[OTlist] COTA documentation regulations

[Patcheslevin]

I reside in California and recently had a state surveyor review our SNF facility.  The company I work for is looking to expand into outpatient services at this facility.  When the surveyor reviewed O.T. documentation and found that a COTA had documented a weekly progress note, I was told that COTAs are not allowed to write weekly progress notes.  My understanding was that they were allowed to do so, but of course OTRs are to complete all other documentation.  I work closely with the COTAs on a daily basis and I review weekly the patient's progress with them.  The COTAs I work with have 20 years experience and I feel are very capable of performing this documentation.  The surveyor stated Title 22 Section 72413 and section 72401 of the Medicare codes, but I am unable to locate this.  Can anyone help me out as now our facility is looking at a deficiency and I am told that COTAs are no longer able to perform any documentation.  Thank you