PURSUANT TO THE PROVISIONS OF THE State Administrative Procedure Act, NOTICE is hereby given of the following proposed rule:
Proposed Action:
Amendment of section 76.4; repeal of sections 76.5 and 76.6; renumbering of section 76.7 to section 76.5; and addition of new sections 76.6, 76.7, 76.8 and 76.9 to Title 8 NYCRR.
Statutory authority:
Education Law, sections 207(not subdivided), 6504(not subdivided), 6507(2)(a) and 7906(4), (7); and L. 2011, ch. 460
Subject:
Occupational Therapy.
Purpose:
To implement chapter 460 of the Laws of 2011, relating to the profession of occupational therapy.
Text of proposed rule:
1. Section 76.4 of the Regulations of the Commissioner of Education is amended, effective June 13, 2012, as follows:
(a) …
(b) Limited permits may be renewed once for a period not to exceed one year at the discretion of the department because of personal or family illness or other extenuating circumstances which prevented the permittee from becoming licensed[, provided that the permittee has not failed the licensing examination in occupational therapy].
(c) Supervision.
(1) The occupational therapist providing direct supervision required by section 7905(2) of the Education Law shall develop a written supervision plan for each permitee. The written supervision plan shall specify the names, professions and other credentials of the persons participating in the supervisory process, the frequency of formal supervisory contacts; the methods (e.g. in-person, by telephone) and types (e.g. review of charts, discussion with permittee) of supervision; the content areas to be addressed; how written treatment notes and reports will be reviewed, including, but not limited to, whether such notes and reports will be initialed or co-signed by the supervisor; and how professional development will be fostered.
(2) Documentation of supervision shall include the date and content of each formal supervisory contact as identified in the written supervision plan and evidence of the review of all treatment notes and reports.
(3) The determination of the level and type of supervision shall be based on the ability level and experience of the permittee providing the delegated occupational therapy services, the complexity of client needs, and the setting in which the permittee is providing the services. The supervision plan shall require that the supervisor be notified whenever there is a clinically significant change in the condition or performance of the client, so that an appropriate supervisory action can take place.
(4) Direct supervision shall mean that the supervisor:
(i) initiates, directs and participates in the initial evaluation, interprets the evaluation data, and develops the occupational therapy services plan with input from the permittee;
(ii) participates, on a regular basis, in the delivery of occupational therapy services;
(iii) is responsible for determining the need for continuing, modifying, or discontinuing occupational therapy services;
(iv) takes into consideration information provided by the permittee about the client's responses to and communications during occupational therapy services; and
(v) is available for consultation with the permittee in a timely manner, taking into consideration the practice setting, the condition of the client and the occupational therapy services being provided.
(5) In no event shall the occupational therapist or licensed physician supervise more than five permittees, or its full time equivalent, provided that the total number of permittees being supervised by a single occupational therapist or licensed physician shall not exceed ten.
2. Sections 76.5 and 76.6 of the Regulations of the Commissioner of Education are repealed, and 76.7 of the Regulations of the Commissioner of Education is renumbered 76.5, effective June 13, 2012.
3. The Regulations of the Commissioner of Education are amended by the addition of new sections 76.6, 76.7, 76.8, and 76.9, effective June 13, 2012, to read as follows:
76.6 Definition of occupational therapy assistant practice and the use of the title occupational therapy assistant.
(a) An "occupational therapy assistant" shall mean a person authorized in accordance with this Part who provides occupational therapy services under the direction and supervision of an occupational therapist or licensed physician and performs client related activities assigned by the supervising occupational therapist or licensed physician. Only a person authorized under this Part shall participate in the practice of occupational therapy as an occupational therapy assistant, and only a person authorized under this Part shall use the title "occupational therapy assistant."
(b) As used in this section, client related activities shall mean:
(1) contributing to the evaluation of a client by gathering data, reporting observations and implementing assessments delegated by the supervising occupational therapist or licensed physician;
(2) consulting with the supervising occupational therapist or licensed physician in order to assist him or her in making determinations related to the treatment plan, modification of client programs or termination of a client's treatment;
(3) the utilization of a program of purposeful activities, a treatment program, and/or consultation with the client, family, caregiver, or other health care or education providers, in keeping with the treatment plan and under the direction of the supervising occupational therapist or licensed physician;
(4) the use of treatment modalities and techniques that are based on approaches taught in an occupational therapy assistant educational program registered by the Department or accredited by a national accreditation agency which is satisfactory to the Department, and that the occupational therapy assistant has demonstrated to the occupational therapist or licensed physician that he or she is competent to use; or
(5) the immediate suspension of any treatment intervention that appears harmful to the client and immediate notification of the occupational therapist or licensed physician.
76.7 Requirements for authorization as an occupational therapy assistant.
To qualify for authorization as an occupational therapy assistant pursuant to section 7906(7) of the Education Law, an applicant shall fulfill the following requirements:
(a) file an application with the Department;
(b) have received an education as follows:
(1) completion of a two-year associate degree program for occupational therapy assistants registered by the Department or accredited by a national accreditation agency which is satisfactory to the Department; or
(2) completion of a postsecondary program in occupational therapy satisfactory to the Department and of at least two years duration;
(c) have a minimum of three months clinical experience satisfactory to the state board for occupational therapy and in accordance with standards established by a national accreditation agency which is satisfactory to the Department;
(d) be at least eighteen years of age;
(e) be of good moral character as determined by the Department;
(f) register triennially with the Department in accordance with the provisions of subdivision (h) of this section, sections 6502 and 7906(8) of the Education Law, and sections 59.7 and 59.8 of this Subchapter;
(g) pay a fee for an initial license and a fee for each triennial registration period that shall be one half of the fee for initial license and for each triennial registration period established in Education law for occupational therapists; and
(h) except as otherwise provided by Education Law section 7907(2), pass an examination acceptable to the Department.
76.8 Supervision of occupational therapy assistant.
(a) A written supervision plan, acceptable to the occupational therapist or licensed physician providing direction and supervision, shall be required for each occupational therapy assistant providing services pursuant to section 7906(7) of the Education Law. The written supervision plan shall specify the names, professions and other credentials of the persons participating in the supervisory process, the frequency of formal supervisory contacts, the methods (e.g. in-person, by telephone) and types (e.g. review of charts, discussion with occupational therapy assistant) of supervision, the content areas to be addressed, how written treatment notes and reports will be reviewed, including, but not limited to, whether such notes and reports will be initialed or co-signed by the supervisor, and how professional development will be fostered.
(b) Documentation of supervision shall include the date and content of each formal supervisory contact as identified in the written supervision plan and evidence of the review of all treatment notes, reports and assessments.
(c) Consistent with the requirements of this section, the determination of the level and type of supervision shall be based on the ability level and experience of the occupational therapy assistant providing the delegated occupational therapy services, the complexity of client needs, the setting in which the occupational therapy assistant is providing the services, and consultation with the occupational therapy assistant.
(d) The supervision plan shall require that the occupational therapist or licensed physician be notified whenever there is a clinically significant change in the condition or performance of the client, so that an appropriate supervisory action can take place.
(e) Direction and supervision means that the occupational therapist or licensed physician:
(i) initiates, directs and participates in the initial evaluation occupational therapy assistant under the authority of, interprets the evaluation data, and develops the occupational therapy services plan with input from the occupational therapy assistant;
(ii) participates, on a regular basis, in the delivery of occupational therapy services;
(iii) is responsible for determining the need for continuing, modifying, or discontinuing occupational therapy services, after considering any reports by the occupational therapy assistant of any changes in the condition of the client that would require a change in the treatment plan;
(iv) takes into consideration information provided about the client's responses to and communications during occupational therapy services; and
(v) is available for consultation with the occupational therapy assistant in a timely manner, taking into consideration the practice setting, the condition of the client and the occupational therapy services being provided.
(f) In no event shall the occupational therapist or licensed physician supervise more than five occupational therapy assistants, or its full time equivalent, provided that the total number of occupational therapy assistants being supervised by a single occupational therapist or licensed physician shall not exceed ten.
76.9 Occupational therapy assistant student exemption. To be permitted to practice as an exempt person pursuant to section 7906(4) of the Education Law, an occupational therapy assistant student shall be enrolled in a program as set forth in section 76.7(b)(1) of this Part and shall be directly supervised by an occupational therapist in accordance with standards established by a national accreditation agency which is satisfactory to the Department. Direct supervision, as required by section 7906(4) of the Education Law, may be provided in conjunction with an occupational therapy assistant who is designated as a fieldwork educator by a program that meets the requirements of section 76.7(b)(1) of this Part. Any such work performed by an occupational therapy assistant as a fieldwork educator shall be subject to the supervision requirements of section 76.8 of this Part.
Text of proposed rule and any required statements and analyses may be obtained from:
Mary Gammon, State Education Department, Office of Counsel, State Education Building, Room 148, 89 Washington Ave., Albany, NY 12234, (518) 474-8857, email: legal@mail.nysed.gov
Data, views or arguments may be submitted to:
Office of the Professions, Office of the Deputy Commissioner, State Education Department, 89 Washington Avenue, 2M, Albany, NY 12234, (518) 474-1941, email: opdepcom@mail.nysed.gov
Public comment will be received until:
45 days after publication of this notice.
Regulatory Impact Statement
1. STATUTORY AUTHORITY:
Section 207 of the Education Law grants general rule-making authority to the Board of Regents to carry into effect the laws and policies of the State relating to education.
Section 6504 of the Education Law provides that admission to the professions shall be supervised by the Board of Regents, and administered by the Education Department, assisted by a state board for each profession.
Paragraph (a) of subdivision (2) of section 6507 of the Education Law authorizes the Commissioner of Education to promulgate regulations in administering the admission to and practice of the professions.
Subdivision (2) of section 7905 of the Education Law authorizes the Commissioner of Education to define in regulation direct supervision of limited permittees in occupational therapy.
Subdivision (4) of section 7906 of the Education Law authorizes the Commissioner of Education to define in regulation the direct supervision of an occupational therapy assistant student engaged in occupational therapy as an exempt person.
Subdivision (7) of section 7906 of the Education Law authorizes the Commissioner of Education to define occupational therapy assistants and to promulgate regulations governing standards for authorization to practice as an occupational therapy assistant, including those relating to education, experience, examination and character, and authorizes the Board of Regents to establish an application fee for such authorization to practice.
2. LEGISLATIVE OBJECTIVES:
The proposed amendment to section 76.4(b) of the Regulations of the Commissioner of Education carries out the intent of the aforementioned statutes by removing the provision that prohibits a holder of a limited permit in occupational therapy from receiving a renewal of the permit in the event the holder has failed the licensing examination.
The proposed adoption of a new section 76.4(c) of the Commissioner's regulations carries out the intent of the aforementioned statutes by defining supervision of a holder of a limited permit in occupational therapy, including a requirement for a written supervision plan and requirements for documentation of supervision.
The proposed adoption of a new section 76.6 of the Commissioner's regulations carries out the intent of the aforementioned statutes by defining occupational therapy practice and providing that only a person authorized by the Department shall participate in the practice of occupational therapy assistant and use the title occupational therapy assistant.
The proposed adoption of a new section 76.7 of the Commissioner's regulations carries out the intent of the aforementioned statutes by establishing standards for authorization to practice as an occupational therapy assistant, including those relating to education, experience, examination, and character, and by establishing fees for initial licensure and for triennial registration.
The proposed adoption of a new section 76.8 of the Commissioner's regulations carries out the intent of the aforementioned statutes by defining supervision of an occupational therapy assistant, including a requirement for a written supervision plan, requirements for documentation of supervision, and a limitation on the number of occupational therapists who may be supervised.
The proposed adoption of a new section 76.9 of the Commissioner's regulations carries out the intent of the aforementioned statutes by setting requirements for an occupational therapy student to qualify for the statutory exemption allowing him or her to practice under supervision.
3. NEEDS AND BENEFITS:
The changes to the existing law governing the practice of occupational therapy that were enacted by Chapter 460 of the Laws of 2011 authorized the Department to establish, in regulation, several significant components of the practice, including the requirements for eligibility and scope of practice for occupational therapy assistants, and requirements for supervision of holders of limited permits, occupational therapy assistants, and occupational therapy assistant students. These regulations are necessary to implement the provisions of Chapter 460.
4. COSTS:
(a) Cost to State government: It is anticipated that the costs to the State Education Department in implementing the requirements of Chapter 460 of the Laws of 2011 will be offset by the licensure and registration fees authorized by the law.
(b) Cost to local government: The proposed amendments to section 76.4(c) and 76.8 of the Commissioner's regulations require the preparation of a written supervision plan governing the supervision of holders of limited permits and occupational therapy assistants, respectively. This may impose some additional small cost required to create and maintain these plans, consisting primarily of the time that the supervisor and occupational therapy assistant will spend in developing the supervision plan. The development of the plan should yield a more effective working relationship and use of the skills of the occupational therapy assistant.
(c) Cost to private regulated parties: The regulations impose certain supervision requirements not currently found in regulation for holders of limited permits, occupational therapy assistants and occupational therapy assistant students. Depending on the costs of supervision currently provided, this may create additional costs to those entities that employ these professionals. The amount of this cost is unknown at this time. As authorized by Chapter 460 of the Laws of 2011, the proposed regulations also establish fees for licensure and triennial registration.
(d) Costs to the regulatory agency: As stated in "Costs to State Government," the proposed amendment does not impose costs on the State Education Department beyond those covered by the proposed licensure and registration fees for occupational therapy assistants.
5. LOCAL GOVERNMENT MANDATES:
The proposed amendment does not impose any program, service, duty, or responsibility upon local governments.
6. PAPERWORK:
The proposed amendments to section 76.4(c) and 76.8 of the Commissioner's regulations require the preparation of a written supervision plan governing the supervision of holders of limited permits and occupational therapy assistants, respectively.
7. DUPLICATION:
The amendment does not duplicate other existing State or Federal requirements.
8. ALTERNATIVES:
Alternative were considered to various aspects of these regulations, particularly as to the supervision requirements for holders of limited permits and occupational therapy assistants.
Not requiring a written supervision plan was considered as an alternative for both supervision of holders of limited permits and occupational therapy assistants. However, given the wide range of settings in which these professionals practice, and the wide range of experience possessed by these professionals, it is believed that a written supervision plan provides the most effective and flexible method for the development and documentation of proper supervision. The requirement for a plan will provide the supervisor with the opportunity to establish supervision guidelines that are unique for each supervised professional and the opportunity to modify the plan as circumstances dictate.
An alternative regarding the nature of the supervisory contacts set out in the plan and how these supervisory contacts are documented was also considered, which would require all supervisory contacts to be addressed and documented. It is believed that limiting these requirements to formal supervisory contacts is a reasonable limitation that will decrease the required paperwork of this regulation.
Various alternatives were considered regarding the number of holders of limited permits and occupational therapist assistants that may be supervised by a single occupational therapist or physician, including not imposing a limit on this number. To ensure safe and effective practice, it is believed that some limit on this number must be imposed. The scope of practice of a holder of a limited permit in occupational therapy or an occupational therapy assistant is substantially the same as that of an occupational therapist, in terms of delivery of treatment. Hence, although the qualifications of these limited permittees and occupational therapy assistants are not the same of those of a therapist, the assistant or permittee is permitted to perform the same therapeutic tasks, with supervision. Given that the supervision is the only limit imposed on practice, it is believed that a reasonable limit on the number of supervised individuals should be imposed. A strict limit of five was considered, as well as a limit of five or its full-time equivalent. It was determined that the full-time equivalent of five was the appropriate number, with an outside limit of ten individuals.
Alternatives to the supervision requirements for occupational therapy assistant students were considered. Virtually all of such students in New York State attend programs accredited by the Accreditation Council for Occupational Therapy (ACOTE), and there is no other recognized national body for accreditation of such programs. ACOTE has established accreditation standards governing the fieldwork of occupational therapy assistant students, and it is believed that these are adequate to protect the public. The alternative would be to create new standards, but this may create a duplicative set of standards that may not be consistent with those used by a given educational program. It was also noted that the ACOTE accreditation standards permit supervision of students by either occupational therapists or occupational therapist assistants. The statute is clear, however, in requiring that students be directly supervised by an occupational therapist.
9. FEDERAL STANDARDS:
There are no Federal standards regarding the matters addressed by these regulations.
10. COMPLIANCE SCHEDULE:
The proposed amendment must be complied with on its stated effective date. No additional period of time is necessary to enable regulated parties to comply.
Regulatory Flexibility Analysis
(a) Small Businesses:
1. EFFECT OF RULE:
The purpose of the proposed amendment is to implement Chapter 460 of the Laws of 2011 which made a variety of changes to the law affecting the practice of occupational therapy.
As of July 2011, there were 10,712 occupational therapists licensed in New York State and 4,032 certified occupational therapy assistants. Reliable data on the number of these individuals employed by a small business is not available for New York State. However, a national workforce study conducted by the American Occupational Therapy Association in 2010 reflected that, nationally, 53% of these professionals work in either a hospital, a school setting or academia. If that pattern holds true for New York State, it follows that the potential maximum number of professionals employed by a small business would be the remaining 47%, or 6,930. The number is likely to be substantially smaller than this.
2. COMPLIANCE REQUIREMENTS:
Small businesses subject to the proposed amendments to the Commissioner's regulations would be subject to supervision requirements applicable to holders of limited permits in occupational therapy and to occupational therapy assistants. These include a requirement for a written supervision plan.
3. PROFESSIONAL SERVICES:
The proposed regulation will require no small businesses to need professional services.
4. COMPLIANCE COSTS:
The proposed section 76.7(g) of the Commissioner's regulations establishes a fee for an initial license and for each triennial registration for an occupational therapy assistant. The establishment of this fee is mandated by statute. The proposed regulation would set this fee at one-half of the amount imposed on occupational therapists, which would yield a fee of $147 for initial licensure and three-year registration, and a fee of $90 for the subsequent three-year re-registrations. Currently, these fees for occupational therapy assistants are set at $103 for initial licensure and three year registration, and $54 for the subsequent three year registrations only. The increase is required because occupational therapy assistants are now subject to discipline and moral character review by the Department, and the cost of these processes must be covered by fee revenue.
In addition, the proposed amendments to section 76.4(c) and 76.8 of the Commissioner's regulations require the preparation of a written supervision plan governing the supervision of holders of limited permits and occupational therapy assistants, respectively. This may impose some additional small cost to the professionals required to create and maintain these plans, consisting primarily of the time that the supervisor and occupational therapy assistant will spend in developing the supervision plan. The development of the plan should yield a more effective working relationship and use of the skills of the occupational therapy assistant.
5. ECONOMIC AND TECHNOLOGICAL FEASIBILITY:
The proposed regulation will not impose any technological requirements on regulated parties, including those that are classified as small businesses, and the regulation is economically feasible. See above "Compliance Costs" for the economic impact of the regulation.
6. MINIMIZING ADVERSE IMPACT:
The proposed fee structure was determined to be the minimum needed to support additional costs. It is on a par with fee structures in other professions. The written supervision plan was determined to be a method whereby the professionals involved could fashion supervision that is flexible and meets the needs of those involved with minimal adverse impact. This was determined to be a better alternative than imposing more detailed supervision requirements.
7. SMALL BUSINESS PARTICIPATION:
The New York State Occupational Therapy Association (NYSOTA), which represents both occupational therapists and occupational therapy assistants, and includes members who have experience in a small business environment, was consulted and provided input into the development of the proposed regulation. In addition, individual professionals provided the State Education Department with comments, and meetings were held in Albany and Middletown to discuss concerns over the proposed amendments.
(b) Local Governments:
The purpose of the proposed amendment is to implement Chapter 460 of the Laws of 2011 which made a variety of changes to the law affecting the practice of occupational therapy. As of July 2011, there were 10,712 occupational therapists and 4,032 occupational therapy assistants licensed in New York State. Reliable data on the number of these individuals employed by local government in New York State is not available, but a national workforce study conducted by the American Occupational Therapy Association in 2010 reflected that nationally, 26.5% of these professionals work in government, which would include both state and local government. This study also found that 21.7% work in schools. The flexibility analysis for local government entities employing these individuals would be the same as that set forth above for small businesses.
Rural Area Flexibility Analysis
1. TYPES AND ESTIMATED NUMBERS OF RURAL AREAS:
The proposed amendments apply to all occupational therapy assistants and holders of limited permits in occupational therapy, and those occupational therapists and physicians who supervise these professionals who live in the 44 rural counties with less than 200,000 inhabitants and the 71 towns in urban counties with a population density of 150 per square mile or less.
2. REPORTING, RECORDKEEPING AND OTHER COMPLIANCE REQUIREMENTS; AND PROFESSIONAL SERVICES:
The proposed amendments to sections 76.4(c) and 76.8 of the Commissioner's regulations establish standards for supervision for holders of limited permits and occupational therapy assistants, respectively. The establishment of such standards is mandated by statute. These amendments also require the preparation of a written supervision plan governing the supervision of holders of limited permits and occupational therapy assistants, respectively.
3. COSTS:
The proposed section 76.7(g) of the Commissioner's regulations establishes a fee for an initial license and for each triennial registration for an occupational therapy assistant. The establishment of this fee is mandated by statute. The proposed regulation would set this fee at one half that amount imposed on occupational therapists, which would yield a fee of $147 for initial licensure and three year registration, and a fee of $90 for the subsequent three year re-registrations. Currently, these fees are set at $103 for initial licensure and three year registration, and at $54 for the subsequent three year registrations only. The increase is required because occupational therapists are now subject to discipline and moral character review by the Department, and the cost of these processes must be covered by fee revenue.
In addition, the proposed amendments to section 76.4(c) and 76.8 of the Commissioner's regulations require the preparation of a written supervision plan governing the supervision of holders of limited permits and occupational therapy assistants, respectively. This may impose some additional small cost to the professionals required to create and maintain these plans, consisting primarily of the time that the supervisor and occupational therapy assistant will spend in developing the supervision plan, The development of the plan should yield a more effective working relationship and use of the skills of the occupational therapy assistant.
4. MINIMIZING ADVERSE IMPACT:
The proposed fee structure was determined to be the minimum needed to support additional costs. It is on a par with fee structures in other professions. The written supervision plan was determined to be a method whereby the professionals involved could fashion supervision that is flexible and meets the needs of those involved with minimal adverse impact. This was determined to be a better alternative than imposing more detailed supervision requirements.
5. RURAL AREA PARTICIPATION:
The State Education Department solicited comments on the proposed amendments from the New York State Occupational Therapy Association (NYSOTA), and Department staff attended a meeting of the Capital District NYSOTA (which includes Schenectady, Rensselaer, Columbia and Greene counties) in Albany and the Hudson-Taconic NYSOTA (which includes Ulster, Sullivan, Dutchess and Delaware counties) in Middletown to discuss these proposed amendments.
Job Impact Statement
1. NATURE OF IMPACT:
The proposed regulation is required to implement changes to the existing law governing the practice of occupational therapy that were enacted by Chapter 460 of the Laws of 2011. This law authorized the Department to establish, in regulation, several significant components of the practice, including the requirements for eligibility and scope of practice for occupational therapy assistants, and requirements for supervision of holders of limited permits, occupational therapy assistants, and occupational therapy assistant students.
Existing regulations state that the direct supervision of occupational therapy assistants shall include meeting with and observing the occupational therapy assistant on a regular basis to review the implementation of treatment plans and to foster professional development. There is no provision in existing regulation governing the supervision of holders of limited permits in occupational therapy.
The proposed regulations contain more detailed provisions for the supervision of occupational therapy assistants and holders of limited permits. These include a requirement for a written supervision plan and requirements for the documentation of formal supervisory contacts. Entities that employ occupational therapy assistants and holders of limited permits might believe that the additional cost associated with compliance will result in the loss of jobs or job opportunities.
In addition, a new limit on the number of individuals who can be supervised by a single individual is proposed. The supervisor may supervise no more than five individuals, or its full time equivalent, provided that the total number of individuals being supervised by a single occupational therapist or licensed physician cannot exceed ten.
2. CATEGORIES AND NUMBERS AFFECTED:
As of July 2011, there were 4,032 certified occupational therapy assistants currently registered with the Department, and 10,712 licensed occupational therapists so registered. In 2011, approximately 155 limited permits in occupational therapy were issued.
3. REGIONS OF ADVERSE IMPACT:
There is no region of the state that would experience a disproportionate adverse impact on jobs or employment opportunities.
4. MINIMIZING ADVERSE IMPACT:
As this proposed regulation was being drafted, several provisions were developed to minimize adverse impact. A provision was added to the requirement that supervision be limited to five professional to allow the full time equivalent of these five individuals. This would allow for the supervision of up to ten individuals on a part-time basis. The requirement that supervisory contacts needed to be documented was limited to formal supervisory contacts as identified in the supervision plan. A requirement that the supervisor devote a fixed percentage of time to supervision was considered and rejected. The written supervision plan was determined to be a method whereby the professionals involved could fashion supervision that is flexible and meets the needs of those involved with minimal adverse impact. This was determined to be a better alternative than imposing more specific and detailed supervision requirements.
