AOTA Clarifies OTD and OTA Mandates

Open letter to membership aims to outline initiatives

Below is the content of a letter from the American Occupational Therapy Association to its membership, authored earlier this month. The Association offers clarity on the mandates issued by ACOTE last year making the doctorate level of education the entry-level point into the occupational therapy profession.

Dear members,

Over the past several months, the Board and staff of AOTA® have reached out frequently to our membership concerning the OTD and OTA mandates. Despite overwhelming feedback from you that the OTD mandate could damage our profession, debate on this issue continues. ACOTE® has recently reaffirmed the OTD mandate, despite our formal request to put the OTD and OTA mandates in abeyance until we can conduct more research about the proposal’s potential negative impact on the profession and patients.

We face a serious, divisive situation at a time when the occupational therapy profession may be especially vulnerable. The issue of the educational mandates affects the entire profession, AOTA, ACOTE, and education programs. It is not about agreement or disagreement with the mandates; it is about a need to further explore critical external issues that could impact the success or failure of such mandates and that the governance process to determine entry level education was not appropriately followed. It is about finding the best path for the occupational therapy profession.

We are contacting you today to clarify several aspects of this issue to ensure that, together, we are concentrating on those areas that most affect your work and your ability to best serve clients. As you know, early this year, President Lamb released a video explaining that, as an organization, we felt that we had not adequately represented the wishes of the members on this issue, which is why we reopened discussions. The fact that we could have done better for you is not in dispute, which is why we hope that the following Q & A about AOTA, ACOTE, and our combined history about the issue will serve as an opportunity to move forward to truly determine the best path for occupational therapy.

How is AOTA governed?
AOTA’s mission is to advocate on behalf of its members and the profession. To pursue its mission, AOTA has a governance structure, articulated in our Bylaws, that charges the Board of Directors to ”govern the affairs of the Association with all duly vested statutory, corporate, and Bylaws powers.” Each member of the Board has a fiduciary duty to act in good faith and in a manner believed to be in the best interests of the Association. AOTA Bylaws also identify other groups that play a role in AOTA governance and work. These groups report to the Board.

As defined in our Bylaws, the Representative Assembly (RA) “shall be a designated body of the Board directly responsible for the establishment of professional standards and policies.” The history of the RA includes developing standards for ethics and practice, and for determining the entry level to the profession, as it did with Resolution J, which moved entry level for the occupational therapist to a postbaccalaureate degree.

What is ACOTE’s official relationship to AOTA?
ACOTE is identified in the AOTA Bylaws as an Associated Advisory Council of the Board. The AOTA Bylaws define ACOTE’s purpose as “to accredit occupational therapy education programs and occupational therapy assistant education programs. ACOTE establishes, approves, and administers educational standards to evaluate occupational therapy and occupational therapy assistant education programs, developing and implementing policies, rules, and procedures for conducting accreditation reviews and making accreditation decisions.” Thus, ACOTE’s charge specifically focuses on educational standards pertaining to the accreditation process. This charge does not extend to all education decisions, including entry level or standards that may relate to post-entry level education or continuing education.

The purpose of ACOTE as defined in the Bylaws is consistent with the requirements of the agencies (CHEA and the U.S. Department of Education) that approve accrediting groups like ACOTE. CHEA standards state that the accrediting group must “demonstrates independence from any parent entity, or sponsoring entity, for the conduct of accreditation activities and determination of accreditation status.” The U.S. Department of Education requires that ““The members of the agency’s decision-making body—who decide the accreditation or preaccreditation status of institutions or programs, establish the agency’s accreditation policies, or both—are not elected or selected by the board or chief executive officer of any related, associated, or affiliated trade association or membership organization” The CHEA and U.S. Department of Education requirements do not require that professional entry level or other educational standards be limited to the accrediting entity within a membership or trade organization.

What was the process for making the initial OTD mandate decision?
In August of 2017, ACOTE released its mandate to move the entry level of OT educational programs to the doctorate level. This action was not in compliance with the governance process of AOTA, requiring this type of decision to go to the Representative Assembly. Further, although ACOTE’s SOPs state that ACOTE will inform the Board of issues regarding accreditation, the Board was not informed that ACOTE was discussing action on the mandate until its public release. After ACOTE’s mandate release, the Board received differing perspectives on what actions or statements the Board could make in reference to this decision. The complexity of the situation required that the Board sort through many perspectives, ultimately resulting in an underinformed endorsement of the mandate.

Why did the AOTA Board reopen discussions?
The receipt of additional information from our legal counsel, as well as overwhelming requests from our membership, led to launching a series of national conversations about the entry level educational mandates in the spring of 2018. The outcome of these listening sessions and a member-wide survey indicated that more than 60% of members oppose moving to the single entry level at this time. Members also voiced deep concerns that the opportunity for robust profession-wide input had not been undertaken and a thorough review and discussion of the current education and practice environments had not been updated.

With our new legal counsel, a firm that specializes in associations and with leading experts in accreditation, certification, and association governance, the Board examined whether the process to move to the entry level mandates aligned with our governance processes. We found inconsistencies in the approach, and the decision by ACOTE circumvented the established governance process of having the Representative Assembly debate and act on establishing these important standards for the profession.

How is AOTA communicating the wishes of its members to ACOTE?
Throughout all of the conversations about the mandates, the AOTA Board sought to find a path forward that brings the profession together. We opened opportunities for members of the profession on all sides of the issue to share perspectives and voice their opinion. The Board also reached out to ACOTE to have a dialog on concerns related to the mandates. While the Board communicated with ACOTE on multiple occasions over the past 3 months in the spirit of open communication and collaboration, ACOTE demonstrated reluctance in having an open conversation about this issue or deficiencies in the process that brought us to this point.

What further action is AOTA taking on the mandate?
In July 2018 the AOTA Board of Directors passed a resolution that the OTD and OTA mandates be placed in abeyance so that further investigation of issues related to the mandates be completed and recommendations be forwarded to the Representative Assembly for consideration. The Board envisions that the Representative Assembly could address these issues in early 2020. This resolution was shared with the ACOTE Executive Committee on July 12th, 2018, and with the full ACOTE Council in a memo on July 17th, 2018.

This solution offers the ability for the occupational therapy profession to maintain choice for prospective students, academic programs, and the profession while we further investigate critical external issues, and to have this standard for the profession go through the established governance process in the Representative Assembly. Maintaining dual point of entry allows programs to make decisions that are best for their institutions and that they feel are in the best interests of the profession. The Board is charged with governing the overall affairs of AOTA in accordance with our Bylaws, and ACOTE is an Associated Council of the Board. Since the ACOTE decision to move forward with the entry level mandates circumvented AOTA governance, the Board has the right and responsibility to take this action through the appropriate processes. This does not conflict with the standards of CHEA or the U.S. Department of Education as it does not reflect the Board interfering with the stated functions of ACOTE.

Is AOTA’s relationship with its accrediting body unusual among professional organizations?
The relationship between AOTA (professional organization) and ACOTE (accrediting body) parallels the structure of many other professional organizations. AOTA–ACOTE is the entity recognized by the U.S. Department of Education and by CHEA. As previously noted, accrediting bodies must not be influenced by the “parent” organization in developing the accreditation standards, policies, and processes or in the review and decisions on specific programs or universities.

In 2005, a memorandum of understanding was created between AOTA and ACOTE to reflect the separation of decision making in accreditation and ensure that the necessary resources were allocated to ACOTE to undertake its charge as outlined in the Bylaws. This was an internal memorandum which was also cited in applications for recognition by CHEA and the U.S. Department of Education. We were recently informed by several legal advisers that this type of document is not best suited to clarifying the AOTA–ACOTE relationship or for demonstrating the separation of functions. Thus, AOTA is working toward defining the separation of functions, as required by CHEA and the U.S. Department of Education, into AOTA policies and procedures, which will be reviewed by AOTA and ACOTE on a regular basis and be available to members and relevant stakeholders. This is part of AOTA’s effort to provide members with access to policies and procedures and continue to be an even more transparent organization.

We are all a part of the occupational therapy profession. We hold the same passion for its strong future. The occupational therapy profession and AOTA should be bold and strategic in our efforts to move the profession forward.

We also must support our directions with thorough, balanced, and thoughtful analyses of the complex factors shaping professions and education, including views from external stakeholders. Therefore the AOTA Board is holding the educational mandates in abeyance while facilitating conversation among the profession to engage broad stakeholders in the discussion and inform the actions of the Representative Assembly.

The Board thanks you, our members, for your engagement in this process. We believe this is in the best interest of the profession as we come together around this issue to determine our path forward. The AOTA Board will continue to keep our members and key stakeholders informed as we clarify next steps on our path to the Representative Assembly.

The AOTA Board of Directors

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