Frequently Asked Practice 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 most billing or insurance issues, or matters involving the employment relationship. Licensees are encouraged to consult with their private attorney on these matters.

Where can I find information on CE requirements and Frequently Asked Questions on CE?

Please refer to the Board's Regulation 94-08 for information on CE requirements and use this link to Continuing Education Frequently Asked Questions.

How often do I need to provide supervision to the COTA I supervise?

Supervision must be provided a minimum of every seven visits or every 30 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. For simplicity and consistency this will use a calendar 30 days, not working days. Please see OT Statute 40-36-290 (A).

Who accepts final responsibility for all delineated tasks?

It is the responsibility of the supervising OTR 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 COTA 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. Please see OT Statute 40-36-290.

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 COTA 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. This is to prevent the practice of having OTRs perform initial and discharge evaluations with no continuity during the treatment phase when changes in the treatment plan may be indicated. AOTA provides a "Guidelines for Supervision” document, which assists with the delineation responsibilities of an OTR. It does account for the varied experience levels among COTAs.

How do I prove that I was involved in consultation?

Supervision is linked directly to each client through the medical record and not to the practitioner. Therefore, the minimum every individual client needs for frequency of supervision and evidence should be noted in the client chart documenting the form of supervision provided.

How many COTAs and/or aides can I 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 licensed professionals and ultimately upon the OTR.

What is the role of an OT aide?

Skilled services cannot be delegated to the aide. The aide may perform any non-treatment aspect of departmental operations as well as treatment aspects that do not require the knowledge or judgment of an OT practitioner. A good guideline is to relate it to the tasks you can delineate to the family of the client. Please see OT Statute 40-36-300 (B and C).

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

Yes. No matter what you call the person, paid or volunteer, an OT aide is a non-licensed person who assists in the provision of OT services.

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

No. In the state of South Carolina, we have "direct access" which means that a physician referral is not required by law to initiate or to continue services. This additionally means if a referral is provided, the state does not dictate if it comes from a physician, physician's assistant, nurse practitioner, chiropractor or various other source options (medical or non-medical). The state, however, does not regulate the policies of third party reimbursement sources, nor does the state impose this referral freedom on employers who may prefer physician referrals. Each professional needs to individually investigate the policies which relate to their practice/learning environments from multiple perspectives such as reimbursement sources, employers, accreditation agencies and malpractice insurance providers to identify any additional requirements or concerns.

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

No. The state of South Carolina does not dictate active practice as an occupational therapist or as an occupational therapy assistant as a requirement for licensure renewal. Continuing education is required at renewal for all licensees who hold an active license. However, for a practitioner who does not hold an active license, requirements are in place to address absence from practice as a risk for decreased competency. Information may be obtained in the statute and regulations for the position of the Board regarding reactivation of licensure following various periods of inactivity in the profession. See Regulation 94-07. Contact the Board for additional information. Forms for reinstatement of a license to active status are available on the Board's Web site.

What are the continuing education requirements for licensure renewal?

Every licensed occupational therapist and occupational therapy assistant shall earn sixteen (16) contact hours of acceptable continuing education credit per biennium year. Of the sixteen (16) contact hours, eight (8) must be related to direct patient care. The remaining eight (8) contact hours may be in any area directly related to health care, subject to Board approval, including, but not limited to supervision, education, documentation, quality assurance, and administration. Please see Regulation 94-08.

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

Licensed Occupational Therapists or Licensed Occupational Therapy Assistants 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 match their personal needs and situations. That individualized personal care from RPP builds strong relationships and provides tools to save or reactivate their careers. RPP's monitoring also provides employers, the licensing 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 at

RPP Frequently Asked Questions (pdf)