MiOTA Advocacy
Frequently Asked Questions: Occupational Therapy Licensure
Q. What are the identified credentials for an OT and OTA?
A. Below is the
section of the licensure law
that relates to credentials:
Sec. 18303. (1) After the
rules described in sections
18307 and 18309 are promulgated
for licensure under this
article, an individual shall not
use the titles "occupational
therapist", "o.t.",
"occupational therapist
licensed", "o.t.l.",
"occupational therapist
registered", "o.t.r.",
"occupational therapist
registered licensed",
"o.t.r.l.", "certified
occupational therapy assistant",
"c.o.t.a.", "certified
occupational therapy assistant
licensed", "c.o.t.a.l.",
"occupational therapy
assistant", "o.t.a.",
"occupational therapy assistant
licensed", "o.t.a.l.", or
similar words which indicate
that he or she is licensed as an
occupational therapist or
occupational therapy assistant
unless the individual is
licensed under this article.
Accepted
credentials are: OT, OTL, OTR,
OTRL, COTA, COTAL, OTA, OTAL.
Q. How should a student sign their documentation?
A. Students should sign "Student" or "Occupational Therapy Student" or "Occupational Therapy Assistant Student" following their signature. Students do not have credentials. Please check with your fieldwork educator if you have questions.
As a reminder,. you must participate in ongoing certification with NBCOT to use the "R" or the "C".
Information is provided from the Draft Rules and Regulations developed by a task force of the Michigan Board of Occupational Therapists. The draft rules were approved by the Board of Occupational Therapists February 2011. The rules now begin an approximately year-long period of stakeholder and public comment through the state of Michigan. The information provided below is accurate as best understood at this time; however, the state website is the only official site for information about licensure.
Q. I've been offered an OT position. Can I get a temporary permit until I get my license?
A. Temporary permits are not issued by the State of Michigan.
Q. I'm a new graduate and I've been offered an OT position. I'll be taking the NBCOT certification examination soon. Can I work?
A. To present yourself as an OT/OTA or to practice as an OT/OTA, you must hold a current license in Michigan. To be licensed, you must have successfully competed the certification examination and all state requirements for licensure (i.e., you cannot provide OT services until you receive your official license, even with supervision.
Q. I'm a new graduate and I've been offered an OT position. I've successfully passed the NBCOT certification examination and I've applied for Michigan licensure as an OT/OTA. How long with this take?
A. According to the state, it takes about 7-8 weeks for a licensure application to be processed. Students can apply for the license prior to completing the certification examination, which may decrease the time for processing.
Q. I'm a new graduate and I've been offered an OT position. I've successfully passed the NBCOT certification examination and I've applied for Michigan licensure as an OT/OTA. Can I work during the interim until I receive my license?
A. The short answer is No. To present yourself as an OT/OTA or to practice as an OT/OTA, you must hold a current license in Michigan. To be licensed, you must have successfully completed the certification examination and all state requirements for licensure. Some employers are willing to hire a person as an unlicensed person, such as a tech or aide. It is still illegal for you to practice as an OT/OTA. New graduates who are working in such circumstances may not use any credentials and may not provide Occupational Therapy services. They are no longer students so therefore cannot provide OT services under any type of supervision. The use of OT credentials is reserved for people who are licensed in the state of Michigan.
Q. When and how much does it cost today for re-licensure?
A. All OT and OTA renewals are due on May 31. A license is renewed for two years. As a reminder, the date of expiration is printed on your license. The cost for both OT and OTA is $130 in 2010. As a reminder, your license needs to be publicly displayed at your place of work.
Q. Why wasn't I notified when my license needed renewing? Why can't there be a second notice or an email notice?
A. Here is the paraphrased answer from the Public Health Code 16201.1, the broader law within which our OT licensure law is based. "A license shall be renewed on or before the expiration date. The department shall mail a notice to the last known address on file with a board advising of the time, procedure, and fee for renewal. Failure of the licensee to receive notice under this subsection does not relieve the licensee of the responsibility for renewing his or her license."
Notices are sent prior to renewal. However, many people do not update the state on changes of address. The same would be true of email addresses, and these change even more frequently. Changing the method of notification would require an amendment to the Public Health Code by the legislature.
Q. Are there new requirements for re-licensure?
A. Re-licensing: OT's and OTA's must take and pass a jurisprudence examination on the laws specific to occupational therapy in Michigan with a minimum converted score of 75. As of 10-2010, this examination has not been developed. Relicensing Occupational Therapy practitioners must provide evidence of continuing professional development. The requirements for this are not finalized yet. It is hoped that the requirements will be compatible with NBCOT continuing certification requirements. In addition, many OT's and OTA's will continue to demonstrate clinical competence through ongoing NBCOT certification.
Q. I took some years off and just recently discovered that my Michigan license had lapsed by about 3 years. What do I do?
A. If you license has lapsed for less than 3 years, you can be relicensed if you (1) submit a completed application and fee (fine), pass the jurisprudence examination for Occupational Therapy practitioners and meet continuing professional development requirements for all lapsed years.
If your license has lapsed for 3 years and one day or more, in addition to the above, you must also retake and pass the NBCOT examination and complete a period of supervised practice experience. These are required to ensure public safety.
Q. Can OTs and OTA's use physical agent modalities (PAM)?
A. Yes, the use of physical agent modalities was identified within our OT scope of practice. OT's and OTA's must demonstrate competency before using a physical agent modality.
Q. I work in a school setting and I need to know what the rules are regarding needing a prescription for therapy now that licensure has passed.
A. The law continues to be silent on this, which means that a referral is not needed for OT services. Of course, the provision of any third-party reimbursed services for children in school requires a referral for payment.
Q. I use Athletic Trainers in my practice and countersign their notes. Is this OK?
A. Only an OT or an OTA may provide OT services. ATs are unlicensed personnel when working in OT and must be directly supervised. By signing their notes, you assume all legal responsibility for their actions.
Q. Can an OTA evaluate someone?
A. The OTA can certainly participate in the evaluation of clients! The identified limitations are that an OT shall not delegate to the OTA sole development of a treatment plan or the sole evaluation and interpretation of evaluation results.
Q. What are the supervision requirements for OTAs?
A. An occupational therapist shall determine and provide the appropriate level of supervision based on the OTA's education, training, and experience and means one of the following:
"General supervision" means that the OT is not required to be physically present on site, but shall be continuously available at the time the limited activity, task or intervention is performed. Continously available includes availability by telecommunication or other electronic device.
"Direct supervision" means that the OT is physically present with the OTA or immediately available for direction and onsite supervision at the time the limited activity, task or intervention is performed, and that the OT has direct contact with the patient or client during each visit.
Q. Are there other supervision requirements?
A. The supervising OT shall (1) provide predetermined procedures for delegated activities, tasks or interventions, (2) maintain a record of names of OTAs to whom tasks have been delegated, (3) meet in person once a month to evaluate the OTA's performance, review records, and provide education. This meeting shall be documented, with identification of the supervisor and whether the supervision is general or direct.
Q. Two OTAs work with me. Can I supervise two OTAs?
A. An OT shall not supervise more than 3 OTAs at the same time. "At the same time" means, for example, that an OT cannot supervise more than 3 OTAs from 10-11 am. An OT also shall not supervise more than 3 unlicensed persons at the same time.
Q. Licensure will increase my workload. Why is licensure necessary?
A. The law was enacted to protect public safety. In the last two years, at least 23 OTs have had allegations filed against them. All affect the public safety of citizens of Michigan. The majority are for fraud, willful or intentional. In all reviewed cases, the Disciplinary Subcommittee of the Board has consistently expressed zero tolerance for fraud. Other issues submitted to the Disciplinary Subcommittee include practice without a license, failure to exercise due care or violation of general care, and substance abuse.
Q. I know an OT who is charging people when she hasn't seen them. Can I do anything?
A. Yes! Submit an allegation. Read about the process at www.mi.gov/mdch. Beyond being the right thing to do, this is your responsibility, according to Public Health Code Section 333.16222: A licensee having knowledge shall report the conduct and name to the the department. Failure to do so can result in administrative charges (paraphrased).
Q. I know someone who is working as an OT but who never passed the NBCOT examination! What do I do?
A. According to the Public Health Code Section 333.16294: A person who "holds himself or herself out as practicing a health profession without a license or under a suspended, revoked, lapsed, void or fraudulently obtained license or ... who uses as his or her own the license of another person is guilty of a felony." (italics mine)
The process is the same as identified in the previous question.
Q. How can I keep up to date as this continues its process?
A. Routinely check the state website. This is where all official information is posted. Go to www.mi.gov/mdch. On the left, click on "Health Systems and Health Professions Licensing", then "Licensing for Health Care Professionals", and finally "Occupational Therapy".
Q. How can I have input into this process?
A. The work for licensure, and now for development of the rules and regulations, has been ongoing for about five years. The optimal time for input has ended. However, input can still be provided in three ways.
- Board members are listed on the MDCH website, with their contact information. Feel free to contact any one of them.
- Board meetings are public and there is a time for public comment. The dates of all Baord meetings are posted on the MDCH website.
- The state will begin a process of soliciting input from all stakeholders, such as administrators of nursing homes and other professionals, as well as occupational therapy practitioners. A time and place for public discussion will be identified. Watch the state web page.