Vaccination
1. Can occupational therapists administer the COVID-19 vaccine? [Updated Jan. 6, 2022]
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On December 22, 2021, the government made a time limited amendment to the Controlled Acts Regulation to allow more individuals to safely administer the COVID 19 vaccine as outlined in the Regulation.
See the news release for full details.
Occupational therapists can be asked to administer the vaccine. Occupational therapists must follow guidance from their employers, be trained to have the knowledge, skills and judgement to administer the vaccine safely.
2. Do occupational therapists have to provide services to clients who are unvaccinated?
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The Ministry of Health has not stipulated that clients require vaccination to receive services. Denying services to unvaccinated individuals creates health inequities which have ethical implications.
Ensuring the safety of all parties is paramount. The College expects occupational therapists to have clear processes for optimizing safe services, for example, screening clients and conducting comprehensive point of care risk assessments to determine how services, the client, or the environment can be adapted for the safety of all involved. There may be instances when an occupational therapist considers delaying the delivery of services, however, these would likely be exceptional circumstances.
Scope of Practice
1. During COVID-19, can I be asked to do activities that are not typically in the scope of my occupational therapy practice?
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Yes. Occupational therapists have a broad set of transferable skills that can support client care during a pandemic when staff resources are limited. As valuable members of the health care team, occupational therapists may be asked to take on activities that are outside of their normal duties. These activities may include assistance with personal needs, for example, dressing, feeding and toileting. Alternatively, occupational therapists may be asked to assist with mask fit testing or screening procedures. Some activities that occupational therapists may be asked to complete are considered controlled acts and require delegation by a practitioner authorized to perform them. As these activities may not be within usual responsibilities, it is expected that occupational therapists have the appropriate training and competency (knowledge, skills and judgment) to perform the activities safely.
With appropriate safeguards in place we would expect occupational therapists to be flexible during a health emergency to assist the health care system manage increased demands. There may be individual exceptions and we encourage those occupational therapists to have discussions with their organizations to address any concerns.
Redeployment
1. I am being redeployed to help with the pandemic. Do I have to update my College profile information?
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If you are redeployed within the same organization you do not have to update the employment information section on your College profile. If you are redeployed to a different organization we ask that you please update the employer name, address and phone number fields. Please contact the registration program at [email protected] if you have specific questions.
Virtual Services
1. I have already introduced remote services to my practice. What are some of the important considerations I need to keep in mind?
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To reduce the risk of contracting or spreading COVID-19, occupational therapists are encouraged to deliver remote (online, by telephone, or other virtual means) service when possible. When determining what services are appropriate for remote delivery, occupational therapists need to implement a risk assessment and exercise their professional judgment. Considerations include:
Effectiveness
Assessing the necessity of clinical interventions based on the unique circumstances and healthcare needs of each of client (examples of questions the occupational therapist will need to ask are: Can the client privately access and safely operate the technology being used to enable the remote service delivery? Does the client have a physical, cognitive, or sensory deficit preventing their ability to proceed with safe or effective remote service delivery? What is the client’s overall comfort and capability with using virtual technologies?).
Does the virtual technology being used allow for effective communication between the client and occupational therapist, safe occupational therapy interventions, and can the occupational therapist form an accurate professional opinion to make necessary health care decisions?
Privacy and Confidentiality
Will remote service delivery impact the client’s privacy or prevent the protection of the confidentiality of personal health information? Is the virtual platform compliant with relevant privacy legislation, such as the Personal Health Information Protection Act (PHIPA)?
What privacy or confidentiality risks are present when using virtual technologies and how will these risks be communicated to the client to ensure informed consent is obtained?
Risk
What are the other limitations of the remote service delivery and how will they impact the overall care provided? For example, will an OT’s inability to observe the client’s non-verbal cues negatively impact the occupational therapist’s ability to form a reliable professional opinion?
What plans can be put in place to manage potential adverse events which may occur during the remote service delivery, such as technical issues or a client medical emergency?
2. Can I provide virtual services to a client who has moved to another province?
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Yes. An occupational therapist registered in Ontario, wanting to provide virtual services to a client out-of-province service will:
1) Determine if the service can be safely and effectively provided through virtual means (online, by telephone, or other appropriate platforms).
2) If yes, contact the regulatory College in the province of the client to find out the process to provide virtual services in their jurisdiction.
3) Upon confirmation from the provincial regulatory College to proceed, and with consent from the client, an OT can start providing virtual services.
3. If I work from home what are my obligations when handling patient information online?
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The COVID-19 pandemic is an unprecedented situation that calls for adjustments to how occupational therapists communicate with their clients, the public and colleagues. Considering appropriate measures to keep client information confidential and secure is still important. The College does not recommend or endorse specific online platforms for virtual care. It is expected that occupational therapists make reasonable efforts to investigate the security and privacy features that these platforms offer as mentioned in the Guidelines for Telepractice . The professional associations may also have resources related to online platforms.
The Information and Privacy Commission of Ontario has some tips when working from home specific to the COVID-19 situation.
In-Person Services
1. What services should be delivered in-person?
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The College recognizes that there are some occupational therapy services that cannot be safely and effectively provided remotely. When this arises, occupational therapists may proceed to provide in-person services provided that all safety conditions outlined by the government are met. This includes implementing a hierarchy of hazard controls and having sufficient personal protective equipment (PPE), to protect you and your clients from the risk of contracting and spreading COVID-19 and, the anticipated benefits of the services outweigh the potential risk to the client and occupational therapist. It is recommended that where possible, occupational therapists limit the number of in-person visits for safety of the client.
Decisions related to the gradual restart of services should be made using fair, inclusive and transparent processes for all clients following the principles articulated in Directive #2 (January 5, 2022):
Proportionality - the capacity of individual healthcare providers, offices and clinics to offer services.
Minimizing Harm to Patients - Prioritizing services that can result in more significant harm if delayed and which mitigate the greatest risk of harm.
Equity - That all persons with the same clinical needs should be treated in the same way unless relevant differences exist, and that special attention is paid to actions that might further disadvantage the already disadvantaged or vulnerable.
Reciprocity - monitoring the health care status of clients who do not yet appear to require services immediately so that if their health status changes, required services are provided.
When assessing if the service should proceed in-person, there will be many factors the occupational therapist should consider. We have compiled some of the main factors below:
the client’s current needs and how these may change over time
whether the client has some characteristics that result in a high risk for their health and safety
any poor or negative outcome which may result if the service delivery is not provided in-person or is delayed too long
the benefit of providing the service, both from the occupational therapist’s clinical perspective and the client’s perceived benefit of receiving the care
Whether or not social distancing can be maintained during the service delivery
PPE availability
Alternate healthcare providers or facilities able to provide the service in a safer, more suitable environment
Any additional associated risks to clients who may need a caregiver or another individual to assist or accompany during the session
Whether there is a COVID-19 outbreak in the setting or community the service delivery is to take place in
Can Infection Prevention and Control (IPAC) measures be adequately followed, for example, can the equipment used during the service delivery be adequately cleaned?
2. What should I do if a client declines to wear a mask during a visit in their own home? Can in-person services be deferred?
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As noted by federal, provincial and municipal authorities, some clients may not tolerate wearing a mask. The government of Canada recently updated its information on non-medical masks and face coverings. Clients who may not tolerate masking requirements may include:
People who suffer from illness or disabilities that make it difficult to wear a mask;
Individuals who have difficulty breathing;
Children under the age of 2;
For clients who cannot tolerate a mask, you must determine the appropriate personal protective equipment (PPE) to wear based on your Point of Care Risk Assessment (PCRA) and COVID-19 screening results. It is strongly recommended that OTs implement all public health safety measures to prevent exposure to, and transmission of, COVID-19. Recognizing that community OTs work in multiple client homes, the client may be concerned about the risk to them, while the OT needs to be concerned about the risk to all clients and themselves. Balancing and addressing all these concerns is essential, as this will help clients feel more comfortable with the services they receive while helping to reduce community spread.
When someone declines to wear a mask when you are in their home, you should explore the reasons for this, and discuss alternatives. Options may include virtual services, providing essential or urgent in-person care while wearing the appropriate PPE if you are with or within a 2-meter distance, or deferring the in-person home visit to a later date. OTs must document the options considered and discussed with the client, the decision made, and record the rationale for deferring if the OT service is non-essential.
If you are deferring clients who still require services, you have a responsibility to follow up with the client in a reasonable time frame to see if there are any changes in their status and complete another PCRA to determine how to proceed.
3. What happens if I can’t physically distance during the service delivery?
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We recognize that for various reasons, such as client safety or environmental set up, you may not be able to maintain a distance of two metres during the service delivery. When this occurs, you may still decide to proceed with in-person services.
To do so, you need to:
Have a sound and ethical rationale based on clinical judgment
Have completed the risk assessment
Ensure you meet the other specific requirements outlined in the operational requirements set forth by the government
As part of the consent process the occupational therapist should also explain to the client/SDM/parent/guardian the reason for not maintaining the recommended physical distance. When proceeding with in-person services the occupational therapist must ensure they wear the appropriate level of personal protective equipment (PPE). PPE includes gloves, gowns, and facial coverings. Determining the appropriate level of PPE involves carrying out a risk assessment based on the nature of the interaction between the occupational therapist and the client when considering the likely modes of transmission of the infection. It appears the likely mechanism of transmission of COVID-19 is through direct large aerosol droplets or indirect contact of contaminated surfaces. If the government has not issued specific PPE requirements applying to your practice, the client has not screened positive for COVID-19, and you are not performing an aerosol generating medical procedure, at a minimum, you should wear a surgical/procedural mask throughout the service delivery and the client should be asked to wear a mask to the appointment and for the duration of the interaction, where tolerated.
4. If I don’t have the appropriate personal protective equipment (PPE), can I continue to provide in-person services?
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No. The College’s Standards for Infection Prevention and Control require occupational therapists to use their knowledge, skill and judgment when taking steps to protect themselves and others from infection. If having assessed the risk you determine PPE is necessary, but the appropriate level of PPE is not available to you, you should not provide in-person services. If in-person services are required but for the availability of PPE, you should explain the reason the service is being canceled or deferred to your client, why remote service delivery is not a safe or effective option, and if available, document those reasons in the client’s record. Consideration should be given to the possible need to refer the client to another occupational therapist who has the appropriate level of PPE available, and the required knowledge, skill and judgment to deliver the service, depending on the risk posed to the client of deferring or cancelling the service.
All occupational therapists should review Public Health Ontario's Updated IPAC Recommendations for Use of Personal Protective Equipment for Care of Individuals with Suspect or Confirmed COVID-19. The government is recommending that healthcare professionals and their employers source PPE through their regular supply chain. PPE allocations from the provincial stockpile will continue. PPE can also be accessed, within the available supply, on an emergency basis through the established escalation process through the Ontario Health Regions. The Ontario government has also developed a Workplace PPE Supplier Directory to help businesses secure PPE and other supplies.
5. Do I have autonomy to determine which services to provide remotely (online, by telephone, or other virtual means) and which to provide in-person?
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Yes. Occupational therapists are responsible for making this determination as it relates to each of their clients. While consideration about the method for providing the service should be given to the client’s and other stakeholder’s preferences, such as third-party payers, if self-employed, you are ultimately responsible for carrying out the necessary risk assessment and determining how the service can be provided safely and effectively.
If working for an organization, you should also refer to any guidance prepared by your employer as it relates to which services are to be provided in-person and which are to be provided remotely. Follow-up with your supervisor, manager or professional/clinical practice lead with any concerns or if clarification of your employer’s direction is required.
Consent
1. Are there additional consent considerations for remote (online, by telephone, or other virtual means) service?
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Yes. Overall, the process for obtaining consent for remote services remains the same as in-person service. Occupational therapists are expected to obtain informed consent from their clients or substitute decision-maker (SDM) when remote services are offered and provide an opportunity for clients to ask questions about the service. Consent discussions should include such things as the nature of the service and withdrawal options and alternatives.
There are additional considerations to include when discussing remote methods of service delivery including:
who will attend remotely and what each participant’s role is?
risks and benefits and any limitations of participating in remote service
information about the privacy and security features of the platform
As a reminder, client/SDM consent can be given verbally. Obtaining written consent is not a College requirement but may be a requirement of the practice setting or organization. Consent must be documented in the clinical record as outlined in the Standards for Consent and consent checklist.
In addition to the required consent, when discussing remote services an occupational therapist can make suggestions to encourage the comfort and effectiveness of the overall experience. For example;
provide a brief orientation to the features of the platform
discuss what to do in case of emergency or unexpected event
encourage privacy of sessions, for example, use of headphones, private areas of house, using mute option to minimize disruptions and maintain privacy
Record Keeping
1. Do I need to document the rationale for providing in-person vs remote service in my clinical notes?
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Yes. However brief, any decision point regarding client care should have an accompanying rationale. Documentation helps trace the clinical story and is available to access should the need arise in the future. As a legal document the clinical note is a source of evidence intended to officially record events, decisions, interventions, and plans made during the OT-client relationship.
The College is not prescriptive in detailing the process for documentation and allows for flexibility among occupational therapists. For example, an occupational therapist could be provide a brief explanation in the initial clinical entry or there could be a reference to a guiding document, for example, a decision tree or organizational process.
Ultimately the College recognizes the balance between what is needed and what is reasonable given the circumstances.
Supervision
1. Can occupational therapy assistants (OTAs) be supervised virtually?
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Yes. In terms of supervising OTAs who are providing services through telepractice, the OT would follow the Standards for the Supervision for Occupational Therapist Assistants. Once the occupational therapist has determined that virtual can is an appropriate method of service delivery for the client, an occupational therapist will maintain accountability by taking the following steps:
Make an occupational therapy plan of care outlining the use of telepractice and assigning care to the OTA.
Ensure the OTA demonstrates competency to deliver occupational therapy services via telepractice.
Establish there is supervision and communication plan in place between the OT and OTA when services are delivered through telepractice (similar to if services were delivered in-person).
Follow the expectations as outlined in the Standards for Supervision of Occupational Therapist Assistants.
2. I am trying to decide if I should take a student during the pandemic. What are some of the things I need to consider before making this decision?
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As the regulator of occupational therapists in Ontario, our focus is on the safe, competent, and ethical practice of our registrants as this is one of the ways we achieve our mandate of public protection. The College is aware of the challenge faced by students and academic providers in finding suitable placements. We recognize that fieldwork is a requirement of graduation, and thus College registration. Our renewal information tells us that over 2000 therapists plan on taking a student this upcoming year, so this question is very topical to our registrant base.
We know many OTs may be wondering if providing a student placement during a pandemic is achievable. The Standards for the Supervision of Students clearly outline a preceptor’s responsibilities. None of these expectations have changed with the current pandemic, but some additional considerations for preceptors might include:
Safety
The safety of clients, therapists and students is always the highest priority. As such, the same general safety protocols you always applied to students should remain, plus any pandemic considerations. We would expect that preceptors educate and train their students on required safety protocols, and the students would adhere to these as well.
Preceptors and students are directed to the College’s COVID-19 webpage, the Ministry of Health, and employer-specific instructions to begin their orientation to safety and other pandemic expectations including: screening of self and client, proper hand hygiene, protective equipment, distance needs during sessions, decisions about virtual or in-person care, sanitization of tools and workspaces, and adapting services to accommodate risks are all valuable learning experiences. As a preceptor, your demonstration of clinical judgement during these difficult times is important for a student to experience and will help them to elevate their own decision-making skills when they enter practice.
Competency with Virtual Services and Virtual Supervision
For some hospital-based therapists, in-person services remain unchanged and the decision to have students onsite may be at the discretion of the organization. However, for therapists in the community, adapting to virtual service delivery does not take away from the competence you have in your area of practice. For those still getting comfortable with virtual service, this would not preclude a student from benefiting from the skills, knowledge, and judgement that you apply daily in your role.
Virtual service with a student and virtual precepting can take many forms, and always involves client consent. The Standards for the Supervision of Students states that this includes making sure the client or SDM has consented to the services and is clear what components of occupational therapy may be provided by the student.
Some examples may include having a student be present online during virtual sessions, or supervising a virtual session that your student is leading. Perhaps the student can observe the services you provide from a distance, or you can include the student in in-person sessions by computer or phone. While the student is listening or watching an in-person session, they can be note- taking, perhaps invited to ask questions if appropriate, and the two of you can debrief after about any follow-up or next steps that the student may be able to complete. If therapy volumes have reduced as clients decide to delay services until in-person resumes, perhaps the indirect client time needed of you as the preceptor could be filled by the student doing projects, building resources, or researching clinical areas of interest.
Of course, all of this precepting innovation will depend on the service area, the risks to all involved, and a review of organizational processes, but again the decision making around the options and possibilities may present great learning experiences. Supervising your student virtually, and/or with virtual services will require some thoughtful planning, adaptability, and regular communication. Involve the school early as well to ensure all risks and benefits are discussed and resolved.
Ethical Considerations
Consent is always paramount with any student/preceptor/client interaction. If consent to student involvement is a challenge in the COVID world, or if having a student present poses additional risks, our Code of Ethics, especially around transparency, autonomy, collaboration, and communication suggests preceptors develop student alternatives.
Further, the Standards for the Supervision of Students instruct the preceptor to “ensure that risks are managed to minimize any potential risk of harm to the client, the student, the supervisor and others in the provision of occupational therapy service.” In the current climate, this is where precepting might need to be creative. For example, if a student cannot experience or learn something directly, can this be simulated, or taught differently? Perhaps projects can fill in the knowledge or experience gaps? Being nimble and adaptable (aka practicing in a pandemic!) are great skills to advance for both practicing therapists and the students they supervise.
Controlled Acts
1. Can an occupational therapist perform a nasopharyngeal swab (NPS) to test for COVID-19?
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Yes, only if an occupational therapist receives appropriate delegation for this controlled act (#6 “putting an instrument, hand or finger: ii. beyond the point in the nasal passages where they normally narrow”) and has the training and competence to safely perform the activity. As this is not a common task for an occupational therapist, adequate training would include such things as procedure knowledge and proper techniques, required PPE, and a process for identifying and managing adverse events.
In every instance of delegation, the client’s best interest must be considered. We know that it is difficult to achieve an appropriate balance between client needs, competence and safety to perform the controlled act during this pandemic. Asking questions is a good start:
Is there a medical directive that defines the scope that may be assigned to OTs?
What are the processes in place that can expedite delegation? (order sets or directives)
Have roles and expectations been clarified in advance?
Has an individual(s) been identified with whom an OT can consult if questions arise?
Does a process for escalation of care exist?
What safeguards can be put in place to minimize risks to the clients and the OT?
With appropriate safeguards in place we would expect OTs to be flexible during situations of health emergencies to assist the health care system manage the increased demands. We do acknowledge that there may be individual exceptions to this and we encourage those OTs to be having discussions with their organizations to address these concerns. OTs should check with their organization regarding liability insurance for coverage of tasks that are not typically within the OT scope of practice.
Please see the Guide to Controlled Acts and Delegation for more details and includes a decision tree for receiving delegation and performing controlled acts.
Occupational Therapy & School Guidance 2022 - 2023
Occupational therapists should continue to work with employers, parents and guardians, school boards, and individual schools to determine the most appropriate process for service provision for the students. For information about the health and safety measures to support safe in-person learning for students and staff for the 2022-23 school year, please go to
COVID-19: health and safety measures at schools | ontario.ca. For current College guidance on COVID-19 measures for occupational therapists, view our
August 23 news posting.
Additional questions? Contact the Practice Resource Service by email:
[email protected] or phone
1.800.890.6570 or 416.214.1177 ext. 240.