On May 2, 2023, the College presented a webinar on the updated Standards of Practice. The following questions from the webinar were received, and general responses are provided below.
Please refer to the Standards of Practice for more detailed information.
General Questions
Question: What are my responsibilities and accountabilities related to the updated standards?
Answer: Occupational therapists have a professional responsibility to meet the expectations set out in the Standards of Practice. Occupational therapists are encouraged to review the updated Standards, reflect on their practice and identify any gaps to incorporate into practice and any learning needs to follow up on.
Question: How will these updated standards affect my day-to-day practice working in the home and community care setting?
Answer: The updated Standards of Practice are now principle-based, which means they are less prescriptive. This will provide occupational therapists, who are often working with diverse client populations in the community, more flexibility to apply and meet the standards of practice. Many of the principles in the updated standards have remained the same. For example, the expectations around how you obtain client consent, implement occupational therapy service and document these processes in day-to-day practice will be similar.
It is important to note that the new competencies have been incorporated into the standards, including some new language and the culture, equity, and justice domain. The standards also emphasize the occupational therapist's responsibility to know the legislation applicable to your practice setting and any organizational policies you need to follow.
Question: How can I build a good working relationship with clients, occupational therapy assistants (OTAs) and others on the team, while maintaining professional boundaries?
Answer: Communication and Collaboration is a competency that all occupational therapists are expected to demonstrate and are integral to good working relationships. The updated standards incorporate the competencies and include the need to consider principles of culture, equity and justice when interacting with others. The Standard for Professional Boundaries and Prevention of Sexual Abuse clearly outlines expectations for occupational therapists to maintain professional boundaries.
Question: What do the updated Standards of Practice mean for occupational therapists in non-clinical roles? Can you provide some examples on how they may apply for non-clinical occupational therapists?
Answer: The term “client” has been expanded to apply to people and organizations that occupational therapists work with in both clinical and non-clinical settings. Occupational therapists will need to reflect on their own role to determine how to apply the standards in their practice setting. Some of the principles may be more straightforward in their application to non-clinical roles, such as maintaining professional boundaries, preventing and managing conflict of interest, and appropriate use of title. Others may require more reflection.
For example, non-clinical occupational therapists may need to document their work and communications with others. The Standard for Record Keeping would apply with expectations for using professional language, maintaining confidentiality and following legislation and organizational policies for storing information securely and privately. If a standard does not apply to your practice situation, you would be expected to provide a reasonable rationale.
Supervision of Occupational Therapy Assistants (OTAs)
Question: Why was the term "occupational therapy assistant" updated?
Answer: The term “occupational therapist” is a protected title in the legislation. To align with legislation and to ensure there is no confusion by the public, occupational therapy assistant (OTA) is the term to be used moving forward. Modifying the term in the standards also recognizes that there are varying job titles for occupational therapy assistants and individuals acting in the role of an occupational therapy assistant.
Question: When signing or co-signing documentation, does the signature have to be electronic or handwritten?
Answer: An occupational therapist's signature can be electronic or handwritten depending on the record system being used. All signatures must be displayed with the appropriate title/designation and applied securely as per the requirements outlined in the Standard for Record Keeping.
Question: The College specifies requirements for the supervision of occupational therapy assistants (OTAs). Is there guidance for occupational therapists who work with personal support workers (PSWs), educational assistants (EAs) or other care providers?
Answer: An occupational therapist must first determine if they are assigning a component of the occupational therapy service or if they are providing recommendations as a consultant. When assigning a component of the service to be delivered by an occupational therapy assistant (OTA) or person acting in the role of an occupational therapy assistant, the occupational therapist is accountable for all the activities assigned and is responsible for monitoring and re-evaluating the services provided by the occupational therapy assistant.
When the occupational therapist is acting as a consultant, they are only identifying problems, providing recommendations, education and/or training regarding a specific issue with a client. This may be the case when working with PSWs, EAs or other care providers where occupational therapists are not assigning occupational therapy components. In these situations, the occupational therapist is accountable for the recommendations they make, but they are not accountable for the individual carrying out the recommended activities. The individual carrying out the recommendations may be involved with the client even after the occupational therapy service has ended and is accountable to their employers.
The Standard for the Supervision of Students and Occupational Therapy Assistants describes the expectations for occupational therapists in both of these roles. A clinical example is provided in this case study resource: Case Study - Occupational Therapists Providing Education or Training of Recommendations to Others.
Question: Does every note completed by the occupational therapy assistant need to be reviewed by the occupational therapist before co-signing?
Answer: Occupational therapists are expected to establish a supervision and communication plan when assigning components of the occupational therapy service to an occupational therapy assistant (Standard for Supervision of Students and Occupational Therapy Assistants). This plan should include a process to review any record-keeping completed by the occupational therapy assistant to ensure its accuracy (Standard for Record Keeping, indicator 4.4). The occupational therapist is expected to document this review, however the co-signing of the occupational therapy assistant’s notes is not required. This differs from notes completed by occupational therapy students which do require co-signing by an occupational therapist.
Psychotherapy
We received several questions related to the Standard for Psychotherapy. The College is working on additional psychotherapy resources that will be available in the near future to help answer these questions. In the meantime, please contact the Practice Resource team if you have a specific question or situation that you would like to discuss.
Question: Can you provide some examples to help me determine if I am practicing psychotherapy?
Answer: In the Standard, there is a resource in Appendix 2: When the Standard for Psychotherapy applies: Occupational Therapy in Mental Health, which provides some examples of psychotherapy practice. The professional associations are also a great resource. They can assist with networking opportunities with other occupational therapists who work in mental health and psychotherapy.
Question: In the standard it states that an occupational therapist must hold a general “certificate of registration to practice psychotherapy” What does this mean?
Answer: There is no specific registration to perform psychotherapy. A certificate of registration means you have completed all the requirements for a general certificate of registration with the College. Provisional or temporary registrants will need permission from the Registrar to perform psychotherapy.
Question: When can we feel comfortable to use the title of psychotherapist?
Answer: The Standard for Psychotherapy does not specify when occupational therapists should start using the title "Psychotherapist". Occupational therapists are advised to collaborate with their supervisors. The College relies on the occupational therapist’s professional judgement to determine when it is suitable to use the psychotherapist title by assessing their own competency, formal training, theoretical understanding and practical experience.
The Regulated Health Professions Act, 1991, s. 33.1(1) permits occupational therapists to use the title "Psychotherapist" only if they identify (oral or written) that they are a registered occupational therapist with the College. The Standard outlines how to correctly use the psychotherapist title.
Psychotherapy is considered a higher risk intervention, is not an entry-level occupational therapy skill, and takes time to develop skills, knowledge and judgement to perform; therefore, the use of the psychotherapist title should only be used by a qualified practitioner. As such, occupational therapists need to be mindful that the title "psychotherapist" should not be used lightly, nor should it be utilized solely for billing or invoicing purposes.
For any questions, please contact our Practice Resource Service at 1-800-890-6570 ext. 240 or [email protected].
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