Tennessee Board of OT FAQ:

 

TNOTA & TN OT licensure board FAQs 2020

 

IT IS THE PROFESSIONAL RESPONSIBILITY OF EACH LICENSE HOLDER TO KNOW AND UNDERSTAND THEIR STATE’S PRACTICE ACT IN FULL. TNOTA IS NOT LIABLE FOR ANY MISINTERPRETATIONS OF THE OT PRACTICE ACT OR ANY RULES AND REGULATIONS GOVERNING OT PRACTICE IN TENNESSEE. WHEN IN DOUBT, CONTACT THE STATE LICENSE BOARD DIRECTLY.

 

This information was retrieved from the Tennessee Occupational Therapy Practice Act and meeting minutes from the Board of OT, which are all publicly available resources.

The Rules Governing the Practice of Occupation Therapy
can be found at:
https://publications.tnsosfiles.com/rules/1150/1150-02.20181105.pdf


1. Do I still need to have the same number of in-person CEUs during the COVID-19 pandemic?

The commissioner for the state board of health issued a policy statement suspending the requirement that a certain portion of CEUs must be done live/in-person; Governor Lee's executive order 77 has extended this date through April 28, 2021. There is a possibility that this date may be extended dependent on the circumstances surrounding COVID-19 and the state’s emergency declarations.

This means that OT licensees are still required to have the same number of CEUs for license renewal, but the requirement that a certain portion of those 24 CE credits be “live/in-person” is temporarily waived.

 

2. What does “live/in-person” CE entail?

The practice act does not specify that a certain number of CEUs must be “live,” but it does place a limit on the number of “independent study…online courses” (i.e. pre-recorded courses without an interactive component, capped at 12 credits) and “interactive online courses” (capped at 12 credits). This information is found on page 34 of our practice act. 

For live streamed webinars such as those offered by TNOTA, that is considered a “live” event and does not fall into the category of “interactive online courses” above.

 

3. The licensure board recently changed the way Continuing Education credits are counted during the OT license renewal cycle. What does this look like?*

Currently (until a formal rule is implemented via rule making hearing), CEUs are measured by calendar year and must be completed by December 31 of the year prior to the licensee’s expiration year.

Example: if your license was due to be renewed in May of 2018, all CE credit needed to be completed by December 31, 2017.

Starting soon, CEUs will be measured on a 24-month cycle (not calendar year) leading up to the license renewal date. OTs/OTAs will be required to participate in a minimum number of continuing competence activities during the 24 months that precede the licensure renewal month. The renewal cycle will begin on the first day of your birthday month and continue to the last day of the month preceding your birthday month.

Example: If your license is due to be renewed in May 2022, you need to have the requisite number of CEUs for renewal in the 24 months before renewal, from May 2020-April 2022.

There are no changes to the number or type of continued competence activities required for licensure.

*The board has not yet held a rulemaking hearing on this issue. These rules will take effect once the rulemaking hearing is held.

 

4. What are the continuing education requirements for new graduates?

From Rule 1150-02-.12, paragraph (2) of the practice act: 

For applicants approved for initial licensure by examination, successfully completing the requirements of Rules 1150-02-.04, .05, and .08, [i.e., completing all academic and fieldwork requirements to become an occupational therapist/occupational therapy assistant, following all procedures for initial licensure, and passing the relevant examinations] as applicable, shall be considered proof of sufficient competence to constitute compliance with this rule for the initial period of licensure. The use of physical agent modalities by any licensee requires additional certification pursuant to Rule 1150-02-.04

In other words, Applicants approved for initial licensure by examination are not required to obtain CEs during your initial licensure cycle (because your college education was in the preceding 24 months).

 

5. What are the requirements for suicide prevention education?

In 2019, the Tennessee legislature passed the Kenneth Madge Tullis, MD Suicide Prevention Training Act, which requires suicide prevention training for certain healthcare providers. Beginning January 1, 2020 (following a formal rulemaking hearing), all licensed occupational therapists (not occupational therapy assistants) are required to have a minimum of 2 hours of training by a board approved provider relative to suicide prevention at least once every 4* years (i.e. at least once per two licensure renewal cycles). These 2 hours count toward your total continuing education credits.

New Tennessee licensees and Occupational Therapists applying for initial licensure in the state of Tennessee on or after January 2020 are not required to complete a training program on suicide prevention for 2 years after the date of initial licensure if the applicant can demonstrate successful completion of a 2 hour training program by a board approved provider, that was completed no more than 2 years prior to the application for initial licensure.

In other words, Occupational Therapists will be required to complete suicide prevention training prior to initial licensure and then once every four* years (every two renewal cycles). This is counted in your total number of required CE, and is not in addition to the current requirement of 24 hours. The current language only requires that Occupational Therapists, not Occupational Therapy Assistants, complete this training. TNOTA strongly recommends that OTAs obtain this training as well.

Tennessee’s OT practice act lists board-approved providers of continuing education, which includes TNOTA. TNOTA offers suicide prevention courses several times per year.

Per our practice act (2018), the below are approved Continued Competence Activity Providers:

                  (a)  American Medical Association (AMA) 


                  (b)  American Nurses Association (ANA) 


                  (c)  American Occupational Therapy Association (AOTA) and AOTA approved providers 


                  (d)  American Physical Therapy Association (APTA) 


                  (e)  American Speech-Language-Hearing Association (ASHA) 


                  (f)  International Association of Continuing Education (IACET) 


                  (g)  Rehabilitation Engineering and Assistive Technology Society of North America (RESNA) 


                  (h)  Tennessee Occupational Therapy Association (TNOTA) 


                  (i)  State occupational therapy associations 


                  (j)  State occupational therapy regulatory agencies 


                  (k)  Accredited colleges and universities 


(10) The Board does not pre-approve continued competence activities. It is the responsibility of the licensed occupational therapist and occupational therapist assistant to use his/her professional judgment in determining whether or not the activities are applicable and appropriate to his/her professional development and meet the standards specified in these rules.

*The statute requires this training every 5 years, though the licensure board recommends every 4 years to coincide with the rhythm of renewal cycles.

*The board has not yet held a rulemaking hearing on this issue. These rules will take effect once the rulemaking hearing is held. 

6. What are the requirements for using CE Broker to track continuing education?

Beginning January 1, 2021 (following a formal rulemaking hearing), all licensed OTs and OTAs in Tennessee are required to use CE Broker to track their continuing competence credits. The OT licensure board has published information on CE Broker on their website, under the continuing education section.CE broker offers both free accounts and paid upgraded accounts. The board does not require a paid CE Broker account—licensees may use the free account. Following the rulemaking hearing, the board will use CE Broker to audit 100% of all “non-compliant” licensees, and will audit 5% of all licensees shown as “compliant” on CE Broker.

Our practice act provides a detailed table of all activities which count for continued competence credit, and the requirements to document those hours. 

*The board has not yet held a rulemaking hearing on this issue. These rules will take effect once the rulemaking hearing is held. 

 

7. Why is it so hard to make changes to the OT Rules and practice act, or have the board interpret my practice act question?

The authority to practice as an occupational therapist is established by legislation. The board has purview to write/clarify rules, but cannot change the laws. For example, the board has the authority to set CE requirements for OT practitioners, but does not have the authority to change the scope of practice (as recently discussed in telehealth issues). Essentially anything that says "Pursuant to TCA..." is in relation to the law and is outside of the board's authority to modify. It would take the act of legislation to make changes. To put that change in motion, stakeholder bodies such as TNOTA would have to go through the legislative process to make changes.

Additionally, the board’s activities are subject to sunshine laws, meaning that no official board business can be conducted outside of a public meeting, which must be announced in advance, live streamed, and made available to the public. The board meets several times a year and is not able to meet outside of the predetermined meeting dates unless authorized by government officials.

  

8. How do I know if a continuing education course is approved?

Other than PAMs providers, the Board does not keep an active list of approved courses to reference.  The entity hosting the course will typically advertise that the course is accepted by a certain association.  The TN board allows a max of 24 credits of CE that is approved by third parties such as AOTA, APTA, AMA, ASHA, state associations, etc. or 12 credits from other parties that do not have approval from third parties.

 

9. Can the OT board help me interpret the OT practice act?

Yes.  There is a Board administrator who conducts day to day business.  If it is an issue that requires clarification or further action, it can be added to the agenda for the next board meeting.

 

10. How often does the board meet?

The board typically meets 4 times per year, with an additional session held if urgent business needs to be addressed.

 

11. How long does it take for my license to get approved?

If your paperwork is completed in its entirety with no errors or withheld information, it typically takes 4 weeks during regular processing time.  It can take up to 6 weeks during peak time (this is the period following graduation).  If you have ever had any kind of legal issue (DUI, etc.) or action against another license, it will take longer and may require the individual seeking the license to appear before the Board for final approval.

 

Contact the TN Board of Occupational Therapy

615-741-3807

665 Mainstream Drive, 2nd Floor

Nashville, TN 37243

[email protected]

Website: https://www.tn.gov/health/health-program-areas/health-professional-boards/ot-board.html