Updated May 10, 2021

Latest updates: "COVID-19 Fully Vaccinated Individuals: Case, Contact and Outbreak Management Interim Guidance" document has been added to the "For Health Care Professionals" section.

As COVID-19 evolves, the provincial and federal government continue to update their resources.

We encourage you to regularly review the websites of the Ministry of Health and Public Health Ontario (PHO) for the most accurate, up-to-date information. Please see the links below.


As the government begins to roll out vaccinations across Ontario, health care professionals are being prioritized based on the important work they are doing. While vaccination is not mandatory, being protected from getting and transmitting COVID-19 is encouraged as this contributes to the safe and ethical care of your clients. Where applicable, we recommend all occupational therapists work with their employers to manage vaccination expectations.

Information on Identification for Health Professionals

Occupational therapists may be asked to provide identification or evidence of your registration as a health professional.

Registrants may wish to pull up their profile on the public register at Find an Occupational Therapist on their phone for proof of registration. Alternatively, occupational therapists can print their "Registration History" tab in advance (which includes their name, registration number, and registration expiry date), or print their renewal receipt from login.

Vaccine Documents


List of Public Health Units and Related Vaccine Information.

Ontario Ministry of Health Vaccine Resources
Public Health Ontario Vaccine Resources
Health Canada Vaccine Resources
Vaccine Education Resources

Occupational Therapy Practice Questions


Can occupational therapists administer the COVID-19 vaccine?

Administering a substance, such as a vaccine, by injection is a controlled act. Occupational therapists can only do this if they are delegated the task by another professional authorized to perform the act. Occupational therapists must be trained and have the knowledge, skills and judgement to administer the vaccine safely. Occupational therapists are expected to be competent to manage all aspects of the act, including management of potentially adverse reactions. Occupational therapists will obtain informed consent from clients. The roles and expectations for occupational therapists who are delegated the activity of administering vaccines should be outlined by the organization. An individual should be available and assigned that can provide consultation to the occupational therapist if questions or clinical concerns arise.

Importantly, occupational therapists need to understand that their professional liability insurance may not cover the completion of tasks that fall outside the scope of practice. They should check with their insurance provider and organization about liability insurance coverage for completing the controlled act of administering a vaccine.

Please see the Guide to Controlled Acts and Delegation for more details and includes a decision tree for receiving delegation and performing controlled acts.

Public Health Units

Central East
Durham Public Health Unit COVID-19 Vaccine Information
Haliburton, Kawartha, Pine Ridge District Health Unit COVID-19 Vaccine Information
Regional Municipality of Peel Health Department COVID-19 Vaccine Information
Peterborough Public Health COVID-19 Vaccine Information
Simcoe Muskoka District Health Unit COVID-19 Vaccine Information
York Region Community & Health Services Department COVID-19 Vaccine Information
Central West
Brant County Health Unit COVID-19 Vaccine Information
Haldimand-Norfolk Health Unit COVID-19 Vaccine Information
Halton Region Public Health COVID-19 Vaccine Information
City of Hamilton-Public Health Services & Safe Communities Department COVID-19 Vaccine Information
Niagara Region Public Health Department COVID-19 Vaccine Information
Region of Waterloo Public Health COVID-19 Vaccine Information
Wellington-Dufferin-Guelph (WDG) Public Health COVID-19 Vaccine Information
East
Eastern Ontario Health Unit COVID-19 Vaccine Information
Hastings Prince Edward Public Health COVID-19 Vaccine Information
Kingston, Frontenac And Lennox & Addington Public Health COVID-19 Vaccine Information
Leeds, Grenville and Lanark District Health Unit COVID-19 Vaccine Information
Ottawa Public Health COVID-19 Vaccine Information
Renfrew County & District health Unit COVID-19 Vaccine Information
North East
Algoma Public Health COVID-19 Vaccine Information
North Bay Parry Sound District Health Unit COVID-19 Vaccine Information
Porcupine Health Unit COVID-19 Vaccine Information
Public Health Sudbury & Districts COVID-19 Vaccine Information
Timiskaming Health Unit COVID-19 Vaccine Information
North West
Northwestern Health Unit COVID-19 Vaccine Information
Thunder Bay District Health Unit COVID-19 Vaccine Information
South West
Chatham-Kent Public Health Unit COVID-19 Vaccine Information
Grey Bruce Health Unit COVID-19 Vaccine Information
Huron Perth Public Health COVID-19 Vaccine Information
Lambton Public Health COVID-19 Vaccine Information
Middlesex-London Health Unit COVID-19 Vaccine Information
Southwestern Public Health COVID-19 Vaccine Information
Winsor-Essex County Health Unit COVID-19 Vaccine Information
Toronto
Toronto Public Health COVID-19 Vaccine Information

  • Ministry of Health dedicated website for the health workers and health employers. The site provides sector-specific guidance for the health sectors and health professionals including resources on COVID-19 symptoms, screening, and testing, signage for health care settings, mental health, and long-term care and retirement homes. As the Ministry of Health’s guidance documents are regularly updated, please access through the Ministry website to make sure you are viewing the most current version.

Long-Term Care Guidance Documents


Emergency Orders


Health sector organizations can call the Healthcare Provider Hotline for policy guidance related to COVID-19, urgent situations and information on Ministry programs: 1-866-212-2272 (toll free). Please be aware, the Hotline is unable to provide clinical advice regarding the management of cases.

Office of the Chief Medical Officer of Health and Minister’s Orders


Get the latest directives from the Chief Medical Officer of Health and Minister’s Orders on the Ministry website, including the following list of documents. Please access through the Ministry website to make sure you are viewing the most current version.

Public Health Ontario


Public Health Ontario also has a dedicated webpage for health workers and health employers, providing valuable Infection Prevention and Control resources, including recommendations on the appropriate level of personal protective equipment (PPE) to be worn by health workers

Government of Canada


The Government of Canada equally has a dedicated COVID-19 webpage for health workers, and has issued various resources to help health workers provide safe and effective service delivery during this pandemic, including:

Health Workforce Matching Portal (Formerly COVID-19 Health Care Provider Recruitment)


Ontario is seeking those with experience in providing health care to help provincial efforts to prevent and control the spread of COVID-19. 

The Ministry of Health is looking for: health care providers who may be working part-time and want to and are able to increase their work hours, former health care providers who are retired and are prepared to return to employment, or anyone who is inactive with their regulatory college or registered but not currently employed.

If you are interested, please register with Ontario’s Health Workforce Matching Portal: onhealthworkforcematching.ca

Resources


Information and Privacy Commissioner of Ontario



The information on this page is to help you understand what you can expect from your occupational therapist during the pandemic. How your occupational therapy services are delivered will be different. Occupational therapists must continue to meet their professional obligations and are still accountable for the decisions they make. This means that even though there will be changes to how you receive services, you should still receive safe and effective care.

Please contact our Practice Resource Service for any questions by phone at 1.800.890.6570 ext 240, or by email to practice@coto.org.

Frequently Asked Questions


Now that Ontario is reopening, can I see an occupational therapist?

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Since May 26, 2020, occupational therapists have been allowed to gradually resume regular health care services. Before resuming in-person services, occupational therapists must first put in place measures to protect themselves, clients, staff, and colleagues, from contracting and spreading the virus. Both the Ministry of Health and the College are recommending that where possible, occupational therapists provide services remotely as it is the best way to reduce the risk of spreading the virus. If the occupational therapist can safely and effectively provide the service you require virtually (online, by telephone, or other virtual means), they should do so, provided you consent to it.


I’ve heard people use different terms about receiving medical services, what’s the difference between remote service, online or virtual care, and telepractice?

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These terms mean the same thing and refer to services provided where you and your occupational therapist are not in the same physical location. During the COVID-19 pandemic, providing services remotely allows your occupational therapist to address some of your health care needs without having to meet you in-person, which could expose them, you, and others to the virus.

Remote service uses information and communication technologies, such as telephone, email, apps, and other online platforms, to allow you and your occupational therapist to share information or “meet” virtually. Talk to your occupational therapist if you do not know how to use the technology suggested, as they can help guide you. You can still choose to have family or other caregivers be a part of the discussions about your care where remote service is being used.


I’ve never received care online or over the phone. What can I expect? How will I give consent?

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Consent can be provided in different ways. Written consent is not required for remote or in-person services, although your occupational therapist may still decide to request it. You can also provide consent orally. What is important is your understanding, so you can make an informed choice about whether you wish to proceed with the service, and whether you consent to receiving it remotely. Your occupational therapist should explain what the service being provided will involve, the benefits of delivering the service remotely, and any limitations in providing the service this way. Many health needs may be met with virtual visits but some may not. For example, it may be hard to assess how you get around and the devices that help you walk. In these circumstances we expect occupational therapist to use their clinical judgment and make the best decision for your care. You need to understand how the remote service will be organized, and know what to expect regarding the time and duration of it.

In addition to obtaining your consent to having the service delivered remotely, your occupational therapist must also clearly outline the nature, benefits, risks, limitations, and potential outcomes of the occupational therapy service itself. This information should be provided to you regardless of whether the service is an assessment, treatment or consultation. You should be advised of the fee for the service, your right to stop participating at any time, and how you can access your health information that is collected and used as part of the remote service delivery. Your occupational therapist should give you an opportunity to ask questions and hear about possible alternatives.


How will my occupational therapist provide a safe environment when I’m receiving in-person services?

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Your occupational therapist will follow strict infection prevention and control measures to keep you safe. Before every interaction with you, your occupational therapist will:

clean and disinfect all shared equipment and any surfaces touched by another client wash their hands with warm soapy water or use a Health Canada approved hand-sanitizer assess the level of required personal protective equipment (PPE). Examples of PPE include masks, goggles, gowns, and gloves.

If your occupational therapist determines that in-person services are required, you will:

be screened prior to your appointment and again when you arrive to determine if you have any COVID-19 symptoms or risk factors be asked to wear a mask to the appointment, if you can tolerate wearing one be required to wash your hands or use an alcohol-based hand sanitizer on arrival and immediately before your departure. If the occupational therapist is providing service in your home, they will wash or sanitize their hands on arrival and immediately before their departure be asked to arrive as close to your appointment time as possible or asked to wait outside until your occupational therapist is ready to see you

For more information about the types of measures your occupational therapist will take to protect your safety, see the guidance we prepared to help occupational therapists safely resume in-person services. This guidance brings together the requirements and recommendations of the Ministry of Health and Public Health Ontario.


What is the difference between medical and non-medical masks?

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Non-medical masks may not be effective in blocking virus particles that may be transmitted by coughing, sneezing or certain medical procedures. They do not provide complete protection from virus particles because of a potential loose fit and the materials used.

To learn more about how to wear a non-medical mask or face covering you can watch this video from the Government of Canada or review Public Health Ontario’s fact sheet which provides tips on when to wear a non-medical mask and which type to wear.


I am concerned about delays. How will my occupational therapist manage any backlog?

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Your occupational therapist should prioritize client care using fair and clear processes. When deciding which clients will receive service first, your occupational therapist should:

consider their capacity to offer services prioritize clients who will suffer the most harm if service is delayed too long treat clients with the same clinical needs in the same way unless relevant differences exist pay special attention to actions that might further disadvantage already disadvantaged or vulnerable clients continue to monitor the health care status of all their clients so any clients who do not appear to need immediate service will receive the care they need it their health care status changes


My occupational therapist isn’t providing in-person services. Why?

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Your occupational therapist needs to consider the risks to you and to themselves and to the public at large. Your occupational therapist is best placed to evaluate whether the benefits of providing in-person services outweigh the risks associated with contracting and spreading the virus. While your wishes will be taken into consideration, your occupational therapist must also consider many other factors when making this decision including:

whether the area where the service is to take place is a COVID-19 affected area, if you have any underlying health conditions that place you at a higher risk were you to contract the virus, if you have signs and symptoms of the virus, if a physical distance of 2 metres can be maintained throughout the service delivery, and if appropriate levels of personal protective equipment are available to proceed with in-person services.

If your occupational therapist is recommending remote service delivery and you have questions , you should have a discussion to better understand the reasons for their decision and to see if there are other options available to you.


Mental Health Resources


Other Resources



[Updated April 23, 2021]


Latest Guidance: New Provincial Orders: Change to Scope of Practice in Hospitals (April 23, 2021)

Past Information and Guidance:

As a reminder, virtual services are recommended when appropriate. If in-person services are required, occupational therapists need to wear proper personal protective equipment (PPE) at all times. Continued adherence with all public health measures, including handwashing, masking and physical distancing, is expected when at work and in the community.

If you have any questions, please contact our Practice team at practice@coto.org or 1-800-890-6570 ext 240.  

You can also visit our COVID-19 web page for additional resources and information or contact your local public health unit for specific details about COVID-19 management in your community. Please continue to check the Ministry of Health website for the most current COVID-19 guidance and information. You can learn more about the shutdown on the Ontario government website.

We thank all registrants for their continued commitment to the delivery of safe, ethical occupational therapy services. Your professionalism and dedication are appreciated.



As the government is allowing deferred, non-essential and elective health services to resume, practices that reopen must:

  • implement the operational requirements outlined by the government;
  • follow the College's guidance on return to work and infection control practices;
  • have access to personal protective equipment.
The updates to the Return to Work Guidance for Occupational Therapists reflect the changes made to the Ministry of Health’s COVID-19 Operational Requirements: Health Sector Restart to ensure alignment with the government’s recommendations as this pandemic evolves. The key changes address how visitors to the occupational therapist’s place of employment are to be managed, including active and passive screening measures affecting visitors, what the occupational therapist should do if they have returned from travel in the past 14 days, as well as additional infection and prevention control recommendations when preparing your place of employment for in-person service delivery.

Occupational therapists may wish to review the following suggested resources:

The College is working with government to respond to the global pandemic in the best interest of the public. Directives from the Ministry of Health and the Premier’s office are reflected in College positions.

If you have further questions about this, contact our practice line at 1.800.890.6570 ext. 240, or practice@coto.org. The College is committed to providing information and clarification and the best possible service during this difficult time.



[Posted June 11, 2020] Video: Conversations with the College
Gradual Reopening: COVID-19 & Occupational Therapy 


What does the Ontario government’s announcement about resuming healthcare services mean for occupational therapists?

What services should be delivered in person at this time? What are some important considerations for OTs offering remote services?

As the province gradually reopens, we know that occupational therapists have a lot of questions about how to resume practice safely and responsibly during the pandemic. The College has developed another video resource to help answer some of these questions and guide you as the province restarts deferred, non-essential and elective healthcare services.



You can also download the presentation. It includes links to helpful resources and information, including the College's Return to Work Guidance.

For more webinars and videos, please visit the College YouTube channel.

If you have questions, contact our practice line at 1.800.890.6570 ext. 240, or practice@coto.org. Our Practice Team is receiving a high volume of calls and emails during this pandemic and we appreciate your patience.


Vaccination


1. Can occupational therapists administer the COVID-19 vaccine?

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Administering a substance, such as a vaccine, by injection is a controlled act. Occupational therapists can only do this if they are delegated the task by another professional authorized to perform the act. Occupational therapists must be trained and have the knowledge, skills and judgement to administer the vaccine safely. Occupational therapists are expected to be competent to manage all aspects of the act, including management of potentially adverse reactions. Occupational therapists will obtain informed consent from clients. The roles and expectations for occupational therapists who are delegated the activity of administering vaccines should be outlined by the organization. An individual should be available and assigned that can provide consultation to the occupational therapist if questions or clinical concerns arise.

Importantly, occupational therapists need to understand that their professional liability insurance may not cover the completion of tasks that fall outside the scope of practice. They should check with their insurance provider and organization about liability insurance coverage for completing the controlled act of administering a vaccine.

Please see the Guide to Controlled Acts and Delegation for more details and includes a decision tree for receiving delegation and performing controlled acts.


2. In my work as an occupational therapist, I often get asked by clients if I have been vaccinated. Should I tell clients if I have received the COVID-19 vaccination or not?

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COVID-19 vaccination is an important topic of conversation in health care settings and it may come up naturally as part of discussions with clients and their families. Occupational therapists work with clients who are often part of vulnerable groups and as a result they may have added worry about the potential transmission of the virus.

First, we suggest that you talk with clients and get a sense of what may be underlying the question. While health information is private, you may choose to tell clients if you have, or have not, been vaccinated. We know vaccination is an important defence against virus transmission, however, public health measures also reduce the likelihood of transmission. Discussing those precautions as they relate to occupational therapy service can help to alleviate some worry. If you do not want to share your vaccination status, a reply like “I am not comfortable disclosing my personal health information, but let’s talk about safety and the measures in place to protect you and I during these times…” can address underlying concerns or curiosity. We are often reminded of how intuitive and respectful occupational therapists are when answering potentially sensitive questions and we trust the same good judgement prevails in questions about vaccination.

Lastly, you may want to check with your organization to see what their expectations are about navigating these conversations with clients and their families.


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


2. 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 registration@coto.org 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 telepractice (remote service) to a client who has moved to another province?

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Yes. However, the jurisdiction for the provision of occupational therapy services is defined by the location where the client resides - even if they reside there temporarily.

An occupational therapist wanting to provide remote out-of-province service will:

1) Determine if the service can be safely and effectively provided remotely (online, by telephone, or other virtual means).
2) If yes, contact the regulatory College in the province of the client to request temporary registration. Most provinces are waiving fees and expediting the process.
3) Upon receipt of temporary registration, and consent from the client, an OT can begin the clinical process of providing the service virtually.


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 (May 26, 2020):

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. Do I need to wear a mask while providing occupational therapy services? What type of mask should be worn?

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Yes. Occupational therapists should follow the recommendations of the government and public health organizations for use of masks. At a minimum, occupational therapists should wear a surgical/procedural mask when providing in-person services with or within 2 metres of clients. These types of masks are made using multiple layers creating a barrier to prevent droplets from an infected source form contaminating the skin and mucous membranes of the nose and mouth of the wearer, or to trap droplets expelled by the wearer, depending on the intended use. If your personal protective equipment supplies allow, the mask should be changed after each client interaction and must be changed whenever it is damp, humid, damaged, or soiled. Occupational therapists must wash their hands before and after touching, adjusting, putting on, or removing their mask.


5. 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.


6. 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 therapists are reminded to follow infection prevention best practices (see the College Standards for Infection Prevention and Control) and that orders, directives and guidance from the Ministry of Health and CMOH overrule the information on this webpage. The information provided is not intended to take the place of legal advice.

If you have any questions, please contact our Practice Resource Service for any questions by phone at 1.800.890.6570 ext 240, or by email to practice@coto.org.

The College will continue to update this web page. Please be sure to check the Ministry’s COVID-19 website, the Ministry website for healthcare providers, and Public Health Ontario