Arizona Occupational Therapy Association (ArizOTA) P.O. Box 5241 Peoria, AZ

Transcription

1 Arizona Occupational Therapy Association (ArizOTA) P.O. Box 5241 Peoria, AZ Burns & Associates, Inc. Attn: Steven Abele 3030 N. 3 rd Street, Suite 200 Phoenix, AZ, AZDDDRebase@navigant.com Dear Mr. Abele, As representatives of the Arizona Occupational Therapy Association, (ArizOTA) Legislative Committee, we are formally addressing our Association s concerns with the proposed rate structure of occupational therapy services provided by certified occupational therapy assistants. As an association, we believe that the reimbursement of occupational therapy services provided by a licensed occupational therapy assistant should be the same as occupational therapy provided by a licensed occupational therapist. If the Department of Developmental Disabilities (DDD) accepts the reduced reimbursement rate, the Department will be the only payer of occupational therapy services in the state that reimburses a different rate for services provided by an assistant. This will have implications for the availability of services provided to clients of DDD. In support of our position that the rate structure should remain the same, regardless of whether an occupational therapist or an occupational therapy assistant provides the therapy service, we would like to provide: Information regarding the educational and certification process of occupational therapy assistants A comparison of what an occupational therapy assistant can and cannot do within the scope of practice of occupational therapy Definitions of the levels of supervision that is required and the implied responsibility that the occupational therapist assumes when supervising an occupational therapy assistant Data to support that the proposed hourly rate is low for practicing occupational therapy assistants in Arizona In order for a Certified Occupational Therapy Assistant (COTA) to obtain certification and licensure, the individual must first attend an educational institute that is accredited by the Accreditation Council for Occupational Therapy Education (ACOTE). The degree granted for a graduate of an OTA Program is an Associate s degree. The information below outlines the accreditation objectives and standards that ACOTE developed and currently implements. ACOTE requires the following objectives to be met by a graduate of an OTA Program: P.O. Box 5214 Peoria, AZ

2 Page 2 Acquired an educational foundation in the liberal arts and sciences, including a focus on issues related to diversity Educated as a generalist with a broad exposure to the delivery models and systems used in settings where occupational therapy is currently practiced and where it is emerging as a service Achieved entry-level competence through a combination of academic and fieldwork education Prepared to articulate and apply occupational therapy principles and intervention tools to achieve expected outcomes as related to occupation Prepared to be a lifelong learner and keep current with the best practice Uphold the ethical standards, values, and attitudes of the occupational therapy profession. Understand the distinct roles and responsibilities of the occupational therapist and occupational therapy assistant in the supervisory process Prepared to advocate as a professional for the occupational therapy services offered and for the recipients of those services (American Occupational Therapy Association [AOTA], 2007, p. 85) More specifically, the ACOTE Standards provide detailed requirements of the staff, institute, curriculum, and fieldwork experience in an accredited OTA Program. These standards may be reviewed in the attached document, Accreditation Standards for an Educational Program for the Occupational Therapy Assistant. Detailed information related to curriculum requirements is referenced on pages Table A Information Obtained From: A.R.S A.R.S A.R.S A.R.S R A.R.S Arizona Minimum Educational Requirement Tests Required for Licensure/Certification Certified Licensed Annual Continuing Education Requirement for Licensure/Certification Certified Occupational Therapy Assistants (COTAs) Physical Therapy Assistants (PTAs) Speech &Language Pathology Assistants (SLPAs) Associates Degree Associates Degree Associates Degree National Certification Exam (NBCOT) Yes Yes 12 hours biannually National Certification Exam (NPTE) State Jurisprudence Exam (AZLAW) Yes No None N/A No Yes 10 hours annually

3 Page 3 In addition to being licensed within the state of Arizona, occupational therapy assistants are board certified through the National Board for Certification in Occupational Therapy (NBCOT ). In order to be eligible to sit for the NBCOT COTA Exam, an occupational therapy assistant must first graduate with an Associate s degree in occupational therapy from an accredited organization. A graduate of an occupational therapy assistant program must also complete all fieldwork requirements and agree to abide by the NBCOT code of conduct prior to sitting for the exam. At this time, in the state of Arizona, occupational therapy assistants are the only therapy assistants with both licensure and national board certification. Please refer to Table A. Occupational therapists and occupational therapy assistants collaborate in order to provide occupational therapy services that are safe and effective for their clients. State and national guidelines provide general definitions of the roles and responsibilities of the occupational therapist and the occupational therapy assistant, as well as the minimal levels of supervision required. In 2009, AOTA provided guidelines for the roles and responsibilities of the occupational therapy assistant. The occupational therapy assistant should be knowledgeable about the evaluation results of the client and may provide input into the intervention plan. The guidelines further state that the occupational therapy assistant selects, implements, and makes modifications to therapeutic activities and interventions that are consistent with demonstrated competency levels, client goals, and the requirements of the practice setting. For additional specifics regarding the roles and responsibilities of occupational therapists and occupational therapy assistants during the delivery of services, please review the attached document, Guidelines for Supervision, Roles, and Responsibilities During the Delivery of Occupational Therapy Services. (2009, p ). Table B provides an in-depth review of the roles and responsibilities of occupational therapists and occupational therapy assistants during the delivery of services within the state of Arizona. Occupational therapy services provided by an occupational therapy assistant must be supervised by an occupational therapist. Though AOTA has provided guidelines for supervision, more supervision may be required in order to effectively deliver services than are within the state and national practice guidelines, and it is the responsibility of the occupational therapist and occupational therapy assistant to determine appropriate levels when this is the case. As of 2009, AOTA defines supervision as a cooperative process in which two or more people participate in a joint effort to establish, maintain, and or elevate a level of competence and performance. The aim of supervision within the practice of occupational therapy is to ensure safe and effective delivery of services as well as to foster professional competence and development. (AOTA, 2009, p. 797) Table B provides an in-depth review of supervision requirements within the state of Arizona. Minimal levels of supervision are assigned based on the certified occupational therapy assistant s work experience in a particular practice setting or with a particular skill. The occupational therapist is responsible with assigning an appropriate level of supervision greater than the minimum level of requirement if it is deemed necessary for the safety of a patient or client. Due to the supervisory mandates, the occupational therapist assumes all liability for the services provided by the occupational therapy assistant. In the above -mentioned document, AOTA states that ultimately the occupational therapist is responsible for all aspects of occupational therapy service delivery and is accountable for the safety and effectiveness of the occupational therapy service delivery process. The occupational therapy service delivery process involves evaluation,

4 intervention planning, intervention implementation, intervention review, and outcome evaluation. Table B Information Obtained From: Occupational Therapy Supervision Requirements Published By AOTA, State Affairs Group, January 2012 (Unless Otherwise Footnoted) State Citation Legislative/Regulatory Information Arizona Statute: Regulation: R Page 4 Occupational therapy assistant means a person who is licensed pursuant to this chapter, who is a graduate of an accredited occupational therapy assistant education program, who assists in the practice of occupational therapy and who performs delegated procedures commensurate with the person s education and training. "Supervision" means the giving of instructions by the supervising occupational therapist or the occupational therapy assistant that are adequate to ensure the safety of clients during the provision of occupational therapy services and that take into consideration at least the following factors: a. Skill level. b. Competency. c. Experience. d. Work setting demands. e. Client population. Supervision means a collaborative process for the responsible periodic review and inspection of all aspects of occupational therapy services. The following levels of supervision are minimal. An occupational therapist may assign an increased level of supervision if necessary for the safety of a patient or client. The levels of supervision are: a. Close supervision means the supervising occupational therapist provides initial direction to the occupational therapy assistant and daily contact while on the premises. b. Continuous supervision means the supervising occupational therapist is in the immediate area of the occupational therapy aide performing supportive services. c. General supervision means the supervising occupational therapist has face-to-face contact with the occupational therapy assistant at least once every 30-calendar days on a per patient or client basis while on the premises, with the supervising occupational therapist available by telephone or by written communication. d. Minimal supervision means the supervising occupational therapist has face-to-face contact with the occupational therapy assistant at least once every 30-calendar days while on the premises Amended in Arizona SB 1105, effective as of September 13, 2013.

5 Page 5 e. Routine supervision means the supervising occupational therapist has face-to-face contact with the occupational therapy assistant at least once every 15-calendar days on a per patient or client basis while on the premises, with the supervising occupational therapist available by telephone or by written communication. Supervision of Occupational Therapy Assistants A. Only a licensed occupational therapist shall: R Prepare an initial treatment plan, initiate or re-evaluate a client or patient s treatment plan, or authorize in writing a change of a treatment plan; 2. Delegate duties to a licensed occupational therapy assistant, designate an assistant s duties, and assign a level of supervision; and 3. Authorize a patient discharge. B. A licensed occupational therapy assistant shall not: 1. Evaluate or develop a treatment plan independently; 2. Initiate a treatment plan before a client or patient is evaluated and a treatment plan is prepared by an occupational therapist; 3. Continue a treatment procedure appearing harmful to a patient or client until the procedure is reevaluated by an occupational therapist; or 4. Continue or discontinue occupational therapy services unless the treatment plan is approved or re-approved by a supervising occupational therapist. C. A supervising occupational therapist shall supervise a licensed occupational therapy assistant as follows: 1. Not less than routine supervision if the occupational therapy assistant has less than 12 months work experience in a particular practice setting or with a particular skill. 2. Not less than general supervision if the occupational therapy assistant has more than 12 months but less than 24 months of experience in a particular practice setting or with a particular skill. 3. Not less than minimal supervision if an occupational therapy assistant has more than 24 months of experience in a particular practice setting or with a particular skill. 4. Increased level of supervision, if necessary, for the safety of a patient or client.

6 Page 6 In addition, the proposed hourly reimbursement rate, assigned by the Rate Rebase Study to Occupational Therapy Assistants, is lower than that of current state and national trends. Please see the following data to support our position. The U.S. Department of Labor s Bureau of Labor Statistics (BLS) 1. The demand for occupational therapy services is strong. The U.S. Department of Labor s Bureau of Labor Statistics (BLS) projected employment of both occupational therapists and occupational therapy assistants to increase by 27% or more between 2004 and Employment of occupational therapy assistants is expected to increase 43% from 2010 to 2020, much faster than the average for all occupations. This projection is based on the Bureau s assumptions that demographic trends and advances in medical technology will fuel demand for therapy services. Quick Facts: Certified Occupational Therapy Assistants 2010 Median Pay Work Experience in a Related Occupation $51,010 per year $24.52 per hour None Number of Jobs, ,000 Job Outlook, % (Much faster than average) Employment Change, ,800 Note: All Occupations includes all occupations in the U.S. Economy. Source: U.S. Bureau of Labor Statistics, Occupational Employment Statistics 3. Median annual wages in the industries employing the largest numbers of occupational therapy assistants in May 2010 were as follows: Quick Facts: Certified Occupational Therapy Assistants Home health care services $54,950 Nursing care facilities 54,460 Offices of physical, occupational and speech therapists, and audiologists 53,910 General medical and surgical hospitals; state, local, and private 46,620 Elementary and secondary schools; state, local, and private 42,700 Note: All Occupations includes all occupations in the U.S. Economy. Source: U.S. Bureau of Labor Statistics, Occupational Employment Statistics

7 Page AOTA Occupational Therapy Compensation and Workforce Study Based on 2010 survey results from state occupational therapy regulatory boards, AOTA estimates the current active occupational therapy workforce to be roughly 118,500 practitioners. The following information has been retrieved from Chapter 3: Compensation Overview. Data from the 2010 AOTA Workforce Study indicated the following compensation statistics for Certified Occupational Therapy Assistants. (Refer to Appendix A) 1. Exhibit 3.4:COTA s Annual Salary Overview Per Exhibit 3.4: COTA s full time annual earned income is $44,000 per year/$21.15 per hour 2. Exhibit 3.10:COTA s Annual Salary Overview by State Per Exhibit 3.10: COTA s full time annual earned income per State (Arizona) is $43,000 per year/$20.67 per hour 3. Exhibit 3.11:COTA s Annual Salary Overview by Setting Per Exhibit 3.11: COTA s full time annual earned income per Setting (Freestanding Outpatient) is $41,800 per year/$20.09 per hour 4. Exhibit 3.6:COTA s Annual Salary Overview by Region Per Exhibit 3.6: COTA s full time annual earned income per Region (Mountain) is $43,000 per year/$20.67 per hour 5. Exhibit 3.5:COTA s Annual Salary Overview by Years of Experience Per Exhibit 3.5: COTA s full time annual earned income per Total Years of Experience (50 th percentile - median) is $45,000 per year/$21.63 per hour As noted above, the Bureau of Labor statistics estimates that the demand for occupational therapy assistants is increasing and that there are a variety of settings in which an assistant can work, many of which provide a higher salary. A reduced reimbursement rate for services provided by occupational therapy assistants is an area of concern, as providers of DDD services will no longer be able to offer competitive salaries to occupational therapy assistants. A reimbursement rate reduction may also result in companies providing DDD services losing occupational therapy assistants to providers of occupational therapy in other settings, or companies providing DDD services deciding to discontinue their use of occupational therapy assistants entirely. Our concerns were supported by the results of a survey that ArizOTA recently conducted. This survey was sent to all members who are providers of DDD services. The purpose of the survey is to gather information regarding employment statistics. Responses from survey: 90% utilize occupational therapy assistants for the delivery of occupational therapy services. 60 % of those same providers reported that they would not continue to use occupational therapy assistants if the proposed rates are adopted. 75% currently have a difficult time staffing occupational therapy positions. In conclusion, the relationship between an occupational therapist and an occupational therapy assistant is unique in that it is one of collaboration. By focusing on the term assistant, the proposed reduction in the reimbursement rate for services provided by occupational therapy

8 Page 8 assistants fails to acknowledge the high level of education, national board certification, and licensure requirements to which all occupational therapy assistants must adhere in order to provide services within the state of Arizona. In addition, our research shows that the proposed hourly rate for assistants is lower than current state and national trends. While figures representing reimbursement for supervision have been included within the rate structure, they are not sufficient considering the level of supervision necessary to ensure quality delivery of occupational therapy services or the liability assumed by the occupational therapist. If the proposed rate structure is adopted, many contracted providers of DDD services will no longer hire occupational therapy assistants due to the lack of funds needed to provide proper supervision. With the shortage of occupational therapists and the demand for both occupational therapists and assistants is increasing, a smaller pool of therapists will be available to deliver services. Based on research and feedback from practitioners within the state, ArizOTA believes the unintended consequence will be the reduction of the number of children receiving needed occupational therapy services and an increase in the number of children being placed on a waitlist. We strongly urge that you reconsider your conclusion of reducing the reimbursement rate of services provided by occupational therapy assistants. We thank you for your time in reviewing this matter. Sincerely, Jodi Lindstrom, OTR/L, CEAC ArizOTA President Committee Members Meagan Orban, M.S., OTR/L Lara Taggart, M.S., OTR/L Oaklee Rodgers, MSOT, OTR/L Debbie Hines, M.A., OTR/L

9 Page 9 Appendix A

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11 Page 11 References: 1. U.S. Department of Labor, Bureau of Labor Statistics. (2005). Table 1: Fastest growing occupations covered in the occupational outlook handbook, Retrieved November 1, 2013, from news. Release/ooh.t01.htm 2. U.S. Department of Labor, Bureau of Labor Statistics. (2007). Unemployment rates, seasonably adjusted. Retrieved November 1, 2013, from Occupational Therapy Workforce and Compensation Report. American Occupational Therapy Association, Bethesda, MD: American Occupational Therapy Association. Retrieved November 1, 2013, from