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Louisiana OT advisory panel flags statutory-rule mismatches, recommends technical edits

November 15, 2025 | Louisiana State Board of Medical Examiners, Boards & Commissions, Organizations, Executive, Louisiana


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Louisiana OT advisory panel flags statutory-rule mismatches, recommends technical edits
The Occupational Therapy Advisory Committee (OTEC) of the Louisiana State Board of Medical Examiners spent much of its Nov. 14 meeting reviewing apparent discrepancies between the language of state law and the committee's recently adopted rules.

Chair Ingrid led a line-by-line read of statutory sections and flagged several areas that the committee said are out of sync with the rules adopted by OTEC. She told the group that Section 3006 reviews requirements for licensure but "it doesn't actually explicitly state that you have to pass [the NBCOT exam] in order to become licensed," calling attention to wording the committee says should be clarified. "That kinda struck me," she said.

Members agreed to replace references that currently point to the American Occupational Therapy Association (AOTA) with the National Board for Certification in Occupational Therapy (NBCOT) where the exam or certification is intended to be the standard; committee members said NBCOT is a separate certifying body and not under contract with AOTA.

The committee also found inconsistent language in Section 3008 concerning applicants trained in other countries; across different copies the provision alternates between "shall" and "may," creating ambiguity about when the board must waive testing for certain applicants. Staff acknowledged the public-facing copy on the board's website may not be the most current version and committed to correct it.

OTEC members pointed out another substantive mismatch: the committee eliminated a continuing-education waiver for state employees in the rules, but the statute still contains an exemption. Patricia Wilton, the board's executive counsel, recommended that OTEC consult the Louisiana Department of Health before pursuing statutory edits that directly affect state employees.

The panel also noted that fee amounts listed in statute appear outdated; staff told members fee changes require legislative action and that they will investigate how rule or administrative fee changes were implemented without corresponding statutory updates.

The committee asked staff to draft technical corrections and to present proposed statutory language and rule-conforming edits for OTEC review at a future meeting. "Tracy will fix that for us," one member said when a website discrepancy was identified.

What happens next: staff will prepare redlined language for the committee to review and will consult with LDH on changes affecting state employees; statutory fee changes would require legislative action.

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