The Board adopts, as if fully set out herein, the “Guidelines for Supervision, Roles, and Responsibilities During the Delivery of Occupational Therapy Services” issued by the American Occupational Therapy Association, effective September 2020, to the extent that it agrees with the laws of the state of Tennessee or the rules of the Board. If there are conflicts with state law or rules, the state law or rules govern the matter. Information to acquire a copy may be obtained by contacting either of the following: American Occupational Therapy Association 6116 Executive Boulevard Suite 200 North Bethesda, MD 20852-4929 Telephone: 800-SAY-AOTA (800-729-2682), ext. 2652 or (301) 652-6611 (members) Telephone: 1-800-SAY-AOTA (729-2682) and press 0 (non-members) Fax: (301) 652-7711 Email: customerservice@aota.org or otpractice@aota.org Internet: www.aota.org Board of Occupational Therapy 665 Mainstream Drive, 2nd Floor Nashville, TN 37243 Telephone: (615) 741-3807 Email: Unit2HRB.Health@tn.gov Internet: www.tn.gov/health

1. (1) Supervision of an Occupational Therapist on a limited permit must include initial and routine inspection of written evaluations, written treatment plans, patient/client notes and routine evaluation of performance. The supervision must be conducted in person, by a licensed occupational therapist and must be as follows:

   1. (a) Routine supervision with direct contact every 2 weeks at the site of treatment, with interim supervision occurring by other methods such as the telephone, conferences, written communication, and e-mail.
   2. (b) Supervision must include observation of the individual treatment under a limited permit in order to assure service competency in carrying out evaluation, treatment planning and treatment implementation. OCCUPATIONAL THERAPY
   3. (c) The frequency of the face to face collaboration between the person treating under a limited permit and the supervising therapist should exceed direct contact every 2 weeks if the condition of the patient/client, complexity of treatment, evaluation procedures, and proficiencies of the person practicing under the limited permit warrants it.

   4. (d) Therapists must maintain documentation of each supervisory visit, and must identify a plan for continued supervision. Records must include, at a minimum, the following information:

      1. 1. Location of visit; a method of identifying clients discussed
      2. 2. Current plan for supervision (daily, weekly, bi-monthly)
      3. 3. Identification of type(s) of interventions observed. These include but are not limited to:
   5. (i) Interventions
   6. (ii) Training

   7. (iii) Consultations

      1. 4. Other supervisory actions. These include but are not limited to:
   8. (i) Discussion/recommendation for interventions and/or goals
   9. (ii) Discussion/training in documentation
   10. (iii) Demonstration/training in intervention techniques
   11. (iv) Assessment/re-assessment/discharge

   12. (v) Additional Comments

       1. 5. An agreement statement signed and dated by both parties, that the supervisory visit did occur and met the needs of the supervisor and supervisee.
       2. 6. It is the responsibility of the supervising occupational therapist to provide and the limited permit holder to seek a quality and frequency of supervision that ensures safe and effective occupational therapy service delivery. Both parties (supervisor and supervisee) must keep copies of the supervisory records. Visit records must be maintained for three (3) years, and must be provided to the Board and/or its representative, upon request.
   13. (e) A co-signature by supervising Occupational Therapist is required on evaluations, treatment plans, and discharge summaries.

2. (2) Supervision of an Occupational Therapy Assistant on a limited permit means initial direction and routine inspection of the service delivery and provision of relevant in-service training. The supervising occupational therapist must provide additional supervision, if the patient’s required level of care is beyond the level of skill of an entry level Occupational Therapy Assistant on a limited permit. This decision is based on client’s level of care, OTA caseload, experience and demonstrated performance competency. Supervision of an Occupational Therapy Assistant on a limited permit must include initial and routine inspection of patient OCCUPATIONAL THERAPY notes and routine evaluation of performance. The supervision must be conducted in person by a licensed occupational therapist and must be as follows:

   1. (a) The Occupational Therapist shall be responsible for the evaluation of the patient and development of the patient/client treatment plan. The Occupational Therapy Assistant on a limited permit may contribute information from observations and standardized test procedures to the evaluation and the treatment plans.
   2. (b) The Occupational Therapy Assistant can implement and coordinate intervention plan under supervision of a licensed Occupational Therapist.
   3. (c) The Occupational Therapy Assistant can provide direct services that follow a documented routine and accepted procedure under the supervision of the licensed Occupational Therapist.
   4. (d) The Occupational Therapy Assistant can adapt activities, media, and environment according to needs of patient/client under supervision of the licensed Occupational Therapist.
   5. (e) Documentation provided by the Occupational Therapy Assistant while on a limited permit must be co-signed by a licensed Occupational Therapist.

   6. (f) Therapists must maintain documentation of each supervisory visit, and must identify a plan for continued supervision. Records must include, at a minimum, the following information:

      1. 1. Location of visit; a method of identifying clients discussed
      2. 2. Current plan for supervision (daily, weekly, bi-monthly)
      3. 3. Identification of type(s) of interventions observed. These include but are not limited to:
   7. (i) Interventions
   8. (ii) Training

   9. (iii) Consultations

      1. 4. Other supervisory actions. These include but are not limited to:
   10. (i) Discussion/recommendation for interventions and/or goals
   11. (ii) Discussion/training in documentation
   12. (iii) Demonstration/training in intervention techniques
   13. (iv) Assessment/re-assessment/discharge

   14. (v) Additional Comments

       1. 5. An agreement statement signed and dated by both parties, that the supervisory visit did occur and met the needs of the supervisor and supervisee. OCCUPATIONAL THERAPY
       2. 6. It is the responsibility of the supervising occupational therapist to provide and the limited permit holder to seek a quality and frequency of supervision that ensures safe and effective occupational therapy service delivery. Both parties (supervisor and supervisee) must keep copies of the supervisory records. Visit records must be maintained for three (3) years, and must be provided to the Board and/or its representative, upon request.

3. (3) Supervision of an Occupational Therapy Assistant with permanent licensure means initial direction and inspection of the service delivery and provision of relevant in-service training, according to the level of supervision the occupational therapy assistant requires. It is the responsibility of the occupational therapist and the occupational therapy assistant to seek the appropriate quality and frequency of supervision that ensures safe and effective occupational therapy service delivery. This decision is based on client’s level of care, OTA caseload, experience and demonstrated performance competency.

   1. (a) The frequency of the face to face collaboration between the Occupational Therapy Assistant and the supervising Occupational Therapist should exceed direct contact of once a month if the condition of the patient/client, complexity of treatment, evaluation procedures, and proficiencies of the person practicing warrants it.
   2. (b) The Occupational Therapist shall be responsible for the evaluation of the patient and the development of the patient/client treatment plan. The Occupational Therapy Assistant may contribute information from observations and standardized test procedures to the evaluation and the treatment plans.
   3. (c) The Occupational Therapy Assistant can implement and coordinate intervention plan under the supervision of the licensed Occupational Therapist.
   4. (d) The Occupational Therapy Assistant can provide direct services that follow a documented routine and accepted procedure under the supervision of the Occupational Therapist.
   5. (e) The Occupational Therapy Assistant can adapt activities, media, and environment according to the needs of the patient/client, under the supervision of the licensed Occupational Therapist.

   6. (f) Therapists must maintain documentation of each supervisory visit, and must identify a plan for continued supervision. A form is available on the Board’s website which may be used to document supervision. Records must include, at a minimum, the following information:

      1. 1. Location of visit; a method of identifying clients discussed
      2. 2. Current plan for supervision (daily, weekly, bi-monthly, monthly, other)
      3. 3. Type of supervision provided. These include but are not limited to:
   7. (i) In person
   8. (ii) Phone contact

   9. (iii) Electronic contact

      1. 4. Identification of type(s) of interventions observed. These include but are not limited to: OCCUPATIONAL THERAPY
   10. (i) Interventions
   11. (ii) Training

   12. (iii) Consultations

       1. 5. Other supervisory actions. These include but are not limited to:
   13. (i) Discussion/recommendation for interventions and/or goals
   14. (ii) Discussion/training in documentation
   15. (iii) Demonstration/training in intervention techniques
   16. (iv) Assessment/re-assessment/discharge

   17. (v) Additional Comments

       1. 6. An agreement statement signed and dated by both parties, that the supervisory visit did occur and met the needs of the supervisor and supervisee.
       2. 7. It is the responsibility of the supervising occupational therapist to provide and the occupational therapy assistant to seek a quality and frequency of supervision that ensures safe and effective occupational therapy service delivery. Both parties (supervisor and supervisee) must keep copies of the supervisory records. Visit records must be maintained for three (3) years, and must be provided to the Board and/or its representative, upon request.

4. (4) Supervision of occupational therapy students and occupational therapy assistant students.

   1. (a) Supervision of occupational therapy students and occupational therapy assistant students shall be consistent with the standards of the Accreditation Council for Occupational Therapy Education (ACOTE) for such supervision.
   2. (b) Students enrolled in an entry-level doctor of occupational therapy (OTD) program shall comply with the ACOTE Standards pertaining to the Experiential Component (EC) for purposes of supervision. In the event that the student’s EC includes an in-depth experience in clinical practice or OT/OTA education, the student will be required to have a minimum of eight (8) hours of direct supervision each week by a licensed occupational therapist.

5. (5) Supervision of an unlicensed person shall be as follows:

   1. (a) There shall be close supervision with daily, direct contact at site of treatment, which demands the physical presence of a licensed physician, occupational therapist or occupational therapy assistant, whenever the unlicensed person assists in the practice of Occupational Therapy.
   2. (b) There shall be personal instruction, observation and evaluation by the licensed occupational therapist or occupational therapy assistant.
   3. (c) There shall be specific delineation of tasks and responsibilities by the licensed physician, occupational therapist or occupational therapy assistant who is responsible for reviewing and interpreting the results of care. The licensed physician, occupational OCCUPATIONAL THERAPY therapist or occupational therapy assistant must ensure that the unlicensed person does not perform duties for which he is not trained. The tasks that may be delegated to an unlicensed person and the responsibilities of the delegating licensee are set forth in T.C.A. § 63-13-207.
   4. (d) Appropriate records must be maintained to document compliance.
   5. (e) The intensity of the supervision is determined by the nature of the task to be performed, the needs of the consumer, and the capability of the unlicensed person.

6. (6) Supervision parameters

   1. (a) Supervision is a collaborative process that requires both the licensed occupational therapist and the licensed occupational therapy assistant to share responsibility. Appropriate supervision will include consideration given to factors such as level of skill, the establishment of service competency (the ability to use the identified intervention in a safe and effective manner), experience and work setting demands, as well as the complexity and stability of the client population to be treated.
   2. (b) Supervision is an interactive process that requires both the licensed occupational therapist and the licensed occupational therapy assistant or other supervisee to share responsibility for communication between the supervisor and the supervisee. The licensed occupational therapist should provide the supervision and the supervisee should seek it. An outcome of appropriate supervision is to enhance and promote quality services and the professional development of the individuals involved.

   3. (c) Supervision of occupational therapy services provided by a licensed occupational therapy assistant is recommended as follows:

      1. 1. Entry level occupational therapy assistants are persons working on initial skill development (less than 1 year of work experience) or who are entering new practice environments or developing new skills (one or more years. of experience) and should require close supervision.
      2. 2. Intermediate level occupational therapy assistants are persons working on increased skill development, mastery of basic role functions (minimum one - three years of experience or dependent on practice environment or previous experience) and should require routine supervision.
      3. 3. Advanced level occupational therapy assistants are persons refining specialized skills (more than 3 years work experience, or the ability to understand complex issues affecting role functions) and should require general supervision.
      4. 4. Licensed occupational therapy assistants, regardless of their years of experience, may require closer supervision by the licensed occupational therapist for interventions that are more complex or evaluative in nature and for areas in which service competencies have not been established.
      5. 5. Certain occupational therapy assistants may only require minimal supervision when performing non-clinical administrative responsibilities.

Authority: T.C.A. §§ 63-13-206, 63-13-207, and 63-13-216. Administrative History: Original rule filed March 15, 1996; effective May 29, 1996. Amendment filed September 11, 1998; effective November 25, 1998. Amendment filed July 31, 2000; effective October 14, 2000. Amendment filed April 17, 2007; effective July 1, 2007. References to Board of Occupational and Physical Therapy Examiners have been OCCUPATIONAL THERAPY changed by the Secretary of State to the applicable entity: Board of Occupational Therapy and/or Board of Physical Therapy pursuant to Public Chapter 115 of the 2007 Session of the Tennessee General Assembly. Amendments filed October 21, 2009; effective January 19, 2010. Amendment filed August 28, 2012; effective November 26, 2012. Amendments filed March 23, 2026; effective June 21, 2026.