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Am I Practising Occupational Therapy?

Am I Practising Occupational Therapy?


For over a decade Janice has been an occupational therapist working directly with individuals who have experienced spinal cord injury. Working closely with clients and their families has allowed Janice to gain insights into the complexity of health and the health system that supports individuals in need.   She has become deeply interested in how health systems operate. As a result of this deepening interest Janice has taken courses in population health, research methodology and project management to gain more knowledge and skills.

Recently Janice interviewed for a non-clinical position at an organization that coordinates health services. In this position Janice would collect and analyze data that informs the need for specific services, evaluates the use and effectiveness of programs, and makes recommendations for health funding.  While she may survey clients and their caregivers, there is no clinical aspect in this potential job.

Janice is excited about expanding her skills and is very interested in pursuing this position, should she be selected.  She has many questions about what this change would involve – including what this may mean for her status with the College.

The job title is not occupational therapist so how can Janice know if she is still practicing occupational therapy? 


Occupational therapy practice is diverse and not necessarily defined by role, job title, or practice setting. It is possible to be practicing occupational therapy without being employed as, or having the job title, “occupational therapist”. Often, people think of practicing occupational therapy within a clinical setting, however, a person can be practicing if they are using the knowledge, skill and judgement acquired through the profession in a role within the health care system. Regardless of whether working in a clinical or nonclinical position, it should be clear and transparently communicated that the person is an occupational therapist and therefore has accountabilities to the College.

Roles vary widely amongst occupational therapists and because of this range it is the responsibility of the individual to determine if they are practicing within the occupational therapy scope of practice. To help with this reasoning the College has developed some general reflective questions with a variety of examples to help guide decisions.

Janice reads through the questions below to see how they apply to her possible new situation.

Demonstrating Credibility and Accountability 

  • Are you telling the public that you are an occupational therapist?

    For example, do you use the title OT Reg (Ont.), as a way of demonstrating your credibility, accountability and knowledge to the public?
  • Based on your role, title, and how you present yourself, would the public expect you to use your occupational therapy knowledge or skill in your interactions with them?

    For example, an occupational therapist in the role of a program or clinic manager would be expected to use relevant knowledge, skill, and judgment in their day-to-day responsibilities and may regularly present themselves as a manager and occupational therapist to clients and colleagues.
  • Is being a regulated health professional a requirement of the role?

    For example, a case manager responsible for working with both clients and providers to coordinate health services.

If you answer yes to any of these questions, you are practicing occupational therapy and must register with the College.

Professional Knowledge and Experience  

  • Do you use occupational therapy skills, knowledge, judgement, and experience to make decisions in your role or apply occupational therapy theory, models and frameworks to your work and do these inform decision-making?

    For example, an occupational therapist who is a professor in an occupational therapy or health-related program will draw on their occupational therapy knowledge, skills and judgment when teaching students and supporting them to learn about their professional responsibilities.
  • Do you get client consent, assess function, plan programs or treatment and keep records pertaining to the people you are interacting with or trying to help?

    For example, an occupational therapist employed by a community college or university as an accommodation coordinator would be using their occupational therapy knowledge and experience when determining appropriate accommodations for students. They would perform an assessment, keep records, etc.

    Another example may be an OT that is providing life or executive coaching as part of preventative healthcare while using their occupational therapy knowledge and experience to improve client outcomes. 
  • Do people you work with seek your input or knowledge specifically as an occupational therapist? 
  • Do you collect, store, or use the personal health information of others and serve as a record agent or custodian? 
If you answered yes to any of these questions, you are likely practicing occupational therapy. 

Client and System Impact

  • Do you have an impact on client care?

    For example, overseeing the practice of other occupational therapists who provide client services; holding a leadership role, working in healthcare risk management or information technology; or working in collaboration with other healthcare professionals to support client services all have an impact on client care. 
  • Do you have an impact on systems that assist with, and promote, health or wellbeing?
  • Does your role impact policy, technology, resources, or knowledge that contribute to the healthcare system? For example, and occupational therapist who is planning, implementing, and evaluating provincial health services will have an impact at the system level.

If you answered yes to any of these questions, you are likely practicing occupational therapy.

After reflecting on the above questions, if you decide you are practicing occupational therapy, you must:

  • Uphold the College’s Standards of Practice, Code of Ethics and Competencies 
  • Complete your annual Quality Assurance requirements
  • Comply with the reporting requirements, including ensuring you update any changes to your personal or work information in your College profile.
  • Hold professional liability insurance that meets the requirement of the College’s bylaws. 
  • Declare your practice hours at annual renewal each year. 

If you decide you are not practicing occupational therapy, please consider the following:

  • You will not be able to use the hours obtained through this role toward the currency requirement
  • You may choose to resign your registration
  • You cannot use the title ‘occupational therapist’, or hold yourself out as someone who is an occupational therapist once you resign your registration

*Some of this content is adapted, with permission, from the College of Nurses of Ontario; the original work is available on


After reviewing the considerations above Janice determines that she would be practising occupational therapy within this nonclinical position for several main reasons:

  • While registration with a regulatory college is not mandatory for the position it is highly recommended and adds credibility and a depth of health-related knowledge to the role.
  • In this new role, Janice will rely on her base of knowledge about health conditions and the health system that was acquired during her clinical experience as an occupational therapist. 
  • The role has a direct impact on client services as the work can influence policy, funding, and quality improvement for health services. By developing, implementing, and evaluating the clinical programs Janice would be contributing to the healthcare system at large and ultimately for the clients in need of valuable health services. 


Occupational therapists have broad skills that can be applied to a variety of clinical and nonclinical roles within the health system.  

If you are still unsure whether you are practicing occupational therapy, contact our practice team at [email protected]

If you have questions about resigning or maintaining currency hours, please contact [email protected]



If you have any questions about this case, or have any ideas or requests for future cases, contact the Practice Resource Service: 1.800.890.6570/416.214.1177x240 or [email protected].

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