Hearsay wearing a lab coat

You asked a careful question about your scope and got an answer delivered with total certainty and no source. Maybe it came in a comment thread, maybe in a team meeting, and you felt yourself shrink a little inside a profession you spent years training for. If that has happened to you, this essay is for you, and so is the free journal club I’m hosting this Saturday.

Details are at the end, or you can join the Evolved Living Collaborative here now and meet us there Saturday.

I see some version of this exchange nearly every week, in practice groups, in team meetings and in hallways outside treatment rooms. I’ve de-identified it, since what matters is how it works and nobody in particular.

A practitioner asks whether OTs can perform digital stimulation as part of a bowel program for a client with a spinal cord injury. She has already checked her state practice act and the AOTA materials, found nothing explicit either way, and is asking before she proceeds. That’s exactly what a careful clinician should do.

Someone answers in two words.

Absolutely not.

They cite no statute, regulation or professional standard, and often give no sign that they hold the credential they’re ruling on.

That answer will land on somebody’s practice. Maybe not hers, since she was already reading the source documents. Somebody watching, though, will absorb “OTs can’t do that” and carry it into a team meeting six months from now, where a person who no longer remembers where they heard it will repeat it as fact.

A scope shrinks one confident, unsourced sentence at a time, repeated until it hardens into something that feels like law.

The missing-sentence fallacy

The reasoning under that two-word answer goes like this: I can’t find this intervention named in an OT document, so it must be prohibited.

Our own professional resources ask for a much fuller process. That process includes checking whether applicable documents actually contain language prohibiting the practice (American Occupational Therapy Association [AOTA], n.d.-c), and I’ll lay out the whole sequence below.

AOTA describes occupational therapy as a dynamic and evolving profession responsive to societal needs, system changes, emerging knowledge, research and technology. It also makes clear that professional documents do not supersede state laws and regulations governing practice (AOTA, 2021). Silence in a document tells you the document is finite, and by itself it proves nothing about prohibition.

Sometimes that silence tells us something more hopeful. A practice that has not been extensively codified may simply be an area where the profession has not yet developed the evidence, competency infrastructure, educational resources or policy language practitioners need. People may already be doing pieces of that work in clinical programs and communities, while much of their knowledge stays in clinical reasoning, local outcomes and conversations with one another.

That gap is an invitation to build, responsibly. When practitioners pool what they have learned, document outcomes, collaborate with researchers and communities, develop competencies, and bring that evidence into professional and regulatory conversations, today’s missing sentence can become tomorrow’s resource.

I’m doing exactly that right now, working on a paper with Dr. Tim Dionne and Dr. Susan Burwash, and I’ll come back to it at the end.

So when you can’t find a practice named anywhere, one question is absolutely whether you are permitted and competent to do this now. Another is who ought to be developing the evidence and infrastructure this area still needs, and sometimes the answer to that second question might include you.

Where our certainty actually comes from

I’ve been watching how scope gets argued online for a long time, and the pattern is remarkably consistent. People who answer scope questions with total conviction are often drawing on something far more local than they realize.

They’re drawing on when and where they went to school, and on what the curriculum emphasized in that particular decade. A clinician trained twenty years ago and one trained last spring can hold very different pictures of the same profession, and each may describe theirs as simply “what OT is.”

They’re also drawing on the traditions of the agencies they’ve worked in, meaning the way a department has always done things and the precedent nobody has questioned since the manager before last.

Very often they’re drawing on their own personal boundaries as well. “I would never do that” is a legitimate thing for a clinician to feel, and “I have not developed competence to do that safely” is an important professional judgment. Delivered as a statement about an entire licensed profession, however, that individual boundary can become personal preference dressed up as policy.

Six things we collapse into one

Most scope arguments in our profession are really six different conversations wearing one label. Untangling them is the skill:

* The profession-wide scope of occupational therapy

* State practice-act regulation

* Clinical guidelines and standards of care

* Areas of natural overlap with other professions

* Employer or facility policy

* An individual practitioner’s scope of competence

“I haven’t been trained in this and wouldn’t perform it” is a complete, honorable, professional sentence, and it belongs to the sixth category. Once it gets upgraded into “our profession isn’t allowed to do this,” it has quietly taken over the other five, usually without anyone in the room noticing.

AOTA’s own decision process gives us a better sequence. Is this consistent with occupational therapy’s professional domain? What does state law permit or restrict? Do applicable professional documents or clinical guidelines prohibit it? What education, training, supervised practice or credentials are required? Has the practitioner demonstrated competency? What does the evidence support? What do the payer and the organization require? And can the practitioner articulate why this service belongs within occupational therapy for this client? (AOTA, n.d.-c).

Answering those questions takes literacy. Answering in two words takes two seconds and can shape somebody’s access to comprehensive care.

What this looks like in real questions

Scope arguments sound abstract until you watch one land on an actual client. Here are four questions I see come up again and again, and each one sits on a different layer.

Can OT address bowel and bladder management after a spinal cord injury? This is the question from the opening. Our own practice framework names toileting and toilet hygiene among the activities of daily living (AOTA, 2020b). For someone living with SCI, a bowel and bladder routine can decide whether they can hold a job, travel, date or sleep through the night, which makes it about as occupational as a need gets. I’ve still watched practitioners hand it off entirely because somebody once called it “a nursing thing.” Nursing has a real role here, and so do physicians, and so do we. That’s category four, natural overlap, being mistaken for category one. Whether a specific technique like digital stimulation is permitted in your state is a separate and legitimate question, and it deserves a sourced answer. Part 2 walks through how to get one.

Can OT address addiction? Occupational therapists look at how substance use reshapes a person’s self-care, productivity and leisure, and help people rebuild daily routines that can hold (Ercan Doğu & Özkan, 2023). AOTA’s own practice publications describe OT’s role in return to work for people with substance use disorder (Wheeler et al., 2022). A national survey of practitioners found genuine interest in working with this population alongside real gaps in confidence and knowledge (Mattila et al., 2022). That’s a category-six gap in education and competence, and a profession can close that kind of gap.

Can OT work in pelvic health? I’ve heard “pelvic floor is a PT specialty” stated as settled fact more times than I can count. Pelvic health covers bowel and bladder health, vaginal and uterine health, and sexual health, including the muscles and structures involved (Akselrud & Vestal, 2021). Our practice framework names toileting and sexual activity among the activities of daily living (AOTA, 2020b), and AOTA’s own clinical guidance says OT practitioners can address underlying body structures and functions, such as pelvic floor strengthening to reduce bowel and bladder leakage, to improve everyday performance (AOTA, n.d.-e). OTs are already practicing and publishing in this area. Specific techniques, including internal assessment, still depend on your jurisdiction and your training, so that question gets answered by your state’s rules and your own competence. What doesn’t hold up is the claim that the whole area belongs to one profession. That’s category four, natural overlap, being mistaken for category one again.

Can OT perform dry needling? Here state law really is most of the conversation, and it shows how quickly that layer can move. At the professional level, AOTA’s policy on interventions to support occupations names dry needling among the techniques that may be used in preparation for, or alongside, occupation (AOTA, 2023). The states have gone very different ways. In 2023, Florida’s Board of Occupational Therapy declined to find dry needling within OT scope. The question then moved to the legislature, and since July 1, 2026, Florida law has authorized OTs to perform dry needling once they meet defined standards for experience, training and demonstrated competency (Florida House of Representatives, 2026; Laws of Florida, 2026). Alaska’s board concluded in 2023 that its OT statute didn’t support dry needling, then retracted that position after conflicting legal opinions and began work on clarifying language (Alaska Board of Physical Therapy and Occupational Therapy, 2023).

So sometimes the honest answer to a scope question really is no, at least for now. A careful no that comes with a citation protects clients and practitioners alike, and it can even become the starting point for change. The no that does damage is the one that arrives with no source at all.

For occupational therapy assistants, the layers multiply

Add an OTA to the picture and every one of those questions picks up another layer.

OTAs deliver a large share of occupational therapy services across settings, and their practice exists within the profession’s scope. Their actual responsibilities are also shaped by state supervision requirements, payer rules, facility requirements, the nature and complexity of the clients being served, their demonstrated service competency, and what the supervising OT appropriately delegates.

An OTA’s individual scope of competence is not necessarily frozen at graduation.

AOTA’s supervision guidance describes supervision as a collaborative process supporting safe and effective service delivery while fostering professional competence and development. It also describes OTAs as providing services under the supervision of and in partnership with occupational therapists, with delegation dependent in part on demonstrated service competency (AOTA, 2020a, 2025). AOTA’s scope decision guidance likewise identifies training and supervised practice as mechanisms through which practitioners can establish competence in an area of practice (AOTA, n.d.-c).

That means mentorship matters. When an OT has developed competence in an emerging or specialized area of practice, supervision can become one mechanism through which an OTA develops the knowledge, skills and demonstrated service competency necessary to participate appropriately in that work.

The supervising OT is not rewriting state law or personally expanding the OTA’s legal scope. Both practitioners remain accountable to state law, applicable regulations, payer requirements, professional standards and facility policies. What can expand is the OTA’s individual capacity within that legally permitted professional scope.

What OTAs are already doing

OTAs are already practicing more expansively than many people assume, and that includes some OTAs themselves. Here are four sentences I hear repeated as rules, and what the sources actually say.

“OTAs don’t do evaluations.” AOTA’s position is more nuanced. OTAs can contribute to the evaluative process, especially the occupational profile, and can administer standardized and nonstandardized assessments once they’ve established competency (AOTA, 2024). The OT still interprets the data and holds responsibility for the evaluation. California’s board goes further and allows OTAs to perform reassessments and discharge plans under OT supervision, as long as the OT reviews and interprets what the OTA gathers and both sign the plan of care (California Board of Occupational Therapy, n.d.).

"Maintenance therapy is therapist-only." Medicare's home health rules did reserve skilled maintenance therapy for therapists until 2020. CMS then changed its regulations so OTAs can furnish maintenance therapy under a program the OT establishes, within their state's scope of practice (Centers for Medicare & Medicaid Services [CMS], 2019a). The OT still handles the initial assessment, the plan of care, program development and reassessment every 30 days, and supervises the OTA. CMS noted that the change brought home health in line with SNFs and said it would let assistants practice at the top of their state licensure (CMS, 2019b). If your agency still tells OTAs that maintenance visits are off-limits, it's worth asking what source that rule rests on.

“OTAs can’t use modalities.” AOTA’s position statement names OTAs alongside OTs as practitioners who may use physical agent, mechanical and instrument-assisted modalities as part of occupation-based intervention (AOTA, 2024). Its ethics guidance adds that where state regulations permit, an OT may delegate modalities to an OTA who is trained and has demonstrated competency, and both keep records of that training (AOTA, n.d.-d). Many states add competence requirements of their own, and that’s the state layer doing its job.

“Advanced practice is for OTs.” California’s board answers this one directly. OTAs can provide advanced practice treatment in areas such as hand therapy, modalities and dysphagia when they’re supervised by an OT the board has approved in that area (California Board of Occupational Therapy, n.d.).

Each of these runs through supervision, demonstrated competence and state law. Taken together, they show how far that structure can stretch when an OT and an OTA treat it as a pathway for growth, and how much gets lost when it’s treated like a fence.

Delegation also remains contextual. Something appropriate to delegate for one client may require greater OT involvement for another because of complexity, instability, risk, the nature of the evaluation, or the clinical reasoning required.

AOTA describes OT-OTA practice as intraprofessional collaboration, a far richer thing than handing a fixed checklist of tasks from one practitioner to another (AOTA, n.d.-a). Delegation is itself an act of clinical reasoning. When it works well, the OT and OTA are partners in shared clinical thinking, each bringing professional knowledge and judgment to the care while remaining accountable to their respective roles.

Flatten that relationship into a universal list of approved tasks and we lose the possibility of mentorship, professional development, evolving competence and two trained minds working together in service of the client.

The risk of crowdsourcing policy

Every answer here depends on where you’re standing. State law varies, and so do regional practice patterns, payer requirements, agency policy and practice settings. The dry needling example makes that vivid: the same question gets a different legal answer in Florida than in Alaska, and a different answer in Florida this year than it got three years ago. A confident answer from someone in another state, setting or profession might be accurate for them and wrong for you, and a comment section gives you no way to tell which.

The open internet is a wonderful place to find colleagues and a risky place to source policy.

When someone meets a nuanced policy question with black-and-white conviction, it’s worth asking a few quiet questions of your own. What source are they relying on? Does that source actually govern this practitioner in this jurisdiction and setting? Does it prohibit the practice, establish conditions for it, or simply not mention it? Are they describing professional scope, legal scope, organizational policy, payer coverage, or their own scope of competence?

Each of those is a very different claim. In Part 2, I’ll walk through the sequence I recommend when you need a real answer.

When the interpretation belongs to whoever runs the building

The same pattern has a quieter version, and it happens inside our own workplaces.

In many settings, the working definition of policy and scope ends up becoming whatever a middle manager, regional lead, director or compliance consultant says it is. Their interpretation gets written into facility policy and repeated at onboarding until it becomes the only version anyone on staff has ever heard.

Facility policy matters, and so do compliance, payer requirements, credentialing, plans of care and organizational responsibilities. Facility policy still can’t stand in for the legal scope of a profession. Clinical determinations about an individual client’s needs require the professional reasoning of the practitioners responsible for evaluation and service delivery, operating within applicable law, payer requirements, organizational policy, evidence, ethics and demonstrated competence.

That distinction matters because policy frequently leaves room for individualized professional judgment. Two clients with the same diagnosis may need very different levels or types of skilled intervention, and the practitioner who evaluated them is the one positioned to say which. Medicare’s coverage of skilled maintenance therapy, which I’ll come back to below, is a striking example of how much room that judgment was always meant to have.

Facility policy is one of the layers above, and a legitimate one. It is also a layer practitioners can engage. Asking what statute, regulation, payer requirement or evidence an organizational rule is based on is a reasonable professional question, and so is bringing clinical reasoning and evidence to the people responsible for writing policy.

Sometimes the answer really is, “That’s how we’ve always done it.” Even then, the conversation can keep going.

Why I went back for the doctorate

That mechanism is the reason.

The number one barrier I hit in the field was a perceived policy wall that, every time I chased it back to its source, often turned out to be hearsay wearing a lab coat. It had been handed down from manager to manager and from fieldwork educator to student until it felt like federal law, and it quietly set the ceiling on what I was allowed to offer a human being whose life I had been invited into.

So I spent three years chasing those sentences back. What I found was a much more layered relationship among law, regulation, payer policy, professional guidance, evidence, organizational policy and clinical reasoning than the version I had inherited through rehabilitation culture.

What policy is actually for

Licensure exists to protect the public. Regulation establishes boundaries around who may practice, under what conditions and with what accountability, and those foundations matter enormously.

AOTA identifies state law as ultimately defining the legally authorized scope of occupational therapists and occupational therapy assistants, while advocating for practitioners to practice to the full extent of their licenses (AOTA, n.d.-b). Those two ideas sit together comfortably. A boundary can protect the public without requiring us to make the professional world inside that boundary as small as possible.

Competence, evidence, ethics, training, client safety and state law all matter, and none of them require us to pretend that the narrowest version of practice we personally inherited is the permanent definition of occupational therapy.

Top of scope, bottom of code

CPT coding and professional scope answer different questions. Billing terminology provides standardized language for reporting healthcare procedures and services, while legal professional scope is established through state law and regulation. A billing code should never stand in for the legal or conceptual definition of occupational therapy practice.

When the narrowest interpretation of a billing category becomes the definition of the work, the service can shrink to whatever is easiest to describe. Our clients rarely fit that neatly. People living with complex, fluctuating or rapidly progressing conditions require skilled judgment, interpretation and real-time adjustment.

Medicare’s history gives us a powerful example of what happens when shorthand gets mistaken for policy. For years, some providers and contractors operated as though Medicare therapy coverage required a beneficiary to demonstrate potential for improvement.

The 2013 Jimmo v. Sebelius settlement did not create a new improvement exception. CMS describes the settlement as clarifying Medicare’s longstanding policy: coverage of skilled nursing and therapy services under the SNF, home health and outpatient therapy benefits does not depend on whether a beneficiary is expected to improve. Skilled care may be covered when it is necessary to maintain function or prevent or slow deterioration, provided the other Medicare coverage criteria are met (CMS, n.d.). CMS further acknowledges that the settlement may have changed practice among providers, adjudicators and contractors who had erroneously believed that improvement was required (CMS, n.d.).

Think about what that means. A restrictive interpretation can become so normalized that an entire service culture starts behaving as though it is the rule, until someone goes back and rediscovers what the policy actually said.

What restriction costs

A restrictive reading usually feels like the safe choice, since nobody gets written up for saying no. The costs are real, and they fall on people who never had a say in the decision.

Clients pay first. When a service is withheld because someone assumed it was prohibited, the person who needed it goes without, or gets routed to a provider who may not see the occupational picture at all. Picture the man with a new spinal cord injury whose bowel routine never gets built around his return to work, because everyone assumed it belonged to someone else. Jimmo showed how long that kind of assumption can go on before anyone checks the source.

The profession pays next. Every area we talk ourselves out of gets filled by another discipline, or by nobody. Over time the public, referral sources and payers learn a smaller version of what occupational therapy is, and that smaller version becomes the one we teach students.

Our future sustainability pays too. Community practice, population health, behavioral health integration, prevention and the areas still emerging are where new service lines and reimbursement pathways get built. A profession that backs away from them before exploring them gives up income for its practitioners and viability for its programs long before any regulator has weighed in.

Our workplaces pay as well. When scope conversations run on fear, colleagues start policing one another, and a question can get treated like a confession. A practitioner who asks about an intervention, or who already uses it with appropriate training and competence, can find herself accused of practicing illegally by someone who has never read the relevant statute. OTAs often absorb the sharpest version of this. Accusations like that damage reputations and push careful clinicians into silence, and silence is where moral distress grows and good practitioners quietly leave.

Much of this comes from scarcity, the belief that scope is a small, fixed territory where any expansion by one practitioner or profession threatens everyone else. Our clients’ occupational needs far outstrip the workforce available to meet them, and there is more than enough work to go around.

Precision and curiosity serve us better than suspicion. If a colleague’s practice genuinely concerns you, the professional response is a direct conversation grounded in sources, and where clients are at real risk, formal channels exist for exactly that. An uncited accusation in a hallway or a comment thread carries none of that accountability.

A broad profession, and a focused practitioner

After all of this, you might wonder whether a broad scope means every OT and OTA is supposed to do everything. It doesn’t.

You’re allowed to specialize. You can love hand therapy and have no interest in dry needling, or spend your whole career in school-based practice and never build a bowel program. You’re allowed to say “that’s outside my competence” or “that isn’t work I want to do,” and both are legitimate professional boundaries. Earlier I called “I haven’t been trained in this and wouldn’t perform it” a complete, honorable sentence, and I meant it.

A personal boundary stays healthy when it stays personal. Mine can shape my caseload and my continuing education. It doesn’t get to set the ceiling for the colleague down the hall, or for the practitioner in another state building an emerging area I’ve never studied.

The profession stays broad so each of us can go deep somewhere. When I respect your zone of excellence and you respect mine, we end up with a field full of practitioners who refer to one another with confidence and who together reach far more of our clients’ occupational lives than any one of us could alone. Some of those zones will be well established, and some will be emerging practice that someone is patiently building right now.

Nobody has to hold all of it. We only have to stop shrinking the parts other people are holding.

Which brings me to Saturday, and to Elizabeth Yerxa

None of this is available to a profession that isn’t fluent in its own science. You can’t argue thoughtfully for an evolving scope from a foundation you can’t put into words, and confidence without grounding is just volume.

Twenty-six years ago, Elizabeth Yerxa described occupational science as part of a “renaissance of service to humankind” through the development of knowledge grounded in occupation (Yerxa, 2000). Reading her now feels like receiving a letter from someone who loved this profession enough to ask what kind of knowledge we would need to become what we claimed we could be.

We can close the distance between that scholarship and everyday practice through translation, carrying occupational science from the academy into the field and into an ordinary Tuesday afternoon.

That’s part of the purpose of the Evolved Living Collaborative: an accessible home for occupational science literacy for OTs, OTAs, students and colleagues interested in understanding what an occupational perspective can contribute.

Another piece of that work is emerging. There remain significant gaps in how practice-based knowledge from emerging and developing areas becomes visible, studied, refined and eventually translated into accessible professional resources. Dr. Dionne, Dr. Burwash and I are exploring an evidence-based pipeline for emerging and developing practice settings, so knowledge being created in real-world practice can become increasingly practical, usable, researchable and anchored in occupational therapy’s distinct identity and science base.

Perhaps the missing sentence from the beginning of this essay is something we need to learn how to write, together.

Come read with us

Journal Club: Elizabeth Yerxa, Occupational science: A renaissance of service to humankind through knowledge (2000) Saturday, September 26, 1pm Pacific Free, inside the Evolved Living Collaborative

OTs, OTAs, students and curious colleagues from other disciplines are all welcome. Come whether you’ve read the article closely, skimmed it on your lunch break, or plan to arrive with nothing but curiosity and a coffee. The classroom has a summary, reflective prompts and an audio walkthrough if you want a running start.

The session will be recorded and reposted in the group, since knowledge translation is the entire point and I want people who can’t make 1pm on a Saturday to have access. If you’d prefer your contributions edited out, you’ll have that option, no explanation required.

Join the Evolved Living Collaborative here: https://www.skool.com/evolved-living-collaborative-6395/about

See you Saturday.

Coming in Part 2 on Monday: what to do instead. I’ll cover where to start when you need a real answer about legal and ethical scope, and how a “not yet” from a regulator can become a map, which is exactly what happened with dry needling in Florida. I’ll also unpack what this month’s Justice Manual update actually means for practitioners, and open three beta spots to work on this with me one to one.

Subscribe so Part 2 lands in your inbox Monday.

References

Akselrud, R., & Vestal, L. (2021). The role of occupational therapists in pelvic health: An interview with Lindsey Vestal. SIS Quarterly Practice Connections, 6(3), 12-14. https://www.aota.org/publications/sis-quarterly/home-community-health-sis/hchsis-8-21

Alaska Board of Physical Therapy and Occupational Therapy. (2023). Frequently asked questions: Dry needling [Position statement update, November 17, 2023]. https://www.commerce.alaska.gov/web/cbpl/ProfessionalLicensing/PhysicalTherapyOccupationalTherapy/FrequentlyAskedQuestions.aspx

American Occupational Therapy Association. (n.d.-a). OT and OTA intraprofessional collaboration. https://www.aota.org/practice/practice-essentials/ot-and-ota-intraprofessional-collaboration

American Occupational Therapy Association. (n.d.-b). Occupational therapy scope of practice. https://www.aota.org/practice/practice-essentials/scope-of-practice

American Occupational Therapy Association. (n.d.-c). Scope of practice questions and answers. https://www.aota.org/practice/practice-essentials/scope-of-practice/scope-of-practice-questions-answers

American Occupational Therapy Association. (n.d.-d). FAQs about ethics. https://www.aota.org/practice/practice-essentials/ethics/faqs-about-ethics

American Occupational Therapy Association. (n.d.-e). Women’s health. https://www.aota.org/practice/clinical-topics/womens-health

American Occupational Therapy Association. (2020a). Guidelines for supervision, roles, and responsibilities during the delivery of occupational therapy services. American Journal of Occupational Therapy, 74(Supplement 3), 7413410020. https://doi.org/10.5014/ajot.2020.74S3004

American Occupational Therapy Association. (2020b). Occupational therapy practice framework: Domain and process (4th ed.). American Journal of Occupational Therapy, 74(Supplement 2), 7412410010. https://doi.org/10.5014/ajot.2020.74S2001

American Occupational Therapy Association. (2021). Occupational therapy scope of practice. American Journal of Occupational Therapy, 75(Supplement 3), 7513410020. https://doi.org/10.5014/ajot.2021.75S3005

American Occupational Therapy Association. (2023). Policy E.18: Interventions to support occupations.

American Occupational Therapy Association. (2024). Physical agent, mechanical, and instrument-assisted modalities in occupational therapy practice, 2024. American Journal of Occupational Therapy, 78. https://doi.org/10.5014/ajot.2024.78S103

American Occupational Therapy Association. (2025). Supervision 101: Important considerations for supervisors and supervisees. OT Practice, 30(12). https://www.aota.org/publications/ot-practice/ot-practice-issues/2025/supervision-101-important-considerations-for-supervisors-and-supervisees

California Board of Occupational Therapy. (n.d.). Supervision: Frequently asked questions. https://www.bot.ca.gov/forms_pubs/supervision_faqs.shtml

Centers for Medicare & Medicaid Services. (n.d.). Jimmo settlement. https://www.cms.gov/medicare/settlements/jimmo

Centers for Medicare & Medicaid Services. (2019). Medicare and Medicaid programs; CY 2020 home health prospective payment system rate update; home health value-based purchasing model; home health quality reporting requirements; and home infusion therapy requirements [Final rule with comment period]. Federal Register, 84(217), 60478. https://www.federalregister.gov/documents/2019/11/08/2019-24026/medicare-and-medicaid-programs-cy-2020-home-health-prospective-payment-system-rate-update-home

Centers for Medicare & Medicaid Services. (2019b, October 31). CMS finalizes calendar year 2020 payment and policy changes for home health agencies and calendar year 2021 home infusion therapy benefit [Fact sheet]. https://www.cms.gov/newsroom/fact-sheets/cms-finalizes-calendar-year-2020-payment-policy-changes-home-health-agencies-calendar-year-2021-home

Ercan Doğu, S., & Özkan, E. (2023). The role of occupational therapy in substance use. Nordic Studies on Alcohol and Drugs. https://doi.org/10.1177/14550725221149472

Florida House of Representatives. (2026). CS/HB 867 bill analysis: Dry needling by occupational therapists. https://www.flsenate.gov/Session/Bill/2026/867/Analyses/h0867c.HCB.PDF

Laws of Florida. (2026). Chapter 2026-110, Committee Substitute for House Bill No. 867. http://laws.flrules.org/2026/110

Mattila, A., Santacecilia, G., & Lacroix, R. (2022). Perceptions and knowledge of substance use disorders and the role of OT: A national survey. American Journal of Occupational Therapy, 76(Supplement 1), 7610510156p1. https://doi.org/10.5014/ajot.2022.76S1-PO156

Wheeler, S., Davis, D., & Acord-Vira, A. (2022). Occupational therapy’s role in return to work and substance use disorder in a general practice setting. SIS Quarterly Practice Connections, 7(1), 30-33.

Yerxa, E. J. (2000). Occupational science: A renaissance of service to humankind through knowledge. Occupational Therapy International, 7(2), 87-98. https://doi.org/10.1002/oti.109

The thinking and writing are mine. I use AI as an editing tool to organize complex ideas, untangle long sentences, and translate dense scholarship into accessible language often after speaking my thoughts into a recorder. I review and take responsibility for everything I publish.

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