SC Board of Occupational Therapy
Frequently Asked Questions

These statements are provided by the Board of Occupational Therapy to serve as guidance for ethical practice and do not constitute legal advice. Additionally, the Board may not provide any advice or guidance concerning billing or insurance issues, or matters involving the employment relationship. Licensees are encouraged to consult with their private attorney on these matters.

How long will it take to get a license once I have applied?

Each application is reviewed on its own merits, so that the time to process and issue a license depends on numerous factors. To prevent any delays, please ensure that the application is complete, and that all required documents are attached or provided in the manner requested by the Board. Once all required documents are received and reviewed, the license can be issued, unless matters are identified requiring a Board appearance for additional review. To apply for licensure, please select the link to licensure requirements and instructions, and applications and forms.

When do I need to renew my license?

Licenses are valid for a period of time not to exceed two years. It is the responsibility of the licensee to renew their license on or before March 15 in every odd numbered year, whether or not a notice to renew is received. An OT or OTA who first becomes licensed after December 14 in either year of a two year licensing period is not required to renew until the following licensing period.

The Board requires initial and ongoing certification with the National Board of Certification in Occupational Therapy ("NBCOT"). LICENSEES MUST BE CERTIFIED AND IN GOOD STANDING WITH NBCOT IN ORDER TO MAINTAIN AND RENEW THEIR SC LICENSE.

What happens if I do not timely renew my license?

If a licensee fails to renew their license before the March 15th deadline, or if the license renewal application is not postmarked prior to March 16th, the Board may charge a late renewal penalty as established in regulation, if the license is renewed prior to April 16. If a licensee fails to renew a license or if the renewal application is not postmarked before April 16th, the license lapses as of April 16th, and will need to be reinstated. A licensee who does not renew their license or submit a license renewal application postmarked before March 16th who practices as an OT or OTA after that date is deemed to be practicing without a license, and is subject to penalties in regards thereto. Instructions and forms to reinstate a license.

What are the continuing education requirements for licensure renewal?

Every licensed occupational therapist and occupational therapy assistant must earn sixteen (16) contact hours of acceptable continuing education credit per biennial license period for license renewal. Continuing education requirements are met through completing continuing education and continued competency activities required for NBCOT certification and/or renewal. Click on the link to the NBCOT Renewal Activity Chart for more detailed information regarding acceptable continuing education.

How do I report my continuing education hours to the Board?

The Board requires all licensees to use CE Broker to track their CE hours. All licensees must have an active account with CE Broker to track their continuing education hours required for license renewal. You may sign up for your free CE Broker account.

What is CE Broker and how do I use it?

CE Broker is an online tool, where licensees must track their continuing education hours. Licensees can add their CE hours to their CE Broker account at any time during the two-year licensing period.

A licensee failing to use CE Broker to track their CE compliance may be subject to an audit and possible disciplinary action.

Sign up for the Free CE Broker Basic Account.

How can I obtain verification of my licensure?

Verification can be obtained by access the on-demand "Licensee Lookup" section of the website.

What are the different types of supervision?

"Supervision" means the personal and direct involvement of an occupational therapist in a supervisee's professional experience which includes evaluation of the supervisee's performance with respect to each client treated by the supervisee.

"Direct supervision" means personal, daily supervision, and specific delineation of tasks and responsibilities by an occupational therapist and includes the responsibility for personally reviewing and interpreting the results of a supervisee on a daily basis.

"On-site" means being on the same premises while direct client treatment is being performed.

What are the supervision requirements for an Occupational Therapy Assistant?

An OTA may only assist in the practice of occupational therapy under the supervision of a licensed OT. The supervising occupational therapist shall at all times be responsible for all occupational therapy services provided by an occupational therapy assistant to carry out the developed treatment plan.

How often does the supervising OT need to provide supervision to the OTA?

Supervision must be provided a minimum of every seven visits or every 30 calendar days, whichever comes first. If there is a change in the client's status that warrants more frequent supervision, that is to be determined by the professionals involved. Documentation of supervision should be noted in the client's chart.

Who is ultimately responsible for all delineated tasks?

It is the responsibility of the supervising OT to have established an understanding of the supervisee's capabilities. The form of supervision (consultation versus reassessment) may be directly related to the expertise of the OTA carrying out the treatment plan. It may be very appropriate to mix the form of supervision based on client needs. This is also true for the non- skilled aspects of tasks delegated to aides.

What is a "consultation/reassessment?" Are they the same?

A consultation or reassessment visit is to be defined based on the judgment of the supervising therapist and the need of the OTA to which the roles are delegated. Therefore, a consultation may be on or off site; however, a reassessment visit would be direct contact with the client.

How many OTAs and/or aides can an OT supervise?

The state does not dictate a maximum number of supervisees that a therapist can be responsible for. The number and type of supervisees is directly related to the abilities of the supervisor. Things to consider are the experience level of all parties involved, the type of tasks, which are being delegated, as well as the type of clients and risks involved. Remember the burden of proof that adequate supervision has been provided falls upon the OT.

Can OTAs provide an initial evaluation and develop a treatment plan of care?

No, only an OT can provide the initial evaluation and develop the treatment plan of care. However, OTAs can contribute by performing supervised screenings and information gathering for the evaluation or assessment.

Can an OTA provide services without a documented OT treatment plan of care?

No, an OTA can only provides services under the supervision of an OT pursuant to an OT created treatment plan.

Can OTAs complete progress notes?

Yes. Progress notes must be signed and dated by the person rendering treatment.

When do progress notes need to be countersigned?

Progress notes completed by an occupational therapy student or occupational therapy assistant student who provided the treatment must be countersigned and dated by the OT or OTA who is providing supervision.

Can OTAs complete a discharge summary?

While the OTA rendering services should write, sign and date a discharge note containing a statement of the client's status at the last treatment session, the supervising OT must co-sign and consult on the discharge note.

What is the role of an OT aide?

Skilled services cannot be delegated to the aide. The aide may only perform duties associated with non-treatment aspects of occupational therapy, including but not limited to transporting clients, preparing treatment areas, attending to the personal needs of clients during treatment sessions, and clerical or housekeeping activities under the direct on-site supervision of a licensed OT or licensed OTA. The aide must be clearly identified as an aide when performing these duties. An aide may not perform an activity or task which requires OT or OTA licensure, requires the exercise of the professional judgment of an OT, or develop or model client treatment plans or discharge plans.

If we have rehab technicians at work, do they have to follow the guidelines for OT aides?

Yes. It does not matter what title you give to the unlicensed person, or whether they are paid or a volunteer, an OT aide is a non-licensed person who assists in the provision of services as described above, and who must be properly identified when performing their duties.

Do I need a physician's referral to treat a client?

While a physician referral is not required by South Carolina law to initiate or to continue occupational therapy services, reimbursement sources, employers, accreditation agencies, malpractice insurance providers and other entities may have referral requirements. Licensees are cautioned to research and identify any additional requirements or concerns pertaining to referral requirements for the initiation or continuation of OT services.

Must I continue to work to maintain a license in South Carolina?

No. Active practice as an occupational therapist or as an occupational therapy assistant is not a requirement for licensure renewal. However, if a license lapses, practice requirements may be required for license reinstatement to address absence from practice as a risk for decreased competency.

How can I get help with a problem with alcohol or other drug problems and preserve my career?

OTs or OTAs who experience problems with alcohol or other drug problems can find help with the Recovering Professional Program (RPP). RPP is a confidential professional substance abuse program uniquely tailored to assist individual healthcare professionals in getting quality services and preserving their careers. Early identification, referral, and monitoring help assure good recovery from this progressive, deadly disease.

Licensees who enroll with RPP before their substance abuse problems impact their practice are not disclosed to the licensing board while in compliance with RPP's requirements. RPP's team of specialized professionals identifies resources for each individual that best matches their personal needs and situations. That individualized personal care from RPP builds strong relationships and provides tools to save or reactivate careers. RPP's monitoring also provides employers, the Board, and patients with assurance of safe, effective practice. A solid record of participation with RPP certifies a licensee's personal commitment to professionalism today and in the future. If you or a colleague is experiencing a problem with substance abuse or dependence, you can find help by contacting RPP at 1-877-349-2094 (toll free). Learn more about RPP.

Frequently Asked Questions: Telehealth

Does the Board support the use of telehealth in the practice of occupational therapy?

Yes. The Board supports the use of telehealth as an effective and comparable method of occupational therapy service delivery.

What is telehealth?

Telehealth, also known as telemedicine, is the provision of health care, health information, and health education remotely across a distance, using telecommunications technology and specially adapted equipment.

Can occupational therapy practitioners provide services to clients by means of telehealth?

Yes. An OT or an OTA licensed in South Carolina may provide telehealth services to clients receiving occupational therapy services in this State.

Are there any special client considerations for providing services by means of telehealth?

Yes. A licensee providing occupational therapy services to a client by means of telehealth must first determine that the initial evaluation and/or subsequent treatment of a client is appropriate for telehealth. A licensee is held to the same standard of care, client protection, and service delivery effectiveness applicable to a licensee providing services in-person. A licensee should evaluate whether these standards can be met for the particular client in regards to the occupational therapy services to be provided. Should the licensee determine at any point that remote treatment of the client cannot be provided safely, effectively, or consistently with the in-person standard of practice, care and/or ethics, in-person treatment shall be resumed.

Must informed consent be obtained prior to conducting an initial evaluation or providing treatment by means of telehealth?

Yes. Prior to the initial evaluation, the licensee must obtain informed consent from the client or parent or guardian to the following: (1) the risks and limitations of the use of technology to provide services; (2) the potential for unauthorized access to protected health information; (3) the potential for disruption of technology during a telehealth visit; and (4) the right to refuse or discontinue telehealth services.

What are the ethical issues concerning telehealth?

Client confidentiality is one of the major issues concerning telehealth. Occupational therapy practitioners must use secure HIPAA compliant technology. In addition to the

Board's statutes and regulations, in particular the Code of Ethics, practitioners may wish to review the following resources. Please note that these resources are offered only as guidance, and to the extent any information contained in the resources conflicts with Board statutes and regulations, the Board's statutes and/or regulations will control.

AOTA's Telehealth Resource Page

NBCOT Certificant Code of Conduct

Can I provide telehealth services in other states?

Occupational therapy practitioners using telehealth technology must adhere to licensure laws and other state legislation regulating the practice of occupational therapy in the state or states in which those services are received. It is highly recommended that occupational therapy practitioners review the requirements in the state where they wish to provide services to ensure compliance.

Does the Board control billing and reimbursement for telehealth occupational therapy services?

SC Board of Occupational Therapy has no authority over billing, insurance, or employment matters. Each licensee should individually review the policies of their reimbursement sources, employers, accreditation agencies, malpractice insurance providers, to identify any additional requirements or concerns which may be germane to telehealth practice.

Frequently Asked Questions: Recovering Professional Program (RPP)

What is the Recovering Professional Program (RPP)?

The RPP is a confidential professional substance abuse monitoring service that has been contracted by the Occupational Therapy Licensure Board through LLR to address the problem of impaired health care professionals.

The RPP is a five year program inclusive of monitoring, continued care, peer assistance and screenings.

What are the benefits of the RPP for occupational therapy practitioners?

The RPP assists occupational therapy practitioners with returning back to safe practice through appropriate referral and effective monitoring, rehabilitation and recovery.

The RPP ensures that impaired occupational therapy practitioners receive the help they need at the earliest point possible.

What about my confidentiality and losing my license if I self-report and volunteer to participate in the RPP?

The RPP emphasizes confidentiality, education and opportunity while treating professionals with compassion and dignity throughout the process of recovery.

The RPP provides anonymity of voluntary participants who comply with program requirements. Program enrollment will not impact occupational therapy licensure unless participants do not comply with program requirements. In that instance, the Board may be notified and disciplinary actions could occur.

How do I find out more about the RPP or enroll?

Occupational therapy practitioners can refer themselves, or be referred by the Board, friends, family, colleagues, employers or peer- assistant representatives.

Contact and communication concerning the RPP can be separate from the Occupational Therapy Board. Voluntary contact can be made directly with the RPP by calling 1-877-349-2094 or visiting their website.

The RPP staff is available for assistance 24 hours aday, seven days a week.

How does it protect the citizens of South Carolina?

The RPP offers additional protection to the individuals receiving occupational therapy services, the public and citizens of South Carolina through early identification of health care professionals in need of help with alcohol and other substance abuse problems in a manner that is consistent and accountable.