Michigan Occupational Therapy Association

FAQ

AnchorLicensure

Rules & Regulations

Practice

Students

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What does licensure mean?
Please note the distinction between NBCOT and state licensure. NBCOT is a voluntary organization; you may choose to belong or not to belong with no penalty after your first year. State licensure is mandatory. You may not practice legally in the state of Michigan without a license. It‘s against the law. People found practicing without a license will be prosecuted by the state.

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AnchorWhat steps do I need to take to earn licensure in Michigan?

The following criteria must be met to receive a license to practice occupational therapy in the state of Michigan: 

  • Graduate from an accredited occupational therapy program
  • Pass the National Board of Certification in Occupational Therapy (NBCOT) exam
  • Demonstrate evidence of good moral character, which means the propensity of the person to serve the public in a fair, honest, and open manner (338.41)
  • Possess a working knowledge of English language
  • Pay the required fee associated with the application
  • Complete fingerprinting and background check
  • Submit the  https://www.michigan.gov/som/404licensure application through the state of Michigan

The Michigan State Police have contracted with Integrated Biometric Technology (IBT), to perform the fingerprint scans. Information about how to schedule a fingerprinting appointment and the form that must be taken to the appointment is included in each licensing/registration application packet. There is a fee of $65.25 that each applicant must pay to IBT for this service. This is in addition to the state application fee. 

Comprehensive information about licensing and the practice of OT in Michigan is available on the State website on the MICHIGAN – OCCUPATIONAL THERAPIST LICENSING GUIDE.

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Does the State of Michigan require that OTs be a member of NBCOT or do they just need to have a license in Michigan?

Maintaining NBCOT registration or certification is not required in the state of Michigan to maintain licensure.

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AnchorDoes the State of Michigan offer a temporary license for new graduates who have yet to pass their board exam?

No. Temporary licenses are not available in the State of Michigan.

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AnchorIs there anything new I need to know about to maintain my license?

1. Jurisprudence Exam: The Bureau of Professional Licensing - Licensing Division in the state of Michigan, recently announced the addition of a new requirement to the occupational therapy and occupational therapy assistant license application. A Jurisprudence Examination (see pages 5-8) is now part of the application for an OT/OTA license in the state of Michigan for anyone applying for licensure after August 23rd, 2016. Effective June 1, 2017 licensure candidates must take the jurisprudence examination through PSI (www.psiexams.com).
The Jurisprudence Examination covers information from two documents:
1.  Michigan Public Health Code
2.  Michigan Rules and Regulations for an OT/OTA

Evidence of continuing professional development will be required for renewal of licensure. The Public Health Code, in MCL 333.18313, requires the completion of an appropriate number of hours of continuing education or continuing competence activities for license renewal. However, administrative rules implementing the continuing education requirements have not been created. Until administrative rules for continuing education are implemented, you are responsible for maintaining your competence in your profession but you do not have to demonstrate the ways you are doing that for renewal.
 
2. Human Trafficking Training: Beginning October 19, 2022, Proof of completion of a one-time training to identify victims of human trafficking is required.

3. Continuing Education Requirement:  Beginning for license renewals in 2019, Proof of 20 continuing education contact hours over 2 year renewal period is required. A minimum of 10 hours must be completed in-person with live, synchronous contact. A minimum of 1 hour of continuing education in pain and symptom management is required.

; For the most current licensing information, view the LARA Occupational Therapy Licensing Guide.

The Michigan Board of Occupational Therapists will also be developing rules related to a lapsed license. Currently, if a license is lapsed more than three years, and you do not hold a current license in another state, the therapist is required to retake the NBCOT certification examination.
 
As a reminder, when your license lapses, you can no longer practice your profession nor can you identify yourself as a licensed or registered individual. Reimbursement for your services may be jeopardized. Practicing without a valid license is a felony under the Public Health Code and can result in legal proceedings as well as disciplinary actions.

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AnchorHow long are the Occupational Therapist/Occupational Therapy Assistant licenses issued for? Can I renew my license early? How will I know when I need to renew?

Your initial Occupational Therapist/Occupational Therapy Assistant license is only good until the next expiration date of your profession (anywhere from 4 months to 1 year). After your first renewal, your license will be valid for 2 years. You will receive a renewal application 45-60 days prior to the expiration date of your license and it will state the renewal fee required. 
You cannot renew your license early. The State system is not set up to receive renewal information until the renewal time for your profession. The State will mail you renewal information approximately 45-60 days before the expiration date of your current license. Remember to notify the Department of Licensing and Regulatory Affairs in writing of any address changes you have. It is your responsibility to renew your license on time. Failure to notify the State of an address change does not exempt you from renewing your license on time. You can renew online at www.michigan.gov/elicense . Online renewal payments require you to pay with a credit card. http://www.michigan.gov/lara/0,4601,7-154-72600_72603_27529_27545-178586--,00.html

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AnchorDoes licensure reciprocity exist between Michigan and other states?

No, there is nothing in place yet. AOTA working on a sub group to address this issue.

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AnchorWhat is the Board of Occupational Therapy?
The Michigan Board of Occupational Therapists is authorized by the state legislature to develop rules and regulations and monitor the profession so that public safety is protected. The Michigan Board of Occupational Therapists is a legislative arm of the state and is not related to the Michigan Occupational Therapy Association, which is a voluntary professional organization.
 
The current members of the OT Board of Michigan are:

Donald FregaProfessional MemberRoyal OakTerm Expires: 12/31/25
Camron MooreheadProfessional MemberSalineTerm Expires: 12/31/25
Matthew SwanProfessional MemberEaton RapidsTerm  Expires: 12/31/25
Melissa MafiahPublic MemberLivoniaTerm Expires: 12/31/23
Mary Jo VaughnProfessional MemberWetmoreTerm Expires: 12/31/22

Information about OT regulation and the Michigan Board of Occupational Therapists can be found at
http://www.michigan.gov/lara/0,4601,7-154-35299_63294_27529_27545---,00.html

The Public Health Code, which includes the regulation of OT profession, is available here: 
http://www.legislature.mi.gov/(S(4m2mihvau011eeqp23d1pgm0))/mileg.aspx?page=getObject&objectName=mcl-368-1978-15-183 

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AnchorWhat is the difference between MiOTA and the Board of Occupational Therapy?
The Board of OT and MiOTA are two separate and unrelated entities. While MiOTA‘s mission and values are to be the voice for OT in Michigan and is a volunteer run, membership-based organization, the Board of OT is the entity which makes the rules and issues the licenses for the state. Its members must be appointed by the governor. MiOTA is not the state board. The Board of OT is the state board. MiOTA works hard to disseminate information when the board of OT puts it out, but there are some questions that really are more within their jurisdiction to answer as they make the rules.

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AnchorCan I have any input into the development of the rules and regulations?
The development of the Rules has been completed and they are available here:  
http://w3.lara.state.mi.us/orr/Files/AdminCode/1530_2015-029LR_AdminCode.pdf

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AnchorDo Occupational Therapists in the State of Michigan have direct access (i.e can provide OT services to clients without a physician's script)?
Yes, OTs are not limited in our practice act to require a script before providing evaluation and treatment.  Insurance companies do often require, but if you only do cash pay, that would not affect you.  The only exception that you may have is that some malpractice insurances may require you to have a script to be insurable.

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AnchorIf you get a script for OT from an NP or PA , is their signature enough on the evaluation or does it also require the physician's signature ( according to Medicare rules)?

NP's and PA's are referred to as Non-physician Providers by Medicare, commonly abbreviated as NPP or NPP's. 

Michigan‘s OT practice act does not restrict us from accepting scripts from NP's and PA's, however, historically, Michigan's PT practice did restrict them, so you may have heard of the restriction because of that. 

In regards to Medicare, scripts from NPP's are acceptable. Prior to 1998, they were only acceptable in rural health care areas (provider shortage areas). 

You can read more at (majority of info you are looking for is around page 10 but up to page 10 is useful as well):
https://www.cms.gov/Research-Statistics-Data-and-Systems/Monitoring-Programs/Medical-Review/Downloads/TherapyCapSlidesv10_09052012.pdf

And you may also find this helpful: 
https://oig.hhs.gov/oei/reports/oei-02-00-00290.pdf

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AnchorWhat are the reentry requirements for the OT profession in Michigan?

Michigan is a licensure state now and therefore we do not require certification.  However there are considerations to take into account here. First if you maintained your licensure in another state then that is a consideration.  If you did not have licensure in another state and did not have active certification then there are parameters that you need to take into account.  Michigan is in the process of finalizing its rules and regulations of licensure.  If you did not maintain licensure then I would suggest you begin with renewing your certification via NBCOT:http://www.nbcot.org/certification-renewal-process.  I will attached the proposed licensure for Michigan so you may use that as your guideline for now.

You can find additional information regarding the process at:
http://www.michigan.gov/documents/lara/Occupational_Therapy_517652_7.pdf
 
http://www.michigan.gov/documents/lara/OT_Endorsement_app_450151_7.pdf
 
http://www.michigan.gov/lara/0,4601,7-154-72600_72603_27529_27545---,00.html

 
How often does in-person supervision need to occur or how often does phone/other supervision need to occur? How should the supervision be documented? Should it be documented per COTA or per consumer?


Yes the state practice act clearly defines a live meeting (does not need to be face to face can be telephonic) for supervision monthly that is documented and signed by both parties. The documentation is by the COTA supervised, not consumer. However, based on regulatory requirements co-signature of notes are often required not be state practice act but by payer requirements. There is no particular document that is required however the State Practice Act defines that the OTL needs to determine if the OTAL requires general or direct supervision for any interventions. I would start the practice of documentation of supervisory visits to include IF any interventions require direct supervision.

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AnchorWhat are the regulations in Michigan for providing OT services via telehealth?

Currently, Michigan OT regulations have no language regarding the capacity to deliver services via telehealth modes of service delivery. However, we are working to discuss and define actions that our MiOTA lobbyist could support us with at this time.

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AnchorWhat is the correct way to indicate occupational therapy credientials: OTRL or OTR/L?

Michigan rules and regulations denote that we do not add the forward slash (/).just OTRL or OTAL without the /.

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AnchorDoes MiOTA approve courses for continuing education units for occupational therapists in Michigan? If not, do you know who does?

We currently do not have an approval process as part of our organization. It is a goal that we are working on. There are no approval processes for Michigan besides AOTA providership. However, most courses will meet NBCOT renewal requirements regardless.

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AnchorCan a therapist in Michigan treat a patient with lymphedema without certification? Is the training by a certified therapist to a COTA who has not been certified sufficient?

Since there is an extremely high liability and risk for putting patients into CHF or other complications if it isn't done correctly the preference is you be certified or under the supervision of someone is. Our licensure does not require we be certified to perform lymphedema therapy. However, our licensure does require competency in the areas we do practice in and therefore, whether certified or not, the provider should have sufficient training and/or supervision/guidance to be able to manage, prevent and lower secondary risks of performing lymphedema therapy as well as be able to provide proof of their competency or understanding if their skills are called into question.

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AnchorDoes Michigan have any rules or requirements in place that would prohibit an OT from completing a dysphagia evaluation and treatment?

AOTA has a position paper regarding dysphasia and feeding issues. It can be found here: https://ajot.aota.org/pdfaccess.ashx?url=%2fdata%2fjournals%2fajot%2f936451%2f7112410015p1.pdf

You may want to also check with the Board of OT under LARA as our licensure also specifies that therapist‘s must be able to demonstrate/prove competency in practice areas of which they are treating. 

The Michigan Occupational Therapy Association is a member-driven advocacy organization for the profession of OT in Michigan, and although we contribute via public comment to policies being made in various state levels, we do not set guidelines for training and competency in specific issues. ACOTE (the American certification for Occupational therapy education) sets minimal education guidelines for graduation from accredited programs, the American Occupational Therapy Association (AOTA) sets guidelines for practice and each state board (ours through LARA) sets guidelines for how practice is to be regulated in the state.  Different states have different policies and LARA would be best able to answer that specific question for Michigan; although I do want to note AOTA‘s white paper I cited above does recommend higher standards for higher risk issues.  

Although clinicians may have exposure to this area in classroom education, not all therapists may have clinical practice in this area when they complete fieldwork experiences.  Please reference the AOTA document above.  AOTA does offer a certification program for clinicians wanting to advance their skills.  Info can be found in their website.  I‘ve attached some resources available on the AOTA.org website. They may also be of further assistance to you.  

What would be the liability if a licensed OT provided treatment on a patient not assessed by them but assessed by a healthcare professional of a different discipline?

Based on our review it is not appropriate for OT to use other disciplines evaluations to develop a plan of care and implement treatment. OT can perform multi-dimensional interdisciplinary evaluations where multiple individuals are performing their respective evaluation with others present.

We recommend using the OT Practice Framework Document from AOTA (an official document) to educate on the OT Process which starts with an occupational profile; observe valued important occupations, perform assessments to characterize client factors impacting practice and then proceeding with plan of care and intervention. Our OT evaluation should be distinct from other disciplines.

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AnchorHow long can students keep their student membership rate through MiOTA?
Students can keep their student membership rate throughout their schooling and may renew at the $30 rate for up to two years post-graduation.

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AnchorCan MiOTA waive the fieldwork requirement to allow students to graduate on time, sit for the NBCOT exam and enter the field?
MiOTA is not able to make any adjustments to these requirements as this is part of the Accreditation of Occupational Therapy Education (ACOTE) requirements in order for entry level field requirements to be completed to then sit for a national examination. American Occupational Therapy Association has been contacted regarding this question as well and they agree with our understanding.

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AnchorAre graduates able to practice under supervision once they've passed the NBCOT exam and have applied for licensure?
No, Michigan licensure law prohibits anyone from practicing OT without a license, including new grads whether they have passed the NBCOT exam or not. 

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AnchorHow long from the time an occupational therapy candidate passes their NBCOT board exam until the state of Michigan is able to grant a license?
The state is able to issue licensure to an applicant as soon as all of the requirements are completed.  The timeframe that it takes for the NBCOT exams results to be sent to us is something that you would want to check with the testing company to find out.  Each license of course may have individual circumstances, but in general once the requirements are fulfilled the license is issued immediately.  

Frank,
Customer Service
Bureau of Professional Licensing
September 16, 2016

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