OTAs may function without supervision from an OT when the services being provided are services that any skilled and competent person can provide (i.e. family member, educator, individual trained or certified in offering that service) and are not occupational therapy services, including services provided under an occupational therapy plan of care, as defined in the OT Practice Act and Rules.
Though an OTA, when providing non-occupational therapy services, may represent oneself as an occupational therapy assistant and use the title OTA, the individual may not represent the services as occupational therapy services.