Written Public Comment Submission Detail

Public Comment Details

Meeting
Commission Meeting - February 2022

Agenda Item
4A: Occupational Therapy and Physical Therapy Services Credential: Necessity and Feasibility Discussion

Name
Carla Sullivan

Organization
DMUSD

Comments
Dear Commissioners -

My name is Carla Sullivan and I am an Occupational Therapist working in the public school system for Del Mar Union School District. I am asking the commission to authorize a Clinical and Rehabilitative Services credential for OTs and PTs.

Personal Testimony
• The lack of a credential has impacted my experience within schools. I hold a Clinical Doctorate and Master’s of Occupational Therapy & Occupational Science however I am limited in my professional growth when working within an elementary public school system. Although highly qualified, I am unable to hold any position of leadership. I have a unique perspective that would provide valuable growth within a school district. In addition, there has been great confusion amongst administration on whether an OT is a certificated or classified employee. An example would be that I have been evaluated from both perspectives. In addition, administration often chooses to hold us to certificated standards at their convenience while holding us to classified standards to our detriment. This leads to great inequality for a profession that is highly educated and qualified.

Professional Inequity
• By excluding OTs and PTs from school-based credential opportunities, the CTC is allowing for significant professional inequity in school systems.
• With access to a credential, OTs and PTs can enhance the diversity of perspective and experience at all levels within school districts, ultimately providing added benefits to students, including those with disabilities.
Student Outcomes and Access to OT and PT
• Occupational therapists and physical therapists have expertise related to children with physical, intellectual, and developmental disabilities, and could contribute at all systems levels to benefit students and improve student outcomes.
Professional Training and Preparation
• OTs and PTs are licensed, hold Bachelors, Masters and Doctorate degrees, are highly qualified in their fields and already meet the requirements for a credential status.
• OT and PT academic and clinical training prepares therapists to work in a variety of settings, including the school setting, assessing contextual factors and needs in order to tailor interventions that meet individual and population needs.
• OTs and PTs have training in working with diverse populations, and focus on child/family centered practice in assessment and intervention strategies.
• OTs and PTs have ongoing continuing education requirements as part of licensure. Opportunities to expand knowledge related to school-based curricula can be made available as part of this requirement. As such, any additional coursework or curricular standards would not cause undue burden or place additional barriers on OTs and PTs seeking to work in school systems, nor would it have a negative impact on hiring or recruitment.
University Support

• Among accredited OT and PT programs in California, there is evidence of strong support for the Credential Initiative.
• Many universities with accredited OT and PT programs are amenable to adding needed continuing education and/or related coursework.

Practitioner Support

• OTAC-CPTA surveys (2015,2018,2021) of OT and PT practitioners have shown that a majority of school-based therapists support this initiative.

Eliminating Potential Barriers in Recruitment
• Increased opportunities for career growth within school districts will attract a high caliber of OT and PT practitioners to the field, and aid in retention of these highly qualified professionals.

Response to the CTC Summary of Survey
• The CTC survey/questionnaire to Local Education Agency (LEA) administrators had a 7% response rate (74/1037). The information is valuable as a pilot but needs further distribution and rewording to ensure essential data is captured.

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