Several speakers urged the California Board of Occupational Therapy on March 7 to remove occupational therapy assistants (OTAs) from a proposed numeric cap in supervision regulations. Commenters said a cap would conflict with existing statute that already limits the number of OTAs an occupational therapist may supervise and that adding the assistant role to a separate list could reduce access to care.

Sami Rafidi, president of the Occupational Therapy Association of California, told the board she and Kristin Neville of AOTA sent a follow-up letter after a November 2024 meeting and reiterated concerns about the proposed language in the California Code of Regulations Title 16, Division 39, Section 4181. Rafidi said the intent of the supervision standards committee had been to exclude OTAs from a new formula that would cap the number of supervisees: “We were asking to omit occupational therapy assistance from that list,” she said.

Ada Boone Horrell, OTA program director at Sacramento City College, described participation on the supervision-standards committee and said the committee had intended to remove assistants from the list because statute already allows occupational therapists to supervise up to three OTAs concurrently. Horrell also said adding OTAs to the list in regulation could limit fieldwork placements for educational programs.

Board members and staff responded that the topic appears in the meeting materials and in the board’s regulatory package, and that the board could not fully debate unpublished regulation language during public comment; the executive officer and counsel advised the group that the board would handle regulatory updates at a later agenda item and that the item would be published when it was ready. The board did not vote on any regulatory language during public comment.

Board staff confirmed the supervision parameters item remains in the regulatory materials and that the board will address it in the regulatory process, with the supervision language expected to be prioritized for staff work on regulations.