| Question: Can a new grad work legally in the state of Michigan before passing the NBCOT Registration Exam? |
Answer: The short answer is “yes”. Registration by the state of Michigan regulates who can use the protected titles of the profession (OTR, OT, COTA, OTA, and any other title that would lead the public to believe that you were a qualified OT). It does not limit who can perform the activities of the profession, so anyone could work legally as an OT, as long as they do not call themselves an OT.
However, you must also meet the requirements for reimbursement of the payment source, which may be more stringent. Medicare, for example, recognizes only 4 types of practitioners who can bill services to them as occupational therapy: OT, OTA, OT student and OT aide. A new graduate is not an OT or an OTA, and they are no longer an OT student so they would be considered an OT aide, who requires direct supervision (in the same room during the service) by an OT to bill the service provided. If you do not meet their requirements for appropriate supervision of subordinate OT practitioners who provide services reimbursed by Medicare as OT, it would be considered fraud.
Once the new graduate passes the NBCOT certification exam they must apply for registration with the State of Michigan. They cannot use the professional titles until they are registered by the state.
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