Massachusetts Association for Occupational Therapy




Financial Services Committee

July 18, 2016

Thank you for the opportunity to submit testimony in support of Senate 549 and House 578, legislation advancing and expanding access to telemedicine services.

The Massachusetts Association for Occupational Therapy is a volunteer organization of occupational therapists and occupational therapy assistants representing the profession of occupational therapy to the public throughout the Commonwealth.  It is through the professional and dedicated service of the over 7000 licensed occupational therapy practitioners throughout Massachusetts that occupational therapy is viewed as vital in helping individuals, including the elderly, children, and the disabled to lead independent, satisfying, and productive lives. Occupational therapy practitioners provide services in a wide variety of settings including the public sector and private sector.

Occupational therapy practitioners use telehealth as a service delivery model to help clients develop skills; incorporate assistive technology and adaptive techniques; modify work, home, or school environments; and create health-promoting habits and routines. Benefits of a telehealth service delivery model include increased accessibility of services to clients who live in remote or underserved areas, improved access to providers and specialists otherwise unavailable to clients, prevention of unnecessary delays in receiving care, and workforce enhancement through consultation and research among others (Cason, 2012a, 2012b). By removing barriers to accessing care, including social stigma, travel, and socioeconomic and cultural barriers, the use of telehealth as a service delivery model within occupational therapy leads to improved access to care and ameliorates the impact of personnel shortages in underserved areas. Occupational therapy outcomes aligned with telehealth include the facilitation of occupational performance, adaptation, health and wellness, prevention, and quality of life. The American Occupational Therapy Association (AOTA) has developed a position paper on Telehealth which helps guide this area of practice (AOTA, 2013).

Research has been conducted by occupational therapy practitioners which demonstrate its effectiveness. Published studies support the use of telehealth in improving functional outcomes with individuals with stroke (Chumbler et al., 2010; Hermann et al., 2010), survivors of breast cancer (Hegel et al., 2011), veterans with polytrauma (Bendixen et al., 2008), and individuals with traumatic brain injury (Diamond et al., 2003; Forducey et al., 2003; Girard, 2007; Verburg et al., 2003). Additional studies have used a telehealth service delivery model to evaluate activities of daily living and hand function in individuals with Parkinson’s disease (Hoffman, Russell, Thompson, Vincent, & Nelson, 2008) and other neurological impairments (Savard, Borstad, Tkachuck, Lauderdale, & Conroy, 2003). Seating experts used telehealth to provide remote wheelchair prescription and consultation to individuals with neurological and orthopedic conditions (Barlow, Liu, & Sekulic, 2009; Schein, Schmeler, Holm, Saptono, & Brienza, 2010; Schein et al., 2011). In addition to positive clinical outcomes, evidence indicates a high level of practitioner and client satisfaction associated with a telehealth service delivery model (Kairy, Lehoux, Vincent, & Visintin, 2009; Steel et al., 2011).

Evidence supports the use of a telehealth service delivery model to deliver appropriate early intervention (EI) and school-based services effectively and efficiently (Cason, 2009, 2011; Heimerl & Rasch, 2009; Kelso, Fiechtl, Olsen, & Rule, 2009).

Similarly, evidence supports the use of telehealth for the delivery of occupational therapy services within the school setting for evaluation and intervention (Gallagher, 2004) as well as for reintegration of students with traumatic injury following acute rehabilitation (Verburg, Borthwick, Bennett, & Rumney, 2003).

Schmeler, Schein, McCue, and Betz (2009) detailed the use of assistive technology via a telehealth service delivery model for clinical and vocational applications. Telehealth is also being used to support work through remote assessment and analysis of work spaces. Bruce and Sanford (2006) described using teleconferencing to complete remote assessments and discussed the need for a highly structured and comprehensive assessment tool to be able to complete remote assessments.

We strongly urge this Committee to favorably report these bills.  Our patients and clients will be well served by this expansion.

Respectfully submitted,
Karen J. Hefler, OT                    Karen Jacobs, OT, OTR, EdD, CPE, FAOTA
President, MAOT                       Boston University


Please see the following link for further clarification on the new regulations that became effective in November 2016:

Additional information about the regulations may be found on the Board of Allied Health Professions web page:

Reminder:  All occupational therapy practitioners should be signing their documentation and appropriately using the new professional designation immediately following your name.

 Important Information for OT Practitioners

On November 18, 2016, new regulations for Occupational Therapy were put into effect.

 The most significant change is that Massachusetts law now requires an OT or an OTA signing any medical record, or any other professional documentation, with the licensee’s name, professional designation, and license number.  An example would be   Mary Smith, OT, xxxx,  / John Doe, OTA, xxxx

Karen J. Hefler, OT
MAOT Government Relations Representative

Legislative Activity 2015-2016

Licensure activity:

Since February 2008, members of MAOT have been actively involved in reviewing the statute and regulations for

occupational therapy (OT). These regulations have not been revised since the implementation of licensure in 1984.

They are outdated and no longer reflect current practice or terminology. The occupational therapy profession has

undergone tremendous growth and change as a result of evolving health care systems, research, and advances

within health care education and practice.

As reported last year, with Governor Baker's term starting in January 2015, part of his transition was Executive

Order 562. He issued a "pause" on all boards, on all regulations. This "pause" concluded in June 2016. All boards

had to review CURRENT regulations (not the new proposed regulations that were approved by the Allied Health Board

in May 2014) and eliminate the "confusing, unnecessary, redundant, and inconsistent". Revisions in the spirit of the

Executive Order 352 were voted on by the Allied Health Board on October 21, 2015. Administration and Finance

then had to review all of the changes submitted by the various professional boards and then the process of the

public hearings could begin.

In June 2016, the revised regulations were approved by Administration and Finance. In summary, the proposed

changes to our outdated 1984 regulations as a result of the Executive Order 562 included the following:

-Documentation-signature with the provider’s name, professional designation, and license number and identification

of types of documentation from the occupational therapist, occupational therapy assistant, and occupational

therapy aide.

-Co-signing of documentation-streamlining criteria for co-signing requirements

-Designations-OT, OTA, OT/s (OT student), OTA/s (OTA student), OT/c or OTA/c (OT or OTA applicants practicing

under the direction of a licensee)

MAOT requested additional changes:

1. Change all references from AOTCB to NBCOT. AOTCB disbanded in April 1996.

2. Replace the word “patient” with “client”. The term “client” is more inclusive and is more applicable to the variety

of practice settings for occupational therapy.

3. Change all references to “occupational therapist assistant” to “occupational therapy assistant”.

4. Replace the words “treatment” or “services” to “intervention”. The term “intervention” is more inclusive and is

more applicable to the variety of practice settings for occupational therapy.

Administration and Finance agreed that changes should be made for “AOTCB” to “NBCOT”, changing “patient" to

“client”, and changing “occupational therapist assistant” to “occupational therapy assistant”. Changing the term

“treatment” to “intervention” was felt to be a more significant change than was in the spirit of the Executive Order

562 (which stated, "no Agency shall promulgate a new regulation which has not been reviewed pursuant to this

Order and does not meet the standards set out in this Order.”)

On August 1, 2016, MAOT submitted comments to John Chapman, Undersecretary, Massachusetts Office on

Consumer Affairs and Business Regulations, advocating changes in order to update our professional licensure

regulations. And on August, 2, 2016, a representative from MAOT attended a listening session at Office of

Consumer Affairs and provided oral testimony advocating changes in order to update our professional licensure

regulations and making corrections on the website to change all references to occupational therapist

assistant to occupational therapy assistant.

On August 19, 2016, representatives from MAOT and AOTA presented oral testimony and written comments to the

Board of Allied Health Professionals in favor of the proposed (limited) changes and advocated additional changes in

order to update our professional licensure regulations.

On August 25, 2016, the Board of Registration in Allied Health Professionals held a Subcommittee Meeting regarding

Continuing Competency. Draft regulations were developed. Key points include:

-Continuing education for 24 units per licensing cycle (every 2 years) with the same requirements for OT and OTA

and PT and PTA.

-Activities can come from a variety of avenues with some limits on the number of units in various categories (similar

to NBCOT).

-Lapsed licenses will be subject to additional requirements.

-The Allied Health Board will conduct audits. Documentation must be kept by the licensee.

-The Allied Health Board will have the ability to suspend, require additional units, pay a fine, etc.

-Requirements will include 2 units of jurisprudence and 2 units of ethics per licensing cycle.

Next steps:

-Proposed regulations will be edited and reviewed by the whole Allied Health Board.

-The State will need to have the "pause" lifted (per the Executive Order 562) in order to go forward in the process

for continuing competency regulations.

In August 2016, MAOT submitted edits to the Board of Registration of Allied Health Professionals website to change

all references to occupational therapist assistant to occupational therapy assistant. And they were done!

Licensure is now on-line! DPL is in process of reviewing vendor for Allied Health. The PCS contract is up for renewal.

On September 21, 2016, representatives from OT, AT, and PT met with Charles Borstel, Director of Division of

Professional Licensure, and Robert Fortes, Deputy Director for Policy and Boards, to discuss continued concerns with

outdated regulations and plans to move forward with further revisions.

On October 27, 2016, the revised regulations were voted on by the Board of Allied Health. These revised

regulations will be submitted on November 4, 2016 and changes will take effect on November 18, 2016. The

changes were published on the website on December 14, 2016. PCS will be notified of the changes for licensure


Legislative Activity

November 2015-Provided testimony in support of Senate Bill 556, An Act Relative to make habilitative services

available to the children of the Commonwealth.

March 2016-A bill was submitted regarding telehealth, but it failed.

June 2016-Conditionally supported House Bill 176, An Act Establishing a board of Physical Therapy, as long as all

three boards can split into separate boards.

The next legislative cycle begins January 17, 2017. Interest has been indicated with respect to telehealth and

mental health parity legislation.

Health Care Reform/Access to Health Care:

On April 28, 2016, a MOAT representative attended an initial organizational meeting, Health Care for All-Mental

Health Parity Coalition. This a Massachusetts Behavioral Health Access and Parity Advocacy Project. MAOT has

attended subsequent meetings and has signed on to letters to various government agencies advocating mental

health parity.

We continue to work on having occupational therapy included in new Mental Health initiatives that are available to 24

states from SAMSHA.

We will continue to monitor any opportunities that present themselves for occupational therapy in the health, mental

health and education areas.

For more information on legislative matters, go to

Contact Karen Hefler, OT, MAOT Government Relations Representative,

The next Legislative Session begins in January 2017. Drafts of bills with sponsors need to be ready by mid-November 2016 for a January 20, 2017 filing. Anyone interested in filing a bill or if you have an idea about an issue relevant to OT in Massachusetts, please contact Karen Hefler.

MAOT - Massachusetts Association for Occupational Therapy, Inc.
Phone: 781.647.5556 - Email:

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