Fieldwork Student and Paraprofessional in a School District
An OT in a Michigan school district supervises a Level II fieldwork student and a district-employed 'therapy paraprofessional.' The student has 8 weeks of experience and is scheduled to run a 30-minute fine-motor group alone while the OT attends an IEP meeting. The paraprofessional is asked to complete a Medicaid billing note and to update the student's goal progress in the IEP progress report. The OT also wants the student to write the discharge summary for a child who is graduating from services. The paraprofessional has a high school diploma and no OT license. The OT plans to review and sign all notes at the end of the week. The district is short-staffed because two OT positions are vacant. The OT has not written a supervision plan.
1. May the Level II fieldwork student run the fine-motor group alone while the OT attends the IEP meeting?
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No. A fieldwork student is not licensed and cannot be the sole provider of OT services. The student may perform increasingly independent tasks as part of a supervised learning experience, but the supervising OT remains responsible for the patient and must provide supervision appropriate to the student's competence and the students' needs. Eight weeks into Level II does not justify leaving a group alone if the OT is unavailable. The OT should either be physically present or available, arrange a licensed OT or OTA to supervise, or reschedule the group. The student can lead activities with the OT in the room or immediately available, and the OT should document supervision. Allowing the student to run the group alone would create an unlicensed-practice and supervision problem.
2. May the paraprofessional complete the Medicaid billing note and update IEP goal progress?
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No. The unlicensed paraprofessional may assist with non-skilled tasks and may collect data under direction, but the Medicaid note documents skilled OT services and must be completed by the licensed provider who delivered and supervised the service. IEP goal progress requires OT judgment about whether goals are met and what the data mean; the OT must interpret the data and complete the progress report. The paraprofessional can record raw observations, but the OT must review, analyze, and sign. Letting the paraprofessional document progress or billing would misrepresent the service and could support fraud and supervision violations.
3. May the student write the discharge summary? What should the OT do?
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The student may draft a summary as a learning exercise, but the OT must make the discharge decision, review the content, and sign the final discharge summary. Discharge is an OT responsibility and cannot be delegated to an unlicensed student. The OT should ensure the summary reflects the child's status, goals, and recommendations, and that the parent and team receive it. The OT should also create a written supervision plan for the student and the paraprofessional, specify which tasks are permitted, and review all documentation before it enters the record. A late weekly review is not sufficient for billing notes or progress reports.