Telehealth Across State Lines and an Unlicensed “Developmental Coach”
An OT licensed only in Ohio owns a pediatric private practice in Columbus. A family she has treated for 14 months moves to northern Kentucky and asks to continue weekly telehealth sessions for sensory integration and self-regulation. The OT plans to bill the family’s new Kentucky Medicaid plan. Meanwhile, to expand capacity, the practice hires a “developmental coach” with a bachelor’s degree in psychology but no OT license and no formal OT assistant training. The coach will lead “sensory gym” groups, write progress notes, and the OT will review and sign them. The OT plans to supervise the coach by phone once a month and to advertise the groups as occupational therapy. The OT has never observed a group.
1. Can the OT continue treating the family by telehealth using her Ohio license? What must she verify before the next session?
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An Ohio license authorizes OT practice in Ohio; it does not automatically authorize treating a patient who is physically located in Kentucky. Telehealth is generally regulated where the patient is located at the time of service, so the OT must determine Kentucky’s licensure requirements before continuing. She should verify whether Kentucky requires a Kentucky license, a telehealth registration, or another authorization, and she should confirm the requirements of the Kentucky Medicaid plan she intends to bill.
If the OT is not authorized in Kentucky, she should not continue skilled OT telehealth sessions. She could help the family locate a Kentucky-licensed OT, provide records with proper consent, or continue only if she obtains the required authorization. Billing Kentucky Medicaid for services provided without the required licensure would create false-claims and licensure risk.
2. Evaluate the plan to have the developmental coach lead groups, write notes, and have the OT sign them. What is permissible and what is not?
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The coach is an unlicensed person, not an OT assistant. The coach may perform non-skilled support tasks-such as setting up the gym, taking attendance, or assisting with transitions-only if those tasks do not require OT judgment and are consistent with state and payer rules. The coach may not design or lead skilled OT groups, select sensory strategies, interpret responses, write OT progress notes, or have notes signed by the OT as if the OT provided the service.
Signing another person’s notes as OT documentation would misrepresent who provided the service and could support false billing. Monthly phone supervision does not cure the problem because supervision cannot delegate skilled OT services to an unlicensed person. The OT should either provide the groups herself, hire a licensed OTA and comply with supervision rules, or advertise and deliver the groups as non-skilled wellness programming without holding them out as OT.
3. What documentation and consent issues should the OT address for the telehealth arrangement?
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The OT should obtain informed consent that explains telehealth, its limitations, privacy protections, emergency procedures, and the patient’s location during each session. She should document the patient’s physical location at the time of service, the technology used, and any technical failures that affected care. The documentation should reflect who provided the service and should not be altered to suggest in-person care.
If the OT continues temporarily while arranging transfer, she should document the plan and avoid creating the impression that she is licensed in Kentucky. Records should be shared only with proper authorization and in compliance with privacy law. If the coach is involved in any non-skilled role, the OT should document that role accurately and keep it separate from OT billing.