR® as a supervisor, and Level II occupational
therapy assistant students have an OTR® or COTA® (in conjunction with the supervising OTR®)
as a supervisor (ACOTE®, 2012).
d. Initial suggested supervision for Level II fieldwork students is direct and within the line of sight
but can decrease as appropriate (AOTA, 2012).

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e. Some payers regulate the type of supervision required for students in certain settings (Costa,
2011).
4. Billing for students’ occupational therapy services is limited to Level II fieldwork students.
a. According to AOTA, “Level II occupational therapy fieldwork students may provide occupational
therapy services under the supervision of a qualified occupational therapist in compliance with
state and federal regulations” (AOTA, 2012, p. S75).
b. “Occupational therapy services provided by students under the supervision of a qualified
practitioner will be billed as services provided by the supervising licensed occupational therapy
practitioner” (AOTA, 2012, p. S76).
c. Some payers regulate the conditions under which reimbursement of a student’s services can
occur (Costa, 2011)

IV. Compliance
A. Policies and procedures: Occupational therapy managers may need to develop or help
modify the organization’s policies and procedures as changes occur (McCormack, 2011a).
Managers are responsible for communicating the policies and procedures and ensuring
their staff are complying with the required procedures (McCormack, 2011a).

B. Ethics: Occupational therapy practitioners and managers should strive to practice


ethically. The AOTA Code of Ethics and Ethics Standards (AOTA, 2010a; see http://www.aota.org/
en/Practice/Ethics.aspx for additional ethics resources), state regulatory boards, and the
organization’s own policies and procedures help provide guidance for ethical practice.
(Note: Please see the study outline on ethics for further information on this topic.)

C. State regulations: Occupational therapy managers also need to be aware of state


regulations affecting occupational therapy practice such as licensure, certification, or
registration (Willmarth, 2011).
1. Examination and licensure are important steps in complying with regulations
a. The national OTR® and COTA® NBCOT® certification examinations “are constructed based on
the results of the practice analysis studies” (Willmarth, 2011, p. 463).
b. The OTR® exam consists of multiple-choice and simulation questions (Willmarth, 2011).
c. State regulatory boards for occupational therapy may also require licensure, certification, or
registration to provide occupational therapy services in the state (Willmarth, 2011).
2. License renewal: State regulatory boards also require occupational therapy practitioners to renew
their license, certification, or registration at specific intervals (e.g., generally 1 or 2 years; Willmarth,
2011). One condition of renewal often required relates to continuing competency (e.g., staying
current in the field through continuing education and other means; Willmarth, 2011).
3. NBCOT® certification renewal: NBCOT® certification allows occupational therapy practitioners
to use its certification marks (OTR® or COTA®; Willmarth, 2011, p. 463). Occupational therapy
practitioners are not required by NBCOT® to recertify. However, if practitioners choose not to
recertify, their credentials would be changed to OT and OTA (Willmarth, 2011). Occupational

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therapy practitioners should verify whether their state regulations mandate NBCOT® renewal to
practice in the state.
4. Disciplinary actions: State regulatory boards are also responsible for ensuring the safety of
consumers and disciplining practitioners for ethical or practice issues (Willmarth, 2011). (Note:
Please refer to the study outline on ethics for further information on this topic.)
5. State regulatory boards may also delineate requirements for “supervision and role delineation of
occupational therapy assistants and aides in different ways” (Willmarth, 2011, p. 461).

D. Health Insurance Portability and Accountability Act (HIPAA): “A law, also known as the
Kennedy-Kassebaum Act (Pub. L. 104–191), that includes governing the use of standards
and administrative code sets for the electronic exchange of health care data; requires
the use of national identification systems for health care patients, providers, payers
(or plans), and employers (or sponsors); and specifies the types of measures required
to protect the security and privacy of personally identifiable health care information”
(Thomas, 2011, pp. 385–386).
1. National Provider Identifier (NPI): This unique number consists of 10 digits, and each health care
provider and practitioner who bills for services must obtain one (Thomas, 2011).
2. Health information privacy: Occupational therapy practitioners must take care to protect the
identifiable health information of consumers (Thomas, 2011). HIPAA regulations give consumers
the right to obtain or review their medical records and limits disclosure of information (Thomas,
2011).
3. Security: This part of HIPAA discusses privacy and confidentiality of electronic health information
to ensure that they are not improperly accessed or altered (Thomas, 2011).
4. Note: Please refer to the documentation part of the study guide for information on abiding by
HIPAA regulations when completing documentation.

E. Accrediting organizations (and requirements): Occupational therapy managers and


practitioners need to be cognizant of the various accrediting organizations related to
their practice setting and their requirements for accreditation related to occupational
therapy practice (McCormack, 2011b).
1. Joint Commission: The purpose of this accrediting body is “to continuously improve health care for
the public, in collaboration with other stakeholders, by evaluating health care organizations and
inspiring them to excel in providing safe and effective care of the highest quality and value” (Joint
Commission, n.d., p. 1). The commission assesses accreditation on a voluntary basis for hospitals or
certain other health care entities (McCormack, 2011b).
2. CARF International: This organization is “an independent, nonprofit organization focused on
advancing the quality of services you use to meet your needs for the best possible outcomes” (CARF,
n.d., p. 1).

F. Other areas in which compliance issues arise:


1. Americans With Disabilities Act (ADA) Amendments of 2008 (Pub. L. 110–325): This act is
important for both occupational therapy managers and practitioners to understand (Kornblau &
Cheng, 2011).

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a. “The ADA prohibits discrimination on the basis of disability in employment, State and
local government, public accommodations, commercial facilities, transportation, and
telecommunications” (U.S. Department of Justice, 2012, para. 1).
b. Under the ADA, businesses of 15 or more employees are required to provide reasonable
accommodations (U.S. Department of Justice, 2012).
c. These guidelines also relate to occupational therapy students with disabilities on fieldwork
(Kornblau & Cheng, 2011).
2. Copyright issues: Copyright is also an important area of compliance for occupational therapy
managers and occupational therapy practitioners (Kornblau & Cheng, 2011).
a. Copyright “protects authors of published and unpublished works from infringement by others”
(Kornblau & Cheng, 2011, p. 503).
b. Some copyrighted material may be able to be used under an exception of the “fair use”
regulations (Kornblau & Cheng, 2011).
3. Malpractice: Malpractice can also occur in occupational therapy if occupational therapy
practitioners do not provide at least the typical standard of care for a client, resulting in injury to a
client (Kornblau & Cheng, 2011). Strategies for reducing malpractice risk and reducing the risk of
harm to clients (Kornblau & Cheng, 2011) include the following elements:
a. Ensuring staff are providing adequate supervision for those who need it
b. Educating employees and staff in methods to keep their clients safe from harm and encouraging
continuing education related to safety
c. Having employees perform a peer review of others’ occupational therapy treatment sessions
d. Documenting occupational therapy sessions accurately and in a timely manner
e. Using effective communication between occupational therapy practitioners and clients and
treating occupational therapy clients with respect (Kornblau & Cheng, 2011)
4. Fraud and abuse: Occupational therapy clinicians should ensure they are following appropriate
reimbursement guidelines to avoid breaking any laws or committing fraud and abuse (Kornblau &
Cheng, 2011).
a. Medicare regulations prohibit Medicare fraud and abuse, and penalties may result for those who
do commit these crimes (Kornblau & Cheng, 2011).
b. Occupational therapy practitioners who serve as managers should be aware of legislation related
to fraud and abuse (CMS, Medicare Learning Network, 2012; Kornblau & Cheng, 2011) such as:
i. Anti-Kickback Statute (42 U.S.C. §§ 1320a–7b(b))
ii. Stark Law (42 U.S.C. § 1395nn)
iii. False Claims Act (31 U.S.C. §§ 3729–3733)
c. Note: Please refer to the insurance part of the study guide outline for further information on
fraud and abuse regulations.

V. Strategic Planning
A. Occupational therapy managers and clinicians may need to participate in the strategic
planning process.

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1. Strategic planning: “The process of ensuring that an organization’s current purpose, aspirations,
goals, activities, and strategies connect to plans and support its mission” (Strickland, 2011, p. 103)
2. Mission: “An organization’s core, underlying purpose, or basis for its existence, focus, and actions”
(Strickland, 2011, p. 103)
3. Vision: “The ideal state or ultimate level of achievement to which an organization aspires”
(Strickland, 2011, p. 103)
4. SWOT analysis: A process that identifies and analyzes the organization’s strengths and weaknesses
and describes the opportunities and threats that may have an impact on its ability to grow and
prosper (Strickland, 2011).

B. Occupational therapy managers need to understand aspects of program finances and


operational costs.
1. Cash flow: The monetary flow of the organization (money that comes into the organization and that
is used by the organization for expenses; Ellexson, 2011)
2. Budget: A specific way to allocate where the organization’s money is spent, how much money is
allotted for various expenses, and the money that comes into the organization (Ellexson, 2011)
3. Startup costs: The costs associated with opening a business (Ellexson, 2011)
4. Operational costs: The ongoing costs of operating the business (e.g., utilities, rent, equipment;
Ellexson, 2011)

VI. Program Development and Entrepreneurship


A. Evidence-based practice: “The formal gathering and synthesis of information from
research findings through systematic research review to determine best clinical practice”
(Abreau & Chang, 2011, p. 331)
1. Managers and occupational therapy clinicians must understand and use evidence to help justify the
rationale for services and ensure that the interventions used are effective (Abreau & Chang, 2011).
2. The five primary steps in evidence-based practice may be helpful for managers (Abreau & Chang,
2011):
a. Develop a question to study.
b. Peruse and search the literature for evidence.
c. Critically evaluate the evidence that is found.
d. Apply the research findings to practice.
e. Evaluate the implementation of the research to practice.
3. Levels of evidence are categorized in different ways. Here is one example (Abreau & Chang, 2011):
a. Level I: Randomized controlled trials
b. Level II: Cohort studies
c. Level III: Case control studies
d. Level IV: Case report
e. Level V: Other

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B. Collaboration with other professionals: During the course of occupational therapy
management or practice, collaboration with other health care professionals and agencies
is crucial. Health care professionals with whom collaboration might be beneficial are as
follows:
1. “Physical therapists (PTs) are highly-educated, licensed health care professionals who can help
patients reduce pain and improve or restore mobility” (American Physical Therapy Association
[APTA], 2012a, p. 1).
2. “Physical therapist assistants (PTAs) provide physical therapy services under the direction and
supervision of a licensed physical therapist. PTAs help people of all ages who have medical
problems, or other health-related conditions that limit their ability to move and perform functional
activities in their daily lives” (APTA, 2012b, p. 1).
3. Speech–language pathologists “evaluate and diagnose speech, language, cognitive-communication
and swallowing disorders” and “treat speech, language, cognitive-communication and swallowing
disorders in individuals of all ages, from infants to the elderly” (American Speech-Language-
Hearing Association [ASHA], n.d.-a, p. 1).
4. Audiologists “are experts in the non-medical management of the auditory and balance systems”
(ASHA, n.d.-b, p. 1).
5. Recreational therapists “utilize a wide range of activity and community based interventions and
techniques to improve the physical, cognitive, emotional, social, and leisure needs of their clients”
(American Therapeutic Recreation Association, n.d., p. 1).
6. “Social work practice consists of the professional application of social work values, principles, and
techniques to one or more of the following ends: helping people obtain tangible services; counseling
and psychotherapy with individuals, families, and groups; helping communities or groups
provide or improve social and health services; and participating in legislative processes” (National
Association of Social Workers, n.d., p. 1).
7. Respiratory therapists “care for patients who have trouble breathing, for example, from a chronic
respiratory disease, such as asthma or emphysema. They also provide emergency care to patients
suffering from heart attacks, stroke, drowning, or shock” (U.S. Department of Labor, Bureau of
Labor Statistics, 2012, p. 1).

C. Program development: Occupational therapy practitioners or managers may participate


in program development at their practice setting.
1. A program proposal is often used to determine whether the new program should be implemented
(Giles, 2011).
2. Proposals for new programs (Giles, 2011) often include the following components:
a. A description of the population for whom the program is being developed
b. Services the program is expected to provide
c. Anticipated short- and long-term goals and outcomes of the program
d. Results of the needs assessment
i. The needs assessment is conducted to establish the need for the program, such as the
number of people who may benefit from the program and the length of time they may need
the services.

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e. Needed equipment, staffing, and other resources
f. Anticipated strategies to evaluate the success of the program

D. Entrepreneurship: Occupational therapy practitioners may decide to become


entrepreneurs and develop their own private practice or develop a business related to an
emerging area of practice (Vaughn & Sladyk, 2011).
1. An entrepreneur is “an individual who organizes a business venture, manages its operation, and
assumes the risks associated with the business” (Ryan, 2000, as cited in Vaughn & Sladyk, 2011, p.
167).
2. An occupational therapy practitioner who decides to become an entrepreneur should develop a
business plan. Business plans (Giles, 2011) typically include the following components:
a. Background information
b. Discussion of the services to be provided by the business venture
c. An analysis of the current market (e.g., target population to market; competitors)
d. Marketing ideas and strategies
e. Possible staffing needs and training
f. Financial information (e.g., expenses, anticipated income)
g. Location of the business or program, equipment, supplies
h. Strategies for evaluating the success of the business or program

E. Consultation: Occupational therapy practitioners and managers may sometimes serve in


the role of a consultant or provide consultative services during the performance of their
job duties.
1. A consultant is an “advisor, helper, facilitator, outsider, change agent, evaluator-diagnostician,
clarifier, trainer, planner, and advocate” (Jaffe & Epstein, 2011, p. 521).
2. Consultation is the “interactive process of helping others solve existing or potential problems by
identifying and analyzing issues, developing strategies to address problems, and preventing future
problems from occurring” (Jaffe & Epstein, 2011, p. 521).
3. Some settings in which consultants may work (Jaffe & Epstein, 2011) are as follows:
a. Community programs
b. School system, colleges, and universities
c. Industry
d. Hospitals
e. Long-term care settings
f. Organizations
4. Some skills required to be a consultant (Jaffe & Epstein, 2011) are as follows:
a. Effectively communicating with client (written and verbal)
b. Being able to conduct client education and training
c. Reviewing and analyzing issues and problems

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d. Connecting the client to appropriate resources
e. Creating effective relationships with clients
f. Having self-confidence, “maturity, flexibility, a sense of humor, and a sense of timing” (Jaffe &
Epstein, 2011, p. 530)
5. Starting a consulting business also requires networking and establishing oneself as a consultant,
developing a business plan, and marketing your ability to provide consulting services (Jaffe &
Epstein, 2011).

F. Marketing of services is an important aspect of consumer service.


1. Marketing is “the process of identifying and communicating with consumers through a set of
strategies and techniques intended to attract, persuade, and maintain the consumers as purchasers
of services and products” (Gandolf & Hirsch, n.d., as cited in Richmond, 2011, p. 128).
2. Reasons for marketing (Richmond, 2011) are as follows:
a. To meet the goals of the organization or business
b. To identify and achieve the goals of the consumer
c. To make people aware of the services or products the company offers
d. To try to obtain regular consumers
e. To develop a quality product
3. Marketing involves four main strategies (Richmond, 2011):
a. Product
b. Price
c. Location of services
d. Promotion or communication of product’s information to consumers
i. Advertisement (e.g., newspaper ads, postcard about services)
ii. Sales promotion (e.g., free giveaways or samples)
iii. Public relations (e.g., open house)
iv. Personal selling (e.g., business card, flier)
4. Conducting a market analysis involves analyzing the market to see whether the product or services
you would like to sell are desired by consumers (Richmond, 2011). The market analysis may include
conducting an assessment of the organization as well as the environment outside the organization
(Richmond, 2011):
a. Identifying trends in the marketplace
b. Determining the population to market the product or services to
c. Identifying competitors who may have similar products or services
d. Using the SWOT analysis to help make decisions about the product or service (strengths,
weakness, opportunities, threats)
e. Identifying how to build relationships with clients
5. A marketing plan may include the following information (Richmond, 2011):

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a. Information about the company marketing the items
b. Description of the company’s mission statement
c. Information about the population for which the services or product are being marketed
d. Identification of the particular services or products the company hopes to market
e. Competition for similar products or services
f. Reasons for marketing
g. Strategies to market the product or services
h. Strategies to identify the success of the marketing plan
6. The marketing plan (Richmond, 2011) is then written and implemented.

G. Writing grants may help obtain needed funds for program development, research, or
education.
1. Reasons for pursuing grant funding may include research activities and educational opportunities
(Wilson, 2011).
2. Public funding may include grants from federal agencies (e.g., National Institutes of Health; Wilson,
2011). Grants.gov is an effective Web site for locating available grants (Wilson, 2011).
3. Private funding may be available from a variety of foundations. Foundationcenter.org is one way to
identify foundations that may offer grant funds (Wilson, 2011).
4. A grant proposal typically includes the following major components (Wilson, 2011):
a. Cover letter
b. Abstract or project summary
c. Problem statement
d. Objectives and outcomes of the activities for which funds are being requested
e. Methods, activities, or equipment for which funds are being requested
f. Strategies for evaluating the funded activities
g. Budget and finances needed
h. Project dissemination

H. Advocacy at all levels is an important component of occupational therapy practice.


1. Advocacy is “the act of speaking up, or pleading the case of another” (Lamb, Meier, & Metzler, 2011,
p. 441).
2. Advocacy is important in occupational therapy: Sometimes occupational therapy practitioners need
to advocate for services for a particular client, advocate for payment for services, or advocate for
legislation that is beneficial for clients they may treat (Lamb et al., 2011).
3. Advocacy can be conducted at the local, state, and federal levels (Lamb et al., 2011).
4. The following federal legislation has had a significant impact on occupational therapy practice
(Lamb et al., 2011):

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a. Education for All Handicapped Children Act of 1975 (Pub. L. 94–142): This legislation provided
“equal access to education for children with physical and mental disabilities” (Lamb et al., 2011,
p. 445).
b. Individuals With Disabilities Education Act of 1990 (Pub. L. 101–476): This legislation provided
for services for those younger than 3 years old (Lamb et al., 2011).
c. Americans With Disabilities Act of 1990 (Pub. L. 101–336): This legislation provided rights to
people with disabilities (Lamb et al., 2011).
d. Health Insurance Portability and Accountability Act (Pub. L. 104–191): This legislation protects
consumers’ private health information (Lamb et al., 2011).
e. Balanced Budget Act of 1997 (Pub. L. 105–133): This legislation, along with several others,
resulted in changes to the reimbursement of occupational therapy and related services under
Medicare (Lamb et al., 2011).
f. Patient Protection and Affordable Care Act of 2010 (Pub. L. 111–148): This piece of legislation is
also known as health care reform. It creates many changes in the health care system that will be
phased in over several years (Lamb et al., 2011).
5. Examples of advocacy strategies (Lamb et al., 2011) are as follows:
a. Study and read about the issues.
b. Write letters or e-mails to policymakers.
c. Visit policymakers and talk to them about issues.
d. Testify on issues related to occupational therapy practice.
e. Participate in political action committees.

VII. Program Evaluation and Quality Improvement


A. Definitions
1. Program evaluation “examines the therapeutic process and forms the basis for program
improvements” (Prabst-Hunt, 2002, as cited in Precin, 2011).
2. Continuous quality improvement is “a management process that evaluates the arrangement of
people, equipment, and procedures in a series of tasks intended to repeatedly produce a desired end
result” (Joint Commission, 2004, as cited in Loveland & Thompson, 2011, p. 429).

B. Program evaluation
1. Reasons for completing an evaluation of an occupational therapy program or service (Precin, 2011)
include that it has the following benefits:
a. Provides support for program or intervention.
b. Assists with marketing services.
c. Assists with program or service improvement.
d. Provides research evidence useful to others.
e. Assists with reimbursement of services or obtaining funding for services.
f. Helps to justify the program and explain outcomes achieved from program participation.

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2. Major steps in evaluating an occupational program or intervention (Precin, 2011) are as follows:
a. Identifying who received services (e.g., demographic information, impairments or diagnoses,
and other pertinent information required for the evaluation; Precin, 2011)
b. Describing the services the recipients received in detail (Precin, 2011)
c. Determining the outcomes of the services received (e.g., wellness, prevention, occupational
engagement; AOTA, 2008b; Precin, 2011)
d. Choosing appropriate assessments and measures to evaluate the program or services (Precin,
2011):
i. Reliability generally “indicates how well an assessment produces consistent scores over
time and across raters” (Precin, 2011, p. 409). Several different types of reliability exist
(intrarater, interrater, etc.).
ii. Validity generally indicates “the degree to which an assessment measures what it states it
measures” (Precin, 2011, p. 409). Several types of validity exist (e.g., content, construct).
e. Deciding on an appropriate experimental design to evaluate the program or services (e.g.,
randomized controlled trial, single-case design; Precin, 2011)
f. Determining appropriate research questions to evaluate the program or services (Precin, 2011)
g. Reviewing, analyzing, and interpreting the collected data (Precin, 2011)
h. Identifying strategies for program or service improvement (Precin, 2011)
i. Disseminating the information or results from the evaluation (Precin, 2011)

C. Continuous quality improvement approach: FOCUS–PDCA (detailed below) is one


method frequently used to determine what problems exist and identify strategies to
correct the problems (Joint Commission, 2004, as cited in Loveland & Thompson, 2011):
1. Find out what type or process within the organization needs to be improved.
2. Organize a group of people that has an understanding of the process that requires
improvement.
3. “Clarify the issues surrounding the process by asking ‘who, what, when, and where’”
(Loveland & Thompson, 2011, p. 429).
4. Understand why the process or procedure demonstrates inconsistency.
5. Select a solution that may help remediate the problems.
6. Plan for improving the process.
7. Do the improvements.
8. Check whether the improvements were effective.
9. Act “to ensure that improvements are maintained and to improve the team performance
during the FOCUS–PDCA cycle” (Loveland & Thompson, 2011, p. 430).

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Standards of Practice
I. Standards of Practice for Occupational Therapy
A. Purpose: “Defines minimum standards for the practice of occupational therapy” (AOTA,
2010d, p. S106)

B. Occupational therapists and occupational therapy assistants are required to abide by


federal and state laws (AOTA, 2010d).

C. Education, examination, and licensure requirements: Abbreviated educational,


examination, and licensure requirements and the standards of practice are listed here.
Refer to the full document for further details (AOTA, 2010d).
1. “To practice as an occupational therapist, the individual trained in the United States” (AOTA,
2010b, p. S106) must meet the following requirements:
a. “Graduated from an occupational therapy program accredited by the Accreditation Council for
Occupational Therapy Education (ACOTE®) or predecessor organizations” (AOTA, 2010d, p.
S106)
b. Successfully completed supervised fieldwork (AOTA, 2010d)
c. Passed an occupational therapist entry-level exam (AOTA, 2010d)
d. Completed “state requirements for licensure, certification, or registration” (AOTA, 2010d, p.
S106)
2. “To practice as an occupational therapy assistant, the individual trained in the United States”
(AOTA, 2010d, p. S106) must meet the following requirements:
a. “Graduated from an occupational therapy assistant program accredited by ACOTE® or
predecessor organizations” (AOTA, 2010d, p. S106)
b. Successfully completed supervised fieldwork (AOTA, 2010d)
c. Passed an occupational therapy assistant entry-level exam (AOTA, 2010d)
d. Completed “state requirements for licensure, certification, or registration” (AOTA, 2010d, p.
S106)

D. Standards: The standards are presented here in abbreviated form. Refer to the primary
document for further details (AOTA, 2010d).
1. Standard I: Professional Standing and Responsibility
a. Services provided “reflect the philosophical base of occupational therapy and are consistent with
the established principles and concepts of theory and practice” (AOTA, 2010d, p. S107).
b. The practitioner understands and follows necessary AOTA and federal, state, and other
pertinent regulatory and payer guidelines.
c. The practitioner keeps up to date with licensure, registration, and certification requirements
and follows the Code of Ethics and Ethics Standards (AOTA, 2010a) and the Standards for
Continuing Competence (AOTA, 2010c).

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d. The practitioner is responsible for the delivery of safe and effective occupational therapy services
(AOTA, 2010d).
e. The practitioner maintains updated knowledge of topics that affect clients or occupational
therapy practice (e.g., payer regulations, policies and legislation; AOTA, 2010d).
f. The practitioner stays knowledgeable and applies knowledge about evidence-based research
(AOTA, 2010d).
g. The practitioner respects all clients (AOTA, 2010d).
2. Standard II: Screening, Evaluation, and Reevaluation
a. An occupational therapist is responsible for all aspects of the screening, evaluation, and re-
evaluation process” (AOTA, 2010d, p. S108).
b. An occupational therapist “accepts and responds to referrals in compliance with state or federal
laws, other regulatory and payer requirements, and AOTA documents” (AOTA, 2010d, p. S108).
c. The occupational therapist works with the client to complete the evaluation process (AOTA,
2010d).
d. The occupational therapy assistant “contributes to the screening, evaluation, and re-evaluation
process by implementing delegated assessments” and reporting pertinent observations to
the occupational therapist, while following federal, state, payer, or other regulations and
information in AOTA documents (AOTA, 2010d, p. S108).
e. Occupational therapy practitioners follow pertinent protocols using current and relevant
assessment tools (AOTA, 2010d).
f. The occupational therapy assistant “contributes to the documentation of evaluation results,” and
the occupational therapist completes, analyzes, interprets, and “documents the occupational
therapy evaluation results” within the required time frames (AOTA, 2010d, p. S108).
g. The occupational therapy practitioner abides by confidentiality and privacy regulations while
communicating results of evaluation and reevaluation (AOTA, 2010d).
h. The occupational therapist “recommends additional consultations to refer clients to appropriate
resources” as needed (AOTA, 2010d, p. S109).
i. “The occupational therapy practitioner educates current and potential referral sources
about” occupational therapy services and how to initiate a referral for services (AOTA,
2010d, p. S109).
3. Standard III: Intervention
a. The occupational therapist has the main responsibility for developing, documenting, and
implementing the occupational therapy intervention following appropriate timelines, formats,
regulations, requirements, and standards (AOTA, 2010d).
b. The occupational therapist and occupational therapy assistant work collaboratively with
the client to “develop and implement the intervention plan” (AOTA, 2010d, p. S109) using
professional judgment and clinical reasoning to identify interventions appropriate for each
client (AOTA, 2010d).
c. The occupational therapy assistant “selects, implements, and makes modifications to
therapeutic interventions that are consistent” with “demonstrated competency and delegated

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responsibilities, the intervention plan, and requirements of the practice setting” (AOTA, 2010d,
p. S109).
d. The occupational therapist “modifies the intervention plan throughout the intervention process
and documents changes in the client’s needs, goals, and performance” (AOTA, 2010d, p. S109),
and the occupational therapy assistant can contribute to modifying the plan (AOTA, 2010d).
e. The occupational therapist and occupational therapy assistant follow appropriate regulations
and requirements for documenting the provision of occupational therapy services (AOTA,
2010d).
4. Standard IV: Outcomes
a. The occupational therapist has the primary responsibility for “selecting, measuring,
documenting, and interpreting expected or achieved outcomes that are related to the client’s
ability to engage in occupations” (AOTA, 2010d, p. S109).
b. The occupational therapist has the primary responsibility for documenting clients’ performance
changes, transitioning clients to other services, changing the intensity of occupational therapy
services, and discontinuing services (AOTA, 2010d).
c. The occupational therapist “prepares and implements a transition or discontinuation plan,” and
the occupational therapy assistant contributes to the plan (AOTA, 2010d, p. S110).
d. Both the occupational therapist and the occupational therapy assistant facilitate “the transition
or discharge process in collaboration with client, family members, significant others, other
professionals . . . and community resources” (AOTA, 2010d, p. S110).
e. The occupational therapist has the primary responsibility for determining “the safety and
effectiveness of the occupational therapy processes and interventions within the practice
setting,” and the occupational therapy assistant contributes to this process (AOTA, 2010d, p.
S110).

II. Scope of Practice for Occupational Therapy


A. Purpose: To “define the scope of practice in occupational therapy” (AOTA, 2010b, p.
S70).

B. The Scope of Practice describes the domain and process of occupational therapy (based
on the Occupational Therapy Practice Framework: Domain and Process, 2nd ed.;
AOTA, 2008b) and the educational and certification requirements to become an OTR® or
a COTA® (AOTA, 2010b). Abbreviated information is provided here. Please see the full
document for further details (AOTA, 2010b).

C. Occupational therapy practice: The Scope of Practice (AOTA, 2010b) delineates the practice
of occupational therapy as follows:
1. Intervention methods or strategies (AOTA, 2010b, p. S71)
a. “Establishment, remediation, or restoration of a skill or ability”
b. “Compensation, modification, or adaption” (e.g., activity, environment)
c. “Maintenance and enhancement of capabilities”
d. “Health promotion and wellness”

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e. “Prevention of barriers to performance, including disability prevention”
f. Note: At the time of this writing, the Scope of Practice (AOTA, 2010b) and the Framework
(AOTA, 2008b) use differing terminology for the intervention methods or strategies. For
example, the Framework uses the term approaches rather than intervention methods (AOTA,
2008b).
2. Evaluation of factors
a. Client factors (e.g., values, beliefs, spirituality; body functions such as neuromusculoskeletal
functions; body structures such as structures related to the nervous system; AOTA, 2008b,
2010b)
b. “Habits, routines, roles, and behavior patterns” (AOTA, 2010b, p. S71)
c. Contexts and environments (e.g., cultural, personal, temporal; AOTA, 2010a)
d. “Performance skills, including motor, process, and communication/interaction skills” (AOTA,
2010b, p. S71)
3. Interventions and procedures
a. Please refer to the Scope of Practice (AOTA, 2010b) for interventions and procedures.

D. Occupational Therapy Practice Framework: Domain and Process (2nd ed.)


1. Domain: “The focus of occupational therapy” (AOTA, 2010b, p. S72)
2. Process: “The delivery of occupational therapy” (AOTA, 2010b, p. S72)
3. Client: Individuals (e.g., person with a hip fracture), organizations (e.g., Area Agency on Aging), or
populations (e.g., people with arthritis; AOTA, 2010b)
4. In the domain of occupational therapy, services help clients engage in a variety of occupations
(AOTA, 2008).
a. At the time of this writing, the following areas of occupation are included in the Framework
(AOTA, 2008, 2010b):
i. ADLs
ii. IADLs
iii. Rest and sleep
iv. Education
v. Work
vi. Play
vii. Leisure
viii. Social participation
5. The process of occupational therapy relates to “evaluating, intervening, and targeting outcomes”
related to the domain of practice (AOTA, 2010b, p. S73)
a. Evaluation includes developing an occupational profile and analyzing a client’s performance of
occupations (AOTA, 2008b, 2010b).
b. Intervention includes developing an intervention plan, implementing the intervention, and
performing a review of the intervention strategies (AOTA, 2008b, 2010b).

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c. Outcomes include “supporting health and participation in life through engagement in
occupations” (AOTA, 2008b, p. 660). Examples of outcomes are listed in the Framework
(AOTA, 2008b).

E. Practice settings and focus areas


1. Occupational therapy clients consist of individuals, organizations, and populations (AOTA, 2008b).
2. Occupational therapy clients may be any age (AOTA, 2008b).
3. Examples of the types of areas in which occupational therapy practitioners may practice are “mental
health, work and industry, rehabilitation, disability and participation, productive aging, and health
and wellness” (AOTA, 2010b, p. S75).
4. Examples of practice settings in which occupational therapy practitioners may work (AOTA, 2010a)
are as follows:
a. Inpatient settings such as nursing centers, acute care hospitals, and psychiatric hospitals
b. Outpatient settings such as clinics, therapy or medical offices, and hospitals
c. Community settings such as homes, schools, day care centers, businesses, and fitness centers
d. Research centers

F. Education and certification requirements


1. The Scope of Practice (AOTA, 2010b) lists similar educational and certification requirements as
previously reviewed in the section on the Standards of Practice for Occupational Therapy (AOTA,
2010d).

Working With a Certified Occupational Therapy Assistant


I. Certified Occupational Therapy Assistant (COTA®)
A. A COTA® is a “graduate of an accredited occupational therapy assistant program who has
completed fieldwork and passed the certification examination by the National Board for
Certification of Occupational Therapy” (Youngstrom, 2009, p. 1163).

B. A COTA® is “trained and educated in basic occupational therapy approaches and


techniques, and their role is one of assisting the occupational therapist with the delivery
of services” (Youngstrom, 2009, p. 939).

II. The OTR®–COTA® Relationship


A. The OTR® and COTA® have a type of partnership in which the COTA® must be supervised
by an occupational therapist in the delivery of occupational therapy services.

B. The OTR® and COTA® collaborate to determine the mutually preferred plan of
supervision (AOTA, 2009a).

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C. The OTR® works with the COTA® to obtain service competency, which is “the process
of teaching, training, and evaluating in which the OTR® determines that the COTA®
performs tasks in the same way that the OTR® would and achieves the same outcomes”
(Youngstrom, 2009, p. 943).
1. Establishing service competency with the COTA® ensures that services provided by both the OTR®
and the COTA® are safe and effective (Youngstrom, 2009, p. 943).
2. Methods to establish service competency include direct supervision, such as “observation or
cotreatment, return demonstration of techniques or skills, review of documentation, testing for
knowledge and its application, and discussion of cases to ascertain clinical reasoning and judgment”
(Youngstrom, 2009, p. 944)
3. After initial service competency is obtained, the OTR® periodically rechecks to ensure skills are
maintained (Youngstrom, 2009, pp. 944–945).

III. Basic Principles of Supervision


A. Supervision refers to overall guidance and promotion of professional growth and
competency. The OTR® and COTA® must determine the suitable quality and frequency of
supervision. Both the OTR® and the COTA® must identify when supervision is warranted
and match supervision to level of competence (AOTA, 2009a).

B. Entry-level OTRs® should be capable of supervising COTAs® with knowledge of the


collaborative nature of this supervisory relationship; entry-level COTAs® are also
required to understand this process and seek supervision appropriately. COTAs® may
qualify as assistive technologists or activity program directors and, because these
positions do not require delivery of occupational therapy services, do not require
supervision from an OTR® (Youngstrom, 2009, p. 940).

C. Supervision varies by clientele and practice setting, as well as by skills of the OTR®
and COTA®. Specific laws vary by state. For a complete breakdown of state-by-state
regulations, see “State OT Statutes and Regulations” (AOTA, n.d.), at http://www.aota.
org/en/Advocacy-Policy/State-Policy/Licensure/StateRegs.aspx.

D. Increased supervision may be needed with complex patients or a large and diverse
caseload. Moreover, supervision above what is minimally required may be necessary to
ensure safe and effective delivery of occupational therapy services (AOTA, 2009a).

IV. Methods of Supervision


A. Direct: Direct supervision is face-to-face and includes observation, modeling,
cotreatment, discussions, teaching, and instruction.

B. Indirect
1. Indirect supervision occurs by phone or written or typed communication and receiving feedback
from others (clients and their family members, other staff members).

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2. The OTR® should create a full picture of the performance of the COTA® by sporadically including
direct feedback approaches in supervision (AOTA, 2009a; Youngstrom, 2009, p. 942).

V. Documentation of Supervision
A. Supervision must meet site-specific and state requirements.

B. Supervision should include frequency, method and type, content reviewed, evidence
that supports competency, and names and credentials of the COTA® and OTR® (AOTA,
2009a).

VI. Roles and Responsibilities During the Delivery of Occupational Therapy


Services
A. The OTR® is responsible for all aspects of occupational therapy service delivery and
is fully accountable for the safety and effectiveness of the evaluation, intervention
planning, intervention implementation, intervention review, and outcome evaluation
(AOTA, 2004).
1. Evaluation
a. The OTR® performs the evaluation and directs all parts of the evaluation process.
b. The OTR® interprets the gathered data and creates an intervention plan.
c. The COTA® may contribute to the evaluation process by performing delegated assessments and
delivering reports of observations and client capacities to the OTR®.
d. The OTR® analyzes the feedback from the COTA® and incorporates that information into the
evaluation process (AOTA, 2009a).
2. Intervention planning
a. The OTR® is responsible for creating the intervention plan, but the OTR® and COTA® partner
with the client to develop this plan.
b. The COTA® must understand the evaluation results and be able to offer client-centered input
into the intervention plan (AOTA, 2009a).
3. Intervention implementation
a. The OTR® is responsible for implementation but may delegate components to the COTA® while
offering adequate supervision.
b. The COTA® must be knowledgeable about the client’s goals and will choose appropriate
therapeutic activities and interventions and modify them as needed, adhering to client goals and
demands of the practice setting (AOTA, 2009a).
4. Intervention review
a. The OTR® judges a client’s need to continue, modify, or stop occupational therapy services on
the basis of information and documentation from the COTA® about the client’s feedback and
performance during the intervention process (AOTA, 2009a).

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5. Outcome evaluation
a. The OTR® selects, measures, and analyzes outcomes as they pertain to a client’s occupational
engagement.
b. The COTA® must understand the client’s specific outcomes and then document and provide
information related to progress.
c. The COTA® may measure outcomes and offer clients discharge resources (AOTA, 2009a).

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Additional Resources
Medicare Fraud and Abuse:
• http://www.aota.org/Advocacy-Policy/Federal-Reg-Affairs/Resources.aspx
Coverage and Reimbursement:
• http://www.aota.org/Advocacy-Policy/Federal-Reg-Affairs/Pay.aspx
• http://www.cms.gov/Medicare/Medicare-General-Information/MedicareGenInfo/index.html

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