Wiki occupational therapy group vs one-on-one coding

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Here's my situation. I work as the biller and coder at a pediatric speech and occupational therapy clinic. The owner, also an OTR/L, has her own case load and has picked up a few more kids due to a COTA leaving. She started one 45 min session. When it was supposed to end, she went and got the other kid and started treating them togother. After a while, she let the first kid go and focused on kid #2. I know she's going to try and do one-on-one coding (97112, 97110, 97530) and group (97150) for some of it. Everything I've read says you need to start a group session at the same time if one therapist is doing the group therapy. We often do 1 unit of group if two therapists have their kids do some activities together while giving them one-on-one time as well. But, there are two separate therapists seeing two separate kids. My question is, 1) is it even ethical for her to do that, and 2) is it legal to do that. Everything about this feels really wrong. She's been doing business for 17+ years and claims that she can do everything that she does. I want to find out as much as I can regarding this before I say anything to her.

Along the same lines, she is stating that she can have two level II students at the same time under her. Is that ok? She shows me documentation that it is ok and I find other documentation that states otherwise. There seems to be a lot of grey areas in regards to this. I have contacted our state Board of Occupational Therapy but I am still awaiting a response from them.

Please help if you can. I need as much insight as I can get. I don't want to be doing anything that is unethical, illegal or fraudulent. I will quit before I do anything like that Thanks!!
 
Along the same lines, she is stating that she can have two level II students at the same time under her. Is that ok? She shows me documentation that it is ok and I find other documentation that states otherwise. There seems to be a lot of grey areas in regards to this. I have contacted our state Board of Occupational Therapy but I am still awaiting a response from them.

https://www.law.cornell.edu/regulations/alabama/Ala-Admin-Code-r-625-X-8-.01

(4) Supervision Ratios:
(a) An occupational therapist may supervise up to three (3) full-time occupational therapy assistants, but never more than two (2) occupational therapy assistants who require "direct" level of supervision. The total number of supervised occupational therapy assistants, occupational therapy personnel on a limited permit, and non-licensed occupational therapy personnel (including any occupational therapy students, occupational therapy assistant students, licensee applicants required to perform a perceptorship, and/or aides) may not exceed five (5) without prior Board approval. The Board may permit the supervision of a greater number by an occupational therapist if, in the Board's opinion, there would be adequate supervision to protect public health and safety.

What have you read that contradicts what she is stating in regards to the number of OT students she may supervise?
 
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