How Closely Does an OT Have to Supervise a COTA? The Rules in All 50 States and DC

It depends on your state, and the most common answer is about once a month. 34 of the 51 jurisdictions set a minimum: in 25 of them the floor for an experienced COTA works out to roughly monthly, four ask for more (California and Georgia weekly, New Jersey and Utah every two weeks), and five use another measure, such as a share of work time or a visit count. The other 17 leave the frequency to the supervising OT. Beyond how often, states differ on whether the contact has to be in person, whether new COTAs get more of it, how many COTAs one OT may supervise, and what you have to write down.

This one is my own profession: I'm an occupational therapist. In home health the COTA usually works alone in the patient's home, which is why the details of these rules matter. For this article I read the OT practice act and the board's rules in every state and DC, and I quote the rule for each one with a link to the official copy.

This isn't legal advice. I checked every rule on November 9, 2026, on the state's own legislature, code or board site. Your board's current rule is the one that counts.

A note on words. COTA is NBCOT's credential; most states license an occupational therapy assistant (OTA). I use COTA and OTA for the same person. Supervising OT means the occupational therapist responsible for the COTA's work.

The Short Answer

• 34 of the 51 jurisdictions set a minimum; 17 don't. The 17 without a fixed interval leave it to the OT, often in a written supervision plan: Colorado, Connecticut, Delaware, Florida, Hawaii, Indiana, Maine, Massachusetts, Mississippi, Missouri, Montana, New Mexico, New York, North Dakota, Oklahoma, Rhode Island and Texas.
• Monthly is the usual floor. In 25 states the minimum for an experienced COTA is about once a month or every 30 days. Five of them also count visits or treatment days and take whichever comes first: Maryland, Minnesota, South Carolina, Virginia and Wisconsin.
• Four states ask for more than monthly from everyone: California and Georgia weekly, New Jersey every two weeks, Utah every two weeks plus a monthly in-person meeting.
• Eight states measure it in hours or a share of work time: Arkansas, Illinois, Kentucky, Nebraska, Nevada, New Hampshire, Pennsylvania and South Dakota. Iowa counts visits: the OT treats every 12th visit. DC and Wyoming use bimonthly without defining it.
• 13 states step it up for newer COTAs, from Alabama (OT in the immediate area for the first 12 months) to Ohio (weekly in the first year).
• 14 states cap the number of COTAs per OT, from New Hampshire (two full-time) to New Jersey and New York (five).
• Paperwork varies. Six states name a supervision log, nine require a written supervision plan, and nine require the OT to co-sign some or all of the COTA's notes. Six say a co-signature alone isn't supervision.
• Only West Virginia's board has written about home health directly, among all the rules and board statements I read. Everywhere else, home health follows the general rule.
• Medicare adds its own layer. In home health the OT must see and reassess the patient at least every 30 days. In Part B private practice, general supervision of COTAs has been allowed since January 1, 2025. Where the state rule is stricter, it wins.

Every State at a Glance

How to read it. No set frequency means the act and rules require supervision but don't set a minimum interval; the cited rule is the one that governs, and the OT decides how often. None stated means the rules have nothing on that point. Words in quotation marks are the rule's own words. Each link goes to the official copy I read, and the type of source is in parentheses after it.

The States That Use Supervision Levels

About a third of the states use named levels, usually close, routine and general, and some add direct, continuous or minimal. The names repeat from state to state, but the definitions don't. General supervision means monthly face-to-face contact in Alabama, every two weeks in New Jersey, and an undefined term in Montana. Here are the definitions in the rules' own words.

Alabama

Alabama has the strictest first year of any state I read: a COTA with less than a year of experience works with the OT in the immediate area. The definitions and the schedule are in Ala. Admin. Code r. 625-X-8-.01 (opens in a new tab):

(a) Direct Supervision: the supervising occupational therapist is in the immediate area of the occupational therapy assistant while performing supportive services. (b) Close Supervision: the supervising occupational therapist provides initial direction to the occupational therapy assistant and daily contact while on the premises. (c) General Supervision: the supervising occupational therapist has face-to-face contact with the occupational therapy assistant at least once every 30-calendar days, with the supervising occupational therapist available by telephone, electronic, or written communication.

(a) Supervision should be "Direct" if the occupational therapy assistant has less than 12-months work experience. (b) Supervision should be "Close" if the occupational therapy assistant has more than 12 months but less than 24 months of experience.

After 24 months it is at least general. COTAs employed by state agencies and public schools for educational needs start at general instead. And the OT "must assign an increased level of supervision if the occupational therapy assistant is new to a practice setting or particular skill" (r. 625-X-8-.01(7)(e) (opens in a new tab)).

Arizona

Arizona's levels count contact per patient and on the premises. From A.A.C. R4-43-101(11) (opens in a new tab):

“General supervision” means the supervising occupational therapist has face-to-face contact with the occupational therapy assistant at least once every 30-calendar days on a per patient or client basis while on the premises, with the supervising occupational therapist available by telephone or by written communication. d. “Minimal supervision” means the supervising occupational therapist has face-to-face contact with the occupational therapy assistant at least once every 30-calendar days while on the premises. e. “Routine supervision” means the supervising occupational therapist has face-to-face contact with the occupational therapy assistant at least once every 15-calendar days on a per patient or client basis while on the premises

The level depends on experience in "a particular practice setting or with a particular skill." A COTA needs not less than general supervision "if the occupational therapy assistant has more than 12 months but less than 24 months of experience," and not less than minimal after 24 months (R4-43-401(C) (opens in a new tab)). Under 12 months it is routine. The Secretary of State's compilation of these rules was last supplemented in 2000.

New Jersey

New Jersey asks the most of any state when it comes to seeing an experienced COTA at work: face-to-face observation at the place the COTA works, at least every two weeks. From N.J.A.C. 13:44K-1.2 (opens in a new tab):

"Close supervision" means daily, face-to-face contact with and frequent observation of the performance of the individual at the location where he or she is rendering services; 2. "Routine supervision" means face-to-face contact with and observation of the performance of the individual at least once a week at the location where he or she is rendering services; and 3. "General supervision" means face-to-face contact with and observation of the performance of the individual at least once every two weeks at the location where he or she is rendering services.

And from N.J.A.C. 13:44K-6.3(b) (opens in a new tab), the supervisor "shall provide close supervision for any occupational therapy assistant who has been engaged in the practice of occupational therapy services for less than one year on a full-time basis," which the rule counts as 1,200 hours. The Division's own copy of the chapter now returns an error, so I read and link the archived copy of that same PDF.

Oregon

Oregon allows telehealth for routine and general supervision, and makes general the floor. From OAR 339-010-0005(1) (opens in a new tab):

(a) "Close supervision" requires daily, direct contact in person at the work site; (b) "Routine supervision" requires the supervisor to have direct contact in person at least every two weeks at the work site or via telehealth as defined in OAR 339-010-0006(9) with interim supervision occurring by other methods, such as telephone or written communication; (c) "General supervision" requires the supervisor to have at least monthly direct contact in person with the supervisee at the work site or via telehealth as defined in OAR 339-010-0006(9) with supervision available as needed by other methods.

And OAR 339-010-0035(3) (opens in a new tab): "An occupational therapy assistant always requires at least general supervision."

Tennessee, Vermont and Wyoming

These three tie the level to the COTA's stage, in nearly the same words. Vermont makes the ladder mandatory (Vt. OT Administrative Rules 3.7 (opens in a new tab)):

"Close supervision" means daily, direct, face-to-face contact at the site of work

(1) Entry level occupational therapy assistants are persons working on initial skill development (less than 1 year of work experience) or who are entering new practice environments or developing new skills (one or more years of experience) and shall require close supervision.

Intermediate COTAs (one to three years) need routine supervision, "direct face-to-face contact at least every two weeks at the site of the work," and advanced COTAs need general supervision, "at least monthly direct face-to-face contact" (Rule 3.7 (opens in a new tab)). Vermont's rules as posted are dated June 1, 2004.

Tennessee uses the same ladder but as a recommendation. Its rule says supervision "is recommended as follows" and that entry-level COTAs "should require close supervision," with close meaning "Daily direct contact at the site of treatment" and general meaning "At least monthly direct contact with supervision available as needed by other methods" (Tenn. Comp. R. & Regs. 1150-02-.01(29), 1150-02-.10(6) (opens in a new tab)).

Wyoming keeps the ladder and adds video. From Wyo. OT Board Rules ch. 3, § 3(b) (opens in a new tab):

(i) An entry-level OTA is an individual working on initial skill development or entering a new practice area. At this level the OT shall provide close supervision, including weekly meetings and oversight, which could take place in person or virtually with a video and audio component.

Intermediate COTAs get bi-weekly meetings and advanced COTAs bimonthly ones. The rules don't say whether bimonthly means twice a month or every two months, and neither does DC's rule, which uses the same word. There is also a loose end between Wyoming's chapters: chapter 1 defines close supervision as "weekly, direct contact at the site of work" and routine supervision as "direct contact at least every two weeks at the site of work" (Wyo. OT Board Rules ch. 1, § 2 (opens in a new tab)), while chapter 3 says the same meetings could take place virtually. If you rely on video in Wyoming, I'd ask the board how it reads the two together.

West Virginia

West Virginia sets two steps and ties general supervision to co-signatures. From 13 CSR 1 § 12.4 (opens in a new tab): for a COTA with less than a year's experience, general supervision "with direct contact at least every two weeks at the site of work and supervision available as needed by telephonic, electronic, or written communication." For a COTA with "increased skill development and mastery of basic role functions," it is "general supervision with monthly direct contact and supervision available as needed by telephonic, electronic, or written communication." And: "General Supervision is demonstrated through co-signatures on all paperwork or electronic notes pertaining to the practice of occupational therapy for the person requiring general supervision."

New COTAs: What Changes in the First Year

Thirteen states give newer COTAs more supervision. The thresholds differ:

• By years of experience: Alabama (under 12 months direct, 12 to 24 months close), Nebraska (8 on-site hours a month under a year, 4 after), New Jersey (close for the first 1,200 hours), Ohio (weekly in the first year), Vermont and Tennessee (close, routine, then general at one and three years), West Virginia (every two weeks in the first year), and New Hampshire (three tiers, at one and five years).
• By experience in the setting or skill: Arizona, Illinois and South Dakota count experience in the current setting or area of practice. Wyoming's entry level includes anyone "entering a new practice area" (ch. 3, § 3(b) (opens in a new tab)), and Vermont's includes those "entering new practice environments" (Rule 3.7 (opens in a new tab)). Wisconsin requires close supervision for an entry-level COTA in "rehabilitation, neonate, early intervention, and school system services" (OT 4.04(5) (opens in a new tab)).

This matters when an experienced COTA moves into home health from a skilled nursing facility or a school. In Arizona, Illinois, South Dakota, Vermont and Wyoming, the rules can treat that COTA as new again, and Alabama requires more supervision for a COTA new to a setting or skill.

In Person, by Phone or by Video

This is where states split most, and where home health feels it.

• In person or on site, on a schedule, whatever the COTA's experience (9): Arizona, Arkansas, Illinois, Kansas, Kentucky, Nebraska, New Jersey, Pennsylvania and Utah. Kentucky defines face-to-face supervision as "being physically present in the room and being able to directly communicate with an individual while observing and guiding the activities of that individual" (201 KAR 28:130 (opens in a new tab)).
• In person for newer COTAs: Alabama for the first 24 months, West Virginia for the first year, Vermont for the first three years, and Tennessee's recommended close and routine levels.
• In person, with no schedule: Georgia (its rule says "in person supervision" but sets no interval for it, under 671-2-.02 (opens in a new tab)), Oklahoma (general supervision "requires direct in-person contact" under 435:30-1-2 (opens in a new tab)) and Rhode Island (in person to start, then periodic on-site supervision).
• Face-to-face, but undefined: Alabama's general level, Maryland, Wisconsin's client contact and Vermont's general level say face-to-face without saying whether video counts. Ask your board before you rely on video there.
• Video or telecommunication allowed, at least in part: Alaska (when in person isn't practicable), California, Georgia (for the weekly contact), Idaho, Iowa, Louisiana, Michigan, Minnesota, Nevada, New Hampshire, North Carolina, Oregon, South Dakota, Utah (for the two-week contact) and Wyoming. Minnesota's statute says face-to-face supervision "includes real-time audio and video communication where the supervisor and supervisee can see each other and clearly visualize the services being provided" (Minn. Stat. § 148.6402, subd. 12a (opens in a new tab)).

Home Health and Other Off-Site Work

Of all the rules and board statements I read, only one speaks to home health directly. West Virginia's position statement says (WV Board of Occupational Therapy, Supervision of (C)OTA in Early Intervention and Home Health Settings, April 23, 2021 (opens in a new tab)):

HOME HEALTH: The OT(R) is responsible for the evaluation of the patient. The OT(R) must have direct contact with the patient before any changes in the treatment plan can be made. The OT(R) must have direct contact with the patient to re-evaluate if there is a significant improvement or significant decline in the patient’s condition prior to the (C)OTA resuming treatment with the patient.

That is a board statement, not a rule; it explains how the board reads 13 CSR 1 § 12.2.a, which requires a face-to-face OT visit at evaluation and before any change in the plan.

Three other things in the rules land hard in home health:

• The site. New Jersey says "at the location where he or she is rendering services" (13:44K-1.2 (opens in a new tab)). Vermont says "at the site of work" (Rule 3.7 (opens in a new tab)), Oregon "at the work site" (OAR 339-010-0005 (opens in a new tab)), Tennessee "at the site of treatment" (1150-02-.01(29) (opens in a new tab)) and Arizona "while on the premises" (R4-43-101(11) (opens in a new tab)). Kansas, Nebraska and Pennsylvania say on site. None of them says what the site is when it's a patient's living room. A joint visit in the home meets the plain words. Whether a meeting at the agency office does is a question for your board.
• The patient, not just the COTA. Some states require the OT to see or review every patient. Arkansas has the OT meet "with each patient and the occupational therapy assistant" monthly (17 CAR § 140-401(3) (opens in a new tab)), Iowa has the OT treat every 12th visit, Wisconsin requires face-to-face contact with the client by every 10th session, and Utah requires the OT to "meet with each client who has been referred to the occupational therapy assistant at least once each month" (Utah Code § 58-42a-306(4) (opens in a new tab)). Maryland, Minnesota, South Carolina and Virginia count per client too. In home health these work like supervisory visits.
• Distance. DC requires the OT to "be able to be on-site within two (2) hours if a need arises" (17 DCMR § 7314.1 (opens in a new tab)). With a spread-out caseload, that is a scheduling rule as much as a supervision rule.

If you schedule therapy, the practical move is to treat the strictest of these as a recurring visit on the calendar, the way agencies already treat the Medicare 30-day reassessment. Our guide to supervisory visits in home health covers the federal side.

How Many COTAs One OT Can Supervise

Fourteen states set a number:

• Two full-time: New Hampshire, "those whose combined work hours total the work hours of 2 full-time occupational therapy assistants" (Occ 405.08 (opens in a new tab)).
• Three: Alabama, Alaska (counting aides and students), California (the board may allow more), Kentucky, North Dakota and Virginia (and no more than six personnel in all).
• Four: Kansas (four full-time equivalents, eight people at most), Michigan (four at the same time), Missouri and Oklahoma.
• Five: New Jersey (seven people in all, counting students) and New York (ten people at most).
• New OTs only: New Mexico limits an OT to "three or fewer occupational therapy assistants during their first year of licensure as an occupational therapist" (16.15.3.8 NMAC (opens in a new tab)).

Colorado, Louisiana and Massachusetts say in their rules that the number is the OT's judgment. The rest are silent.

Logs, Plans and Co-Signatures

The rules ask for three different kinds of paper, and they are easy to mix up.

• A supervision log. Arkansas, Illinois, Kentucky, Nevada, North Carolina and Vermont name a log. Arkansas and Illinois require both of you to sign every entry. Michigan requires a record of each monthly meeting signed by both. Kentucky's log must show "The number of hours worked by the OTA/L each month," so the hours can be checked against the four-hour floor (201 KAR 28:130 (opens in a new tab)).
• A written supervision plan. Delaware, New Jersey, New Mexico, New York, North Dakota, Pennsylvania, Tennessee, Vermont and Wyoming require one. New York's must specify "the frequency of formal supervisory contacts," the methods, and "whether such notes and reports will be initialed or co-signed by the supervisor" (8 NYCRR § 76.8 (opens in a new tab)).
• Co-signatures. Alaska, Indiana, Kentucky, Maryland, South Carolina, Utah, Virginia and West Virginia require the OT to co-sign some or all of the COTA's notes, and Wisconsin does under close supervision. Six states say a co-signature isn't supervision on its own: Delaware, Illinois, Missouri, North Carolina, Ohio and Oklahoma. Illinois puts it in four words: "Co-signature does not reflect supervision" (68 Ill. Adm. Code 1315.163 (opens in a new tab)). Louisiana and Massachusetts say COTA notes don't need one.

Several states also want the supervising OT on file with the board: Maine, New Hampshire, New Mexico, North Carolina, North Dakota, Oklahoma and Oregon among them. Change jobs or supervisors, and the form changes too.

Texas went the other way. Since June 1, 2019, its board says COTAs with a regular license "are no longer required to receive supervision hours or maintain a supervision log" (Texas Board of OT Examiners (opens in a new tab)). What remains is the note rule: in each intervention note, the COTA "must include the name of an occupational therapist who is readily available to answer questions about the client's intervention at the time of the provision of services" (22 TAC § 372.1(g)(3) (opens in a new tab)).

Medicare: Home Health and Part B

Medicare doesn't set a supervision schedule for COTAs. It sets who counts as an OTA, who supervises, and how often the OT has to see the patient. Keep it separate from the state rule: you need both.

Who counts. An OTA under Medicare's home health rules is a person who "Is licensed or otherwise regulated, if applicable, as an occupational therapy assistant by the state in which practicing" and who graduated from an ACOTE-accredited OTA program and is eligible for or has passed the NBCOT exam (42 CFR 484.115(g) (opens in a new tab)). The agency's conditions of participation add that "Rehabilitative therapy services are provided under the supervision of an occupational therapist or physical therapist" (42 CFR 484.75(c)(2) (opens in a new tab)).

The 30-day rule. For home health therapy to be covered (42 CFR 409.44(c)(2)(i)(B) (opens in a new tab)):

At least every 30 calendar days a qualified therapist (instead of an assistant) must provide the needed therapy service and functionally reassess the patient in accordance with § 409.44(c)(2)(i)(A).

If it's missed, "therapy visits for the therapy discipline(s) not in compliance with these policies will not be covered" until the OT completes the reassessment (42 CFR 409.44(c)(2)(i)(C) (opens in a new tab)). The 30-day therapy reassessment rule walks through the counting. And a COTA visit is a visit under the OT order, not one of its own; which order an assistant works under explains why.

The 30-day visit is about the patient. It doesn't replace your state's supervision of the COTA, though one visit can do both jobs if it meets both rules. Watch the states that count visits: at three COTA visits a week, Maryland's and Virginia's tenth visit, Wisconsin's tenth session and Iowa's twelfth visit can all come before day 30.

Part B private practice. Since January 1, 2025, an OT in private practice can supervise a COTA generally rather than directly. The current rule reads (42 CFR 410.59(c)(2) (opens in a new tab)):

Occupational therapy services may be performed by an occupational therapy assistant under the general supervision of the occupational therapist in private practice; services performed by an unenrolled occupational therapist must be under the direct supervision of the occupational therapist.

The change came in the CY 2025 physician fee schedule final rule. CMS wrote that "we are finalizing as proposed the revisions to" §§ 410.59 and 410.60 to allow general supervision, and, on states with stricter rules: "For the States with more restrictive supervision levels, such as direct supervision, Medicare-covered therapy services provided in those States are required to be furnished in compliance with State law" (89 FR 97710, December 9, 2024 (opens in a new tab)).

One trap: CMS's Benefit Policy Manual hasn't caught up. Chapter 15, § 230.2, last revised in 2014, still says "General supervision is required for OTAs in all settings except private practice (which requires direct supervision) unless state practice requirements are more stringent, in which case state or local requirements must be followed" (Medicare Benefit Policy Manual, ch. 15 (opens in a new tab)). The regulation controls the private practice part. The last part of that sentence is still right, and it is the rule for this whole article.

The stricter rule wins. Medicare sets a floor for coverage. Your state sets a floor for your license. Your agency's policy may set a third. You follow whichever is strictest on each point: a Utah COTA in home health needs the two-week and monthly in-person contact from the state, plus the OT's 30-day reassessment visit from Medicare.

Key Takeaways

• 34 of 51 jurisdictions set a minimum for COTA supervision; 17 leave it to the OT.
• The usual floor for an experienced COTA is about monthly. California and Georgia want weekly contact, New Jersey and Utah every two weeks.
• Nine states require in-person or on-site contact on a schedule for every COTA, and four more for newer COTAs.
• 13 states give new COTAs more supervision, and several count being new to a setting, which includes moving into home health.
• 14 states cap how many COTAs an OT can supervise, from two full-time in New Hampshire to five in New Jersey and New York.
• A co-signature is not supervision in at least six states. Keep a log or record even where none is required.
• Medicare's 30-day reassessment is a separate rule. Follow the stricter of Medicare, your state and your agency.
• This isn't legal advice. I checked these rules on November 9, 2026, and your board's current rule is the one that counts.

Frequently asked questions

How often does an OT have to supervise a COTA?

It depends on the state. 34 of the 51 jurisdictions set a minimum. In 25 of them the floor for an experienced COTA works out to about once a month, sometimes written as every 10th visit or 30 days, whichever comes first. California and Georgia want weekly contact, New Jersey every two weeks, and Utah every two weeks plus an in-person meeting each month. The other 17 leave the frequency to the supervising OT, usually in a written plan. Whatever your state says, the stricter of your state rule and your payer's rule is the one you follow.

Can COTA supervision be done by phone or video?

In many states, yes, for at least part of it. Idaho, Michigan, Minnesota, Nevada, New Hampshire, North Carolina, Oregon, South Dakota, Wyoming and several others say in their rules that video or telecommunication counts. Nine states require contact in person or on site on a fixed schedule whatever the COTA's experience: Arizona, Arkansas, Illinois, Kansas, Kentucky, Nebraska, New Jersey, Pennsylvania and Utah. Alabama, Vermont and West Virginia require on-site contact for newer COTAs. Check the exact words for your state in the table.

How many COTAs can one OT supervise?

Fourteen states set a number. New Hampshire is the tightest, at the combined hours of two full-time COTAs. Alabama, Alaska, California, Kentucky, North Dakota and Virginia cap it at three, and Alaska's three includes aides and students. Kansas, Michigan, Missouri and Oklahoma allow four. New Jersey and New York allow five, and New Mexico limits an OT in their first year of licensure to three. The other states leave the number to the OT's judgment.

Does a new-grad COTA need more supervision?

In 13 states the rules step supervision up for newer COTAs. Alabama requires the OT to be in the immediate area for the first 12 months, New Jersey requires daily face-to-face contact for the first year, Ohio requires weekly supervision in the first year, and Nebraska doubles the monthly on-site hours from 4 to 8. Illinois, Arizona and Wyoming also count being new to a setting or skill, which matters when an experienced COTA moves into home health.

Does the Medicare 30-day reassessment count as COTA supervision?

Not by itself. Medicare's home health rule requires the OT to provide the therapy service and functionally reassess the patient at least every 30 days, which is a coverage rule about the patient. State supervision rules are about the OT and the COTA: meetings, contact hours, logs and co-signatures. One visit can do both jobs if it meets both rules, but in states that count visits, the 10th or 12th COTA visit can come before day 30.

Sources

Every state's rule is linked in the table, to the state's legislature, its official administrative code publisher or its OT board. All were read on November 9, 2026. Where a site blocks automated reading, I read the same official document another way and say so in the research notes.

• 42 CFR 484.115(g) (opens in a new tab) (OTA qualifications), 484.75(c) (opens in a new tab) (supervision of skilled professional assistants), 409.44(c) (opens in a new tab) (home health therapy coverage and the 30-day reassessment) and 410.59 (opens in a new tab) (Part B outpatient OT, including private practice supervision).
• CMS, CY 2025 Physician Fee Schedule final rule (opens in a new tab), 89 FR 97710 (December 9, 2024), effective January 1, 2025: section II.H on supervision of OTAs and PTAs in private practice.
• CMS, Medicare Benefit Policy Manual, Chapter 15 (opens in a new tab), § 230.2.
• West Virginia Board of Occupational Therapy, position statement on supervision in early intervention and home health (opens in a new tab) (April 23, 2021).
• The OT Compact adds one line for COTAs working on a compact privilege: they "must be supervised by an occupational therapist licensed or holding a compact privilege in that remote state" (as enacted in South Carolina, S.C. Code § 40-36-540(D) (opens in a new tab)). Our OT Compact tracker shows where it stands.
• Related on this site: supervisory visit requirements in home health, which order an assistant works under, holding both a COTA and a PTA license.