Speech-Language Pathologists Supervising Occupational Therapists

The Board of Occupational Therapy recently promulgated regulations (Title 16, California Code of Regulations Sections 4153 through 4155) defining the education and training requirements that an occupational therapist ("OT") must possess in order to be issued an advanced practice certification in swallowing assessment, intervention and evaluation. Included in the provisions defining the on-the-job training requirements for OTs, speech-language pathologists ("SLPs") are identified as qualifying supervisors for the purposes of overseeing the 240 hours of experience the OT must obtain in swallowing assessment, evaluation or intervention.

Several concerned SLPs contacted SLPAB regarding their role in providing supervision to OTs. The SLPAB consulted legal counsel regarding the prevailing statutes that address the supervision parameters for licensed SLPs. Legal counsel advised the SLPAB that according to the Practice Act, any person who works directly under the supervision of a SLP facilitating or assisting a supervisor in evaluations or treatments must be registered with the Board as a SLP aide. Thus, it is legally possible for OTs to obtain supervised on-the-job training from SLPs provided the OTs become qualified aides and are registered with the Board as such. [Reference: Business and Professions Code Sections 2530.2, 2530.6 & 2570.3 and Title 16, California Code of Regulations Sections 1399.154.1-1399.154.4 & 4153]

It should be noted that licensed speech-language pathologists are neither obligated by the laws and regulations governing the practice of speech-language pathology nor the provisions governing the practice of occupational therapy, to participate as a supervisor to another health care practitioner. The decision to function as a supervisor to another practitioner is a personal decision that must be carefully considered in terms of the assumed professional liability for the services provided by another practitioner who is likely less experienced or competent in the practice.