4. Page 8 of the Draft PT Rules states:
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R 338.7139 Delegation of acts, tasks, or functions to a licensed or unlicensed individual; direct supervision of a
licensed or unlicensed individual; requirements.
Rule 39. (1) Under section 16215(6) of the code, MCL 333.16215, the requirements of this rule do not apply to a
physical therapist who delegates to a physical therapist assistant if the physical therapist satisfies the
requirements for delegation to a physical therapist assistant under R 338.7138.
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R 338.7138 was omitted in the Draft PT Rules.
APTA MI strongly recommends that R 338.7138 be returned to the PT Rules.
R 338.7138 clearly states the requirements for proper supervision of the licensed physical therapist assistant by
the licensed physical therapist. Although MCL 333.16109 Definitions; S-U defines supervision, the person
seeking information will need to know how to find it in the Public Health Code. Which is not a given. Additionally,
333.16109 does not include that a physical therapist shall not supervise more than 4 physical therapist assistants
at the same time.
For convenience, here is R 338.7138 from the current PT Rules:
R 338.7138 Delegation of acts, tasks, or functions to a physical therapist assistant; supervision of physical therapist
assistant; requirements.
Rule 38. (1) A physical therapist who delegates the performance of selected acts, tasks, or functions to a physical
therapist assistant as permitted under section 16215 of the code, MCL 333.16215, shall supervise the physical therapist
assistant consistent with section 16109(2) of the code, MCL 333.16109, and satisfy the requirements of this rule.
(2) A physical therapist who delegates acts, tasks, or functions under this rule shall also satisfy all the following:
(a) Ensure the qualifications of the physical therapist assistant under the physical therapist's supervision, including
verification of the physical therapist assistant's training, education, and licensure.
(b) Examine and evaluate the patient or client before delegating acts, tasks, or functions performed by a physical
therapist assistant.
(c) Provide predetermined procedures and protocols for delegated acts, tasks, or functions.
(d) Maintain a record of the names of the physical therapist assistants to whom acts, tasks, or functions are delegated.
(e) Monitor a physical therapist assistant's practice and provision of assigned physical therapy acts, tasks, or functions.
(f) Meet regularly with the physical therapist assistant to whom acts, tasks, or functions have been delegated to evaluate
the assistant's performance, review records, and educate the physical therapist assistant on the acts, tasks, or functions
that have been delegated.
(3) A physical therapist shall not supervise more than 4 physical therapist assistants at the same time.
9. Page 14. R 338.7161 License renewals; requirements; applicability.
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Here is the current Draft Language:
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(6) The department shall receive a request for a waiver of PDRs for the board’s consideration not less
than 30 days before the last regularly scheduled board meeting before the expiration date of the license.
Recommend that the current Draft Language be omitted.
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It is far more restrictive than the Public Health Code.
It substantially limits a licensee’s ability to inform the board that they need a waiver of PDRs in the event
of a personal or family illness, injury or catastrophic event such as losing your home and all your
possessions in a fire.
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Here is the current Public Health Code language:
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The department must receive a request for a continuing education waiver under section 16205(1) of the
code, MCL 333.16205, before the expiration date of the license.
Recommend that the current Public Health Code language remain in the PT Rules.
