Existing law requires the Commission on Teacher Credentialing to, among other things, establish standards for the issuance and renewal of credentials, certificates, and permits. Existing law sets forth the minimum requirements for a preliminary services credential with a specialization in administrative services, which include, among other requirements, possession of one of various types of credentials and the completion of a minimum of 3 years of teaching experience, as provided.

This bill would provide that a valid license to practice occupational therapy or physical therapy and verification of meeting a basic skills requirement, as specified, and 3 years of experience as a school-based occupational therapist or physical therapist may be used to satisfy respective requirements for a preliminary services credential with a specialization in administrative services, as provided.

This bill would incorporate additional changes to Section 44270 of the Education Code proposed by SB 1329 to be operative only if this bill and SB 1329 are enacted and this bill is enacted last.

Existing law requires the Commission on Teacher Credentialing to, among other things, establish standards for the issuance and renewal of credentials, certificates, and permits. Existing law sets forth the minimum requirements for a preliminary services credential with a specialization in administrative services, which include, among other requirements, possession of one of various types of credentials and the completion of a minimum of 3 years of teaching experience, as provided.

This bill would provide that a valid license to practice occupational therapy or physical therapy and verification of meeting a basic skills requirement, as specified, and 3 years of experience as a school-based occupational therapist or physical therapist may be used to satisfy respective requirements for a preliminary services credential with a specialization in administrative services, as provided.

Existing law requires the Commission on Teacher Credentialing to, among other things, establish standards for the issuance and renewal of credentials, certificates, and permits. Existing law sets forth the minimum requirements for a preliminary services credential with a specialization in administrative services, which include, among other requirements, possession of one of various types of credentials and the completion of a minimum of 3 years of teaching experience, as provided.

This bill would provide that a valid license to practice occupational therapy or physical therapy and verification of meeting a basic skills requirement, as specified, and 3 years of experience as a school-based occupational therapist or physical therapist may be used to satisfy respective requirements for a preliminary services credential with a specialization in administrative services, as provided.

Existing law sets forth the minimum requirements for a services credential with a specialization in health. Existing law authorizes the holder of a services credential with a specialization in health to perform, at all grade levels, health services approved by the Commission on Teacher Credentialing. Existing law specifies that services as an occupational therapist or physical therapist are not health services for this purpose.

This bill would state the intent of the Legislature to enact future legislation related to an occupational therapist or a physical therapist applying for an administrative services credential.

GOVERNOR'S VETO

GV Bill Id:AB 2725

Author:(Blanca Rubio and Muratsuchi)

As Enrolled Ver:August 31, 2024

2/3 vote

SUMMARY

Adds to the minimum requirements for a preliminary services credential with a specialization in administrative services, a valid license to practice occupational therapy or a valid license to practice physical therapy, verification of meeting a basic skills requirement as determined by the Commission on Teacher Credentialing (CTC), and three years of experience as a school-based occupational therapist (OT) or physical therapist (PT).

Senate Amendments

Add double-jointing language to avoid chaptering out issues with SB 1329 (Committee on Education) of the current legislative session.

Governor's Veto Message

This bill would allow occupational therapists and physical therapists with three years of school-based experience to obtain an administrative services credential, provided they also meet the basic skills requirement and complete an administrative services program, or pass an examination aligned to administrative services standards adopted by the Commission on Teacher Credentialing (CTC).

While this bill is well-intentioned, there is no state requirement that occupational therapists and physical therapists must hold an administrative services credential to hold supervisory or administrative roles in local educational agencies. The pathways for these licensed professionals can be created at the local level, through human resources and collective bargaining. As a more appropriate statewide approach, the CTC could create at least two administrative services pathways: one for teachers, and one for other credential or license holders without a teacher preparation background. As such, I am requesting that the CTC develop such pathways.

COMMENTS

Therapy services being provided in schools today. According to the California Department of Education's (CDE) Guidelines for Occupational Therapy and Physical Therapy in California Public Schools, 2012, OTs and PTs work with the educational team to support a child's ability to gain access to the general education curriculum, meet state standards, participate in postsecondary education, and become functional independent citizens upon graduation. In school-based practice, OTs are health professionals whose purpose in a public school setting is to support a child's engagement and participation in daily occupations, which include activities of daily living, education, prevocational work, play, rest, leisure, and social participation. PTs are health professionals whose purpose is to correct, facilitate, or adapt the child's functional performance in motor control and coordination, posture and balance, functional mobility, accessibility, and the use of assistive devices.

According to the Author

"OTs and PTs have been providing related services to students in public schools since the 1970s and are the only Individuals with Disabilities Education Act (IDEA)-mandated professionals not included in a credential opportunity afforded to teachers and all other related services providers. This is based on a statute that was written at a time prior to IDEA and districts' employment of OTs and PTs. Currently, OTs and PTs working in school systems are not authorized to obtain a base credential, thereby rendering them ineligible to pursue an administrative services credential or participate in many higher-level positions. Creating a pathway for OTs and PTs who desire to obtain an administrative services credential will allow qualified personnel an opportunity to move into administrative roles and share their unique expertise at a leadership level."

Arguments in Support

The Occupational Therapy Association of California and the California Physical Therapy Association write, in a joint letter, "OTs and PTs have been providing educationally-related services to students in public schools since the 1970s and are the only Individual with Disabilities Education Act mandated professionals who are not included in a credential opportunity afforded to other related service providers and teachers. Currently, OTs and PTs working in the school systems are not authorized to obtain a base credential, thereby rendering them ineligible to pursue an administrative service credential. This measure would allow OTs and PTs to pursue administrative and leadership positions. Their unique training and expertise can contribute meaningfully at a systems level to support access and inclusion of all students.

Thus, Education Code Section 44270 needs to be modified to increase professional equity for OTs and PTs and ultimately support improved outcomes for all students. Passage of AB 2725 is a crucial step in supporting children and families by providing a pathway for OTs and PTs to advance within the educational system."

Arguments in Opposition

None on file

FISCAL COMMENTS

According to the Senate Appropriations Committee: "The CTC estimates General Fund costs of $138,000 in the first year and ongoing General Fund costs of $136,000 to create resources, answer inquiries from the public and local educational agencies (LEAs), update the system, and process additional applications."

VOTES

ASM EDUCATION: 7-0-0

YES: Muratsuchi, Addis, Alvarez, Bonta, Flora, Hoover, McCarty

ASM APPROPRIATIONS: 14-0-1

YES: Wicks, Sanchez, Arambula, Bryan, Calderon, Wendy Carrillo, Dixon, Mike Fong, Grayson, Haney, Hart, Pellerin, Ta, Villapudua

ABS, ABST OR NV: Jim Patterson

ASSEMBLY FLOOR: 65-0-15

YES: Addis, Aguiar-Curry, Alanis, Alvarez, Arambula, Bauer-Kahan, Bennett, Berman, Boerner, Bonta, Bryan, Calderon, Juan Carrillo, Wendy Carrillo, Chen, Connolly, Davies, Dixon, Essayli, Mike Fong, Vince Fong, Friedman, Gallagher, Garcia, Gipson, Hart, Holden, Hoover, Irwin, Jackson, Jones-Sawyer, Kalra, Lackey, Lee, Lowenthal, Maienschein, McCarty, McKinnor, Muratsuchi, Ortega, Pacheco, Papan, Jim Patterson, Joe Patterson, Pellerin, Quirk-Silva, Ramos, Rendon, Reyes, Rodriguez, Blanca Rubio, Sanchez, Santiago, Soria, Ta, Valencia, Villapudua, Waldron, Ward, Weber, Wicks, Wilson, Wood, Zbur, Robert Rivas

ABS, ABST OR NV: Bains, Cervantes, Megan Dahle, Flora, Gabriel, Grayson, Haney, Low, Mathis, Stephanie Nguyen, Petrie-Norris, Luz Rivas, Schiavo, Ting, Wallis

SENATE FLOOR: 40-0-0

YES: Allen, Alvarado-Gil, Archuleta, Ashby, Atkins, Becker, Blakespear, Bradford, Caballero, Cortese, Dahle, Dodd, Durazo, Eggman, Glazer, Gonzalez, Grove, Hurtado, Jones, Laird, Limón, McGuire, Menjivar, Min, Newman, Nguyen, Niello, Ochoa Bogh, Padilla, Portantino, Roth, Rubio, Seyarto, Skinner, Smallwood-Cuevas, Stern, Umberg, Wahab, Wiener, Wilk

ASSEMBLY FLOOR: 77-0-2

YES: Addis, Aguiar-Curry, Alanis, Alvarez, Arambula, Bains, Bauer-Kahan, Bennett, Berman, Boerner, Bonta, Bryan, Calderon, Juan Carrillo, Wendy Carrillo, Chen, Connolly, Megan Dahle, Davies, Dixon, Essayli, Flora, Mike Fong, Friedman, Gabriel, Gallagher, Garcia, Gipson, Grayson, Haney, Hart, Holden, Hoover, Irwin, Jackson, Jones-Sawyer, Kalra, Lackey, Lee, Low, Lowenthal, Maienschein, Mathis, McCarty, McKinnor, Muratsuchi, Stephanie Nguyen, Pacheco, Papan, Jim Patterson, Joe Patterson, Pellerin, Petrie-Norris, Quirk-Silva, Ramos, Rendon, Reyes, Luz Rivas, Rodriguez, Blanca Rubio, Sanchez, Santiago, Schiavo, Soria, Ta, Ting, Valencia, Villapudua, Waldron, Wallis, Ward, Weber, Wicks, Wilson, Wood, Zbur, Robert Rivas

ABS, ABST OR NV: Cervantes, Ortega

UPDATED

VERSION: August 31, 2024

CONSULTANT: Debbie Look / ED. / (916) 319-2087 FN: 0005174

CONCURRENCE IN SENATE AMENDMENTS

CSA1 Bill Id:AB 2725

Author:(Blanca Rubio and Muratsuchi)

As Amended Ver:August 22, 2024

Majority vote

SUMMARY

Adds to the minimum requirements for a preliminary services credential with a specialization in administrative services, a valid license to practice occupational therapy or a valid license to practice physical therapy, verification of meeting a basic skills requirement as determined by the Commission on Teacher Credentialing (CTC), and three years of experience as a school-based occupational therapist (OT) or physical therapist (PT).

Senate Amendments

Add double-jointing language to avoid chaptering out issues with SB 1329 (Committee on Education) of the current legislative session.

COMMENTS

Therapy services being provided in schools today. According to the California Department of Education's (CDE) Guidelines for Occupational Therapy and Physical Therapy in California Public Schools, 2012, OTs and PTs work with the educational team to support a child's ability to gain access to the general education curriculum, meet state standards, participate in postsecondary education, and become functional independent citizens upon graduation. In school-based practice, OTs are health professionals whose purpose in a public school setting is to support a child's engagement and participation in daily occupations, which include activities of daily living, education, prevocational work, play, rest, leisure, and social participation. PTs are health professionals whose purpose is to correct, facilitate, or adapt the child's functional performance in motor control and coordination, posture and balance, functional mobility, accessibility, and the use of assistive devices.

According to the Author

"OTs and PTs have been providing related services to students in public schools since the 1970s and are the only Individuals with Disabilities Education Act (IDEA)-mandated professionals not included in a credential opportunity afforded to teachers and all other related services providers. This is based on a statute that was written at a time prior to IDEA and districts' employment of OTs and PTs. Currently, OTs and PTs working in school systems are not authorized to obtain a base credential, thereby rendering them ineligible to pursue an administrative services credential or participate in many higher-level positions. Creating a pathway for OTs and PTs who desire to obtain an administrative services credential will allow qualified personnel an opportunity to move into administrative roles and share their unique expertise at a leadership level."

Arguments in Support

The Occupational Therapy Association of California and the California Physical Therapy Association write, in a joint letter, "OTs and PTs have been providing educationally-related services to students in public schools since the 1970s and are the only Individual with Disabilities Education Act mandated professionals who are not included in a credential opportunity afforded to other related service providers and teachers. Currently, OTs and PTs working in the school systems are not authorized to obtain a base credential, thereby rendering them ineligible to pursue an administrative service credential. This measure would allow OTs and PTs to pursue administrative and leadership positions. Their unique training and expertise can contribute meaningfully at a systems level to support access and inclusion of all students.

Thus, Education Code Section 44270 needs to be modified to increase professional equity for OTs and PTs and ultimately support improved outcomes for all students. Passage of AB 2725 is a crucial step in supporting children and families by providing a pathway for OTs and PTs to advance within the educational system."

Arguments in Opposition

None on file

FISCAL COMMENTS

According to the Senate Appropriations Committee: " The CTC estimates General Fund costs of $138,000 in the first year and ongoing General Fund costs of $136,000 to create resources, answer inquiries from the public and local educational agencies (LEAs), update the system, and process additional applications."

VOTES:

ASM EDUCATION: 7-0-0

YES: Muratsuchi, Addis, Alvarez, Bonta, Flora, Hoover, McCarty

ASM APPROPRIATIONS: 14-0-1

YES: Wicks, Sanchez, Arambula, Bryan, Calderon, Wendy Carrillo, Dixon, Mike Fong, Grayson, Haney, Hart, Pellerin, Ta, Villapudua

ABS, ABST OR NV: Jim Patterson

ASSEMBLY FLOOR: 65-0-15

YES: Addis, Aguiar-Curry, Alanis, Alvarez, Arambula, Bauer-Kahan, Bennett, Berman, Boerner, Bonta, Bryan, Calderon, Juan Carrillo, Wendy Carrillo, Chen, Connolly, Davies, Dixon, Essayli, Mike Fong, Vince Fong, Friedman, Gallagher, Garcia, Gipson, Hart, Holden, Hoover, Irwin, Jackson, Jones-Sawyer, Kalra, Lackey, Lee, Lowenthal, Maienschein, McCarty, McKinnor, Muratsuchi, Ortega, Pacheco, Papan, Jim Patterson, Joe Patterson, Pellerin, Quirk-Silva, Ramos, Rendon, Reyes, Rodriguez, Blanca Rubio, Sanchez, Santiago, Soria, Ta, Valencia, Villapudua, Waldron, Ward, Weber, Wicks, Wilson, Wood, Zbur, Robert Rivas

ABS, ABST OR NV: Bains, Cervantes, Megan Dahle, Flora, Gabriel, Grayson, Haney, Low, Mathis, Stephanie Nguyen, Petrie-Norris, Luz Rivas, Schiavo, Ting, Wallis

SENATE FLOOR: 40-0-0

YES: Allen, Alvarado-Gil, Archuleta, Ashby, Atkins, Becker, Blakespear, Bradford, Caballero, Cortese, Dahle, Dodd, Durazo, Eggman, Glazer, Gonzalez, Grove, Hurtado, Jones, Laird, Limón, McGuire, Menjivar, Min, Newman, Nguyen, Niello, Ochoa Bogh, Padilla, Portantino, Roth, Rubio, Seyarto, Skinner, Smallwood-Cuevas, Stern, Umberg, Wahab, Wiener, Wilk

UPDATED

VERSION: August 22, 2024

CONSULTANT: Debbie Look / ED. / (916) 319-2087 FN: 0004837

 THIRD READING  

Bill No: AB 2725

Author: Blanca Rubio (D) and Muratsuchi (D)

Amended: 8/22/24 in Senate

Vote: 21

SENATE EDUCATION COMMITTEE: 7-0, 6/5/24

AYES: Newman, Jones, Cortese, Glazer, Gonzalez, Smallwood-Cuevas, Wilk

SENATE APPROPRIATIONS COMMITTEE: 7-0, 8/15/24

AYES: Caballero, Jones, Ashby, Becker, Bradford, Seyarto, Wahab

ASSEMBLY FLOOR: 65-0, 5/9/24 (Consent) - See last page for vote

SUBJECT: Teacher credentialing: administrative services credential: occupational and physical therapists

SOURCE: California Physical Therapy Association

Occupational Therapy Association of California

DIGEST:

This bill provides that a license to practice occupational or physical therapy, meeting the basic skills requirement, and three years of experience as a school-based occupational therapist (OT) or physical therapist (PT) satisfies the requirements for a preliminary services credential with a specialization in administrative services.

Senate Floor Amendments of 8/22/24 resolve conflicts with SB 1329 (Senate Committee on Education).

ANALYSIS:

Existing law:

1. Specifies that the minimum requirements for the preliminary services credential in administrative services are all of the following:
2. Possession of one of the following:
3. A valid teaching credential requiring the possession of a baccalaureate degree and a professional preparation program including student teaching;
4. A valid designated subjects career technical education, adult education, or special subjects teaching credential, provided the candidate also possesses a baccalaureate degree;
5. A valid services credential with a specialization in pupil personnel, health, or clinical or rehabilitative services or a valid services credential authorizing service as a teacher librarian; or
6. A valid credential issued under the laws, rules, and regulations in effect on or before December 31, 1971, which authorizes the same areas as in subparagraphs (ii) and (iii).
7. Completion of a minimum of three years of successful, full-time classroom teaching experience in the public schools, including, but not limited to, service in state- or county-operated schools, or in private schools of equivalent status or three years of experience in the fields of pupil personnel, health, clinical or rehabilitative, or librarian services;
8. Completion of an entry-level program of specialized and professional preparation in administrative services approved by the Commission on Teacher Credentialing (CTC) or a one-year internship in a program of supervised training in administrative services, approved by the CTC;
9. Current employment in an administrative position after completion of professional preparation whether full or part-time, in a public school or private school of equivalent status. The CTC encourages school districts to consider the recency of preparation or professional growth in school administration as one of the criteria for employment; and
10. Specifies that a preliminary administrative services credential is valid for 5 years from the date of initial employment in an administrative position and is not renewable. (Education Code (EC) §44270)
11. Prohibits the CTC from issuing an initial credential, permit, certificate, or renewal of an emergency credential to a person to serve in the public schools unless the person has demonstrated proficiency in basic reading, writing, and mathematics skills in the English language, as specified. (EC §44252 (b))
12. Specifies that the minimum requirements for a services credential with a specialization in health are:
13. Five years, or its equivalent, of college or university education, or five years of professional preparation approved by the CTC;
14. Possession of a valid license, certificate, or registration, appropriate to the health service to be designated, issued by the California agency authorized by law to license, certificate, or register persons to practice that health service in California; and
15. Such additional requirements as may be prescribed by the CTC.
16. Authorizes the holder of a services credential with a specialization in health to perform, at all grade levels, the health service approved by the CTC as designated on the credential. Services as an audiometrist, occupational therapist, or physical therapist are not deemed health services. (EC §44267)
17. Specifies that the minimum requirements for a services credential in a specialization in clinical or rehabilitative services are:
18. A baccalaureate degree or higher degree from an institution approved by the CTC;
19. A fifth year, or its equivalent, of college or university education; and
20. Such specialized and professional preparation as the CTC may require.
21. Authorizes the holder of a services credential with a specialization in clinical or rehabilitative services to perform, at all grade levels, the service approved by the CTC as designated on the credential. This includes, but is not limited to, speech, language, and hearing services. (EC §44268)
22. Defines “related services” as transportation, and such developmental, corrective, and other supportive services (including speech-language pathology and audiology services, interpreting services, psychological services, physical and occupational therapy, recreation, including therapeutic recreation, social work services, school nurse services designed to enable an individual with exceptional needs to receive a free appropriate public education as described in the individualized education program (IEP) of the child, counseling services, including rehabilitation counseling, orientation, and mobility services, and medical services, except that such medical services are for diagnostic and evaluation purposes only) as may be required to assist an individual with exceptional needs to benefit from special education, and includes the early identification and assessment of disabling conditions in children. (EC §56363)
23. Specifies that occupational therapy services encompass occupational therapy assessment, treatment, education of, and consultation with, individuals who have been referred for occupational therapy services subsequent to diagnosis of disease or disorder (or who are receiving occupational therapy services as part of an IEP pursuant to the federal Individuals with Disabilities Education Act (IDEA). Occupational therapy assessment identifies performance abilities and limitations that are necessary for self-maintenance, learning, work, and other similar meaningful activities. Occupational therapy treatment is focused on developing, improving, or restoring functional daily living skills, compensating for and preventing dysfunction, or minimizing disability. (Business and Professions Code (BPC) §2570.2).
24. Specifies that physical therapy encompasses the physical or corrective treatment of any bodily or mental condition of any person by the use of the physical, chemical, and other properties of heat, light, water, electricity, sound, massage, and active, passive, and resistive exercise, and shall include physical therapy evaluation, treatment planning, instruction, and consultative services. The practice of physical therapy includes the promotion and maintenance of physical fitness to enhance the bodily movement related health and wellness of individuals through the use of physical therapy interventions. (BPC §2620)

This bill provides that a valid license to practice occupational or physical therapy, verification of meeting the basic skills requirement, and three years of experience as a school-based OT or PT satisfies the requirements for a preliminary services credential with a specialization in administrative services.

Comments

1. Need for the bill. According to the author, “Occupational Therapists (OTs) and Physical Therapists (PTs) have been providing related services to students in public schools since the 1970s and are the only Individuals with Disabilities Education Act (IDEA)-mandated professionals not included in a credential opportunity afforded to teachers and all other related services providers. This is based on a statute that was written at a time prior to IDEA and districts’ employment of OTs and PTs. Currently, OTs and PTs working in school systems are not authorized to obtain a base credential, thereby rendering them ineligible to pursue an administrative services credential or participate in many higher-level positions. Creating a pathway for OTs and PTs who desire to obtain an administrative services credential will allow qualified personnel an opportunity to move into administrative roles and share their unique expertise at a leadership level.”
2. The role of OTs and PTs in schools. According to the California Department of Education’s 2012 guidelines, OTs and PTs collaborate with educational teams to help students access the general education curriculum, meet state standards, pursue postsecondary education, and achieve independence after graduation. In schools, OTs focus on enhancing students' participation in daily activities such as education, play, and social interactions, while PTs work on improving motor skills, posture, mobility, and the use of assistive devices.

These therapies are often specified in a student’s IEP as related services necessary for benefiting from special education. Schools employ OTs and PTs either as classified staff or through contracts for non-classroom based roles. The California Longitudinal Pupil Achievement Data System (CALPADS) defines OTs as professionals who help students develop and maintain daily living and working skills, and PTs as professionals who treat physical impairments through methods like exercise and heat therapy. Occupational therapy services have been offered in California schools since the 1970s, with 3,000 of the 16,000 licensed OTs practicing in school settings. Similarly, physical therapy services have been provided in schools since the 1970s, with over 1,700 of the 22,000 licensed PTs working in educational environments.

1. Expanding opportunities for OTs and PTs in schools. OTs and PTs do not currently have the opportunity to earn a credential in their field. This bill would authorize OTs and PTs to be eligible for a preliminary services credential in administrative services based upon their licensure to practice occupational therapy or physical therapy.

In a report to the CTC for its February 2022 meeting, staff noted that the CTC has been asked by many in the OT and PT sector to consider the development of a credential for individuals that serve as OTs and PTs. Requests for a credential are based on a desire for individuals serving as OTs or PTs to advance in their careers, enter the certificated employee salary scale, and hold Administrative Services positions. Currently, there is no credential requirement for OTs and PTs to serve in California’s public schools. There is also no avenue for such individuals to obtain an Administrative Services Credential, as the statutory requirements for the credential require possession of a teaching or services credential issued by the CTC. The lack of a pathway for OTs and PTs who provide special education related services in the public schools prevents these educators from being able to take on certificated leadership roles, as a basic credential is required for OTs and PTs to gain access to an administrative credential under current law.

FISCAL EFFECT: Appropriation: No Fiscal Com.: Yes Local: No

According to the Senate Appropriations Committee, the Commission on Teacher Credentialing (CTC) estimates General Fund costs of $138,000 in the first year and ongoing General Fund costs of $136,000 to create resources, answer inquiries from the public and local educational agencies (LEAs), update the system, and process additional applications.

SUPPORT: (Verified 8/22/24)

California Physical Therapy Association (co-source)
Occupational Therapy Association of California (co-source)
American Federation of State, County, and Municipal Employees
Association of California School Administrators
California Federation of Teachers
California Labor Federation
California School Employees Association
California State Council of Service Employees International Union
California Teachers Association
Los Angeles County Office of Education
Physical Therapy Board of California

23 individuals

OPPOSITION: (Verified 8/22/24)

None received

ASSEMBLY FLOOR: 65-0, 5/9/24

AYES: Addis, Aguiar-Curry, Alanis, Alvarez, Arambula, Bauer-Kahan, Bennett, Berman, Boerner, Bonta, Bryan, Calderon, Juan Carrillo, Wendy Carrillo, Chen, Connolly, Davies, Dixon, Essayli, Mike Fong, Vince Fong, Friedman, Gallagher, Garcia, Gipson, Hart, Holden, Hoover, Irwin, Jackson, Jones-Sawyer, Kalra, Lackey, Lee, Lowenthal, Maienschein, McCarty, McKinnor, Muratsuchi, Ortega, Pacheco, Papan, Jim Patterson, Joe Patterson, Pellerin, Quirk-Silva, Ramos, Rendon, Reyes, Rodriguez, Blanca Rubio, Sanchez, Santiago, Soria, Ta, Valencia, Villapudua, Waldron, Ward, Weber, Wicks, Wilson, Wood, Zbur, Robert Rivas

NO VOTE RECORDED: Bains, Cervantes, Megan Dahle, Flora, Gabriel, Grayson, Haney, Low, Mathis, Stephanie Nguyen, Petrie-Norris, Luz Rivas, Schiavo, Ting, Wallis

Prepared by: Ian Johnson / ED. / (916) 651-4105

8/23/24 21:36:31

**** END ****

 THIRD READING  

Bill No: AB 2725

Author: Blanca Rubio (D) and Muratsuchi (D)

Amended: 4/15/24 in Assembly

Vote: 21

SENATE EDUCATION COMMITTEE: 7-0, 6/5/24

AYES: Newman, Jones, Cortese, Glazer, Gonzalez, Smallwood-Cuevas, Wilk

SENATE APPROPRIATIONS COMMITTEE: 7-0, 8/15/24

AYES: Caballero, Jones, Ashby, Becker, Bradford, Seyarto, Wahab

ASSEMBLY FLOOR: 65-0, 5/9/24 (Consent) - See last page for vote

SUBJECT: Teacher credentialing: administrative services credential: occupational and physical therapists

SOURCE: California Physical Therapy Association

Occupational Therapy Association of California

DIGEST:

This bill provides that a license to practice occupational or physical therapy, meeting the basic skills requirement, and three years of experience as a school-based occupational therapist (OT) or physical therapist (PT) satisfies the requirements for a preliminary services credential with a specialization in administrative services.

ANALYSIS:

Existing law:

1. Specifies that the minimum requirements for the preliminary services credential in administrative services are all of the following:
2. Possession of one of the following:
3. A valid teaching credential requiring the possession of a baccalaureate degree and a professional preparation program including student teaching;
4. A valid designated subjects career technical education, adult education, or special subjects teaching credential, provided the candidate also possesses a baccalaureate degree;
5. A valid services credential with a specialization in pupil personnel, health, or clinical or rehabilitative services or a valid services credential authorizing service as a teacher librarian; or
6. A valid credential issued under the laws, rules, and regulations in effect on or before December 31, 1971, which authorizes the same areas as in subparagraphs (ii) and (iii).
7. Completion of a minimum of three years of successful, full-time classroom teaching experience in the public schools, including, but not limited to, service in state- or county-operated schools, or in private schools of equivalent status or three years of experience in the fields of pupil personnel, health, clinical or rehabilitative, or librarian services;
8. Completion of an entry-level program of specialized and professional preparation in administrative services approved by the Commission on Teacher Credentialing (CTC) or a one-year internship in a program of supervised training in administrative services, approved by the CTC;
9. Current employment in an administrative position after completion of professional preparation whether full or part-time, in a public school or private school of equivalent status. The CTC encourages school districts to consider the recency of preparation or professional growth in school administration as one of the criteria for employment; and
10. Specifies that a preliminary administrative services credential is valid for 5 years from the date of initial employment in an administrative position and is not renewable. (Education Code (EC) 44270)
11. Prohibits the CTC from issuing an initial credential, permit, certificate, or renewal of an emergency credential to a person to serve in the public schools unless the person has demonstrated proficiency in basic reading, writing, and mathematics skills in the English language, as specified. (EC 44252 (b))
12. Specifies that the minimum requirements for a services credential with a specialization in health are:
13. Five years, or its equivalent, of college or university education, or five years of professional preparation approved by the CTC;
14. Possession of a valid license, certificate, or registration, appropriate to the health service to be designated, issued by the California agency authorized by law to license, certificate, or register persons to practice that health service in California; and
15. Such additional requirements as may be prescribed by the CTC.
16. Authorizes the holder of a services credential with a specialization in health to perform, at all grade levels, the health service approved by the CTC as designated on the credential. Services as an audiometrist, occupational therapist, or physical therapist are not deemed health services. (EC 44267)
17. Specifies that the minimum requirements for a services credential in a specialization in clinical or rehabilitative services are:
18. A baccalaureate degree or higher degree from an institution approved by the CTC;
19. A fifth year, or its equivalent, of college or university education; and
20. Such specialized and professional preparation as the CTC may require.
21. Authorizes the holder of a services credential with a specialization in clinical or rehabilitative services to perform, at all grade levels, the service approved by the CTC as designated on the credential. This includes, but is not limited to, speech, language, and hearing services. (EC 44268)
22. Defines “related services” as transportation, and such developmental, corrective, and other supportive services (including speech-language pathology and audiology services, interpreting services, psychological services, physical and occupational therapy, recreation, including therapeutic recreation, social work services, school nurse services designed to enable an individual with exceptional needs to receive a free appropriate public education as described in the individualized education program (IEP) of the child, counseling services, including rehabilitation counseling, orientation, and mobility services, and medical services, except that such medical services are for diagnostic and evaluation purposes only) as may be required to assist an individual with exceptional needs to benefit from special education, and includes the early identification and assessment of disabling conditions in children. (EC 56363)
23. Specifies that occupational therapy services encompass occupational therapy assessment, treatment, education of, and consultation with, individuals who have been referred for occupational therapy services subsequent to diagnosis of disease or disorder (or who are receiving occupational therapy services as part of an IEP pursuant to the federal Individuals with Disabilities Education Act (IDEA). Occupational therapy assessment identifies performance abilities and limitations that are necessary for self-maintenance, learning, work, and other similar meaningful activities. Occupational therapy treatment is focused on developing, improving, or restoring functional daily living skills, compensating for and preventing dysfunction, or minimizing disability. (Business and Professions Code (BPC) 2570.2).
24. Specifies that physical therapy encompasses the physical or corrective treatment of any bodily or mental condition of any person by the use of the physical, chemical, and other properties of heat, light, water, electricity, sound, massage, and active, passive, and resistive exercise, and shall include physical therapy evaluation, treatment planning, instruction, and consultative services. The practice of physical therapy includes the promotion and maintenance of physical fitness to enhance the bodily movement related health and wellness of individuals through the use of physical therapy interventions. (BPC 2620)

This bill provides that a valid license to practice occupational or physical therapy, verification of meeting the basic skills requirement, and three years of experience as a school-based OT or PT satisfies the requirements for a preliminary services credential with a specialization in administrative services.

Comments

1. Need for the bill. According to the author, “Occupational Therapists (OTs) and Physical Therapists (PTs) have been providing related services to students in public schools since the 1970s and are the only Individuals with Disabilities Education Act (IDEA)-mandated professionals not included in a credential opportunity afforded to teachers and all other related services providers. This is based on a statute that was written at a time prior to IDEA and districts’ employment of OTs and PTs. Currently, OTs and PTs working in school systems are not authorized to obtain a base credential, thereby rendering them ineligible to pursue an administrative services credential or participate in many higher-level positions. Creating a pathway for OTs and PTs who desire to obtain an administrative services credential will allow qualified personnel an opportunity to move into administrative roles and share their unique expertise at a leadership level.”
2. The role of OTs and PTs in schools. According to the California Department of Education’s 2012 guidelines, OTs and PTs collaborate with educational teams to help students access the general education curriculum, meet state standards, pursue postsecondary education, and achieve independence after graduation. In schools, OTs focus on enhancing students' participation in daily activities such as education, play, and social interactions, while PTs work on improving motor skills, posture, mobility, and the use of assistive devices.

These therapies are often specified in a student’s IEP as related services necessary for benefiting from special education. Schools employ OTs and PTs either as classified staff or through contracts for non-classroom based roles. The California Longitudinal Pupil Achievement Data System (CALPADS) defines OTs as professionals who help students develop and maintain daily living and working skills, and PTs as professionals who treat physical impairments through methods like exercise and heat therapy.

Occupational therapy services have been offered in California schools since the 1970s, with 3,000 of the 16,000 licensed OTs practicing in school settings. Similarly, physical therapy services have been provided in schools since the 1970s, with over 1,700 of the 22,000 licensed PTs working in educational environments.

1. Expanding opportunities for OTs and PTs in schools. OTs and PTs do not currently have the opportunity to earn a credential in their field. This bill would authorize OTs and PTs to be eligible for a preliminary services credential in administrative services based upon their licensure to practice occupational therapy or physical therapy.

In a report to the CTC for its February 2022 meeting, staff noted that the CTC has been asked by many in the OT and PT sector to consider the development of a credential for individuals that serve as OTs and PTs. Requests for a credential are based on a desire for individuals serving as OTs or PTs to advance in their careers, enter the certificated employee salary scale, and hold Administrative Services positions.

Currently, there is no credential requirement for OTs and PTs to serve in California’s public schools. There is also no avenue for such individuals to obtain an Administrative Services Credential, as the statutory requirements for the credential require possession of a teaching or services credential issued by the CTC. The lack of a pathway for OTs and PTs who provide special education related services in the public schools prevents these educators from being able to take on certificated leadership roles, as a basic credential is required for OTs and PTs to gain access to an administrative credential under current law.

FISCAL EFFECT: Appropriation: No Fiscal Com.: Yes Local: No

According to the Senate Appropriations Committee, the Commission on Teacher Credentialing (CTC) estimates General Fund costs of $138,000 in the first year and ongoing General Fund costs of $136,000 to create resources, answer inquiries from the public and local educational agencies (LEAs), update the system, and process additional applications.

SUPPORT: (Verified 8/15/24)

California Physical Therapy Association (co-source)
Occupational Therapy Association of California (co-source)
American Federation of State, County, and Municipal Employees
Association of California School Administrators
California Federation of Teachers
California Labor Federation
California School Employees Association
California State Council of Service Employees International Union
California Teachers Association
Los Angeles County Office of Education
Physical Therapy Board of California

23 individuals

OPPOSITION: (Verified 8/15/24)

None received

ASSEMBLY FLOOR: 65-0, 5/9/24

AYES: Addis, Aguiar-Curry, Alanis, Alvarez, Arambula, Bauer-Kahan, Bennett, Berman, Boerner, Bonta, Bryan, Calderon, Juan Carrillo, Wendy Carrillo, Chen, Connolly, Davies, Dixon, Essayli, Mike Fong, Vince Fong, Friedman, Gallagher, Garcia, Gipson, Hart, Holden, Hoover, Irwin, Jackson, Jones-Sawyer, Kalra, Lackey, Lee, Lowenthal, Maienschein, McCarty, McKinnor, Muratsuchi, Ortega, Pacheco, Papan, Jim Patterson, Joe Patterson, Pellerin, Quirk-Silva, Ramos, Rendon, Reyes, Rodriguez, Blanca Rubio, Sanchez, Santiago, Soria, Ta, Valencia, Villapudua, Waldron, Ward, Weber, Wicks, Wilson, Wood, Zbur, Robert Rivas

NO VOTE RECORDED: Bains, Cervantes, Megan Dahle, Flora, Gabriel, Grayson, Haney, Low, Mathis, Stephanie Nguyen, Petrie-Norris, Luz Rivas, Schiavo, Ting, Wallis

Prepared by: Ian Johnson / ED. / (916) 651-4105

8/18/24 9:19:31

**** END ****

SENATE COMMITTEE ON

Senator Anna Caballero, Chair

2023 - 2024 Regular Session

AB 2725 (Blanca Rubio) - Teacher credentialing: administrative services credential: occupational and physical therapists

Bill Summary:

This bill would allow school-based occupational or physical therapists to satisfy the requirements and pursue a preliminary services credential with a specialization in administrative services if they meet specific requirements.

Fiscal Impact:

The Commission on Teacher Credentialing (CTC) estimates General Fund costs of $138,000 in the first year and ongoing General Fund costs of $136,000 to create resources, answer inquiries from the public and local educational agencies (LEAs), update the system, and process additional applications.

Background:

Existing law specifies minimum requirements for the preliminary services credential in administrative services are all of the following:

1. Possession of one of the following:
2. A valid teaching credential requiring the possession of a baccalaureate degree and a professional preparation program including student teaching;
3. A valid designated subjects career technical education, adult education, or special subjects teaching credential, provided the candidate also possesses a baccalaureate degree;
4. A valid services credential with a specialization in pupil personnel, health, or clinical or rehabilitative services or a valid services credential authorizing service as a teacher librarian; or
5. A valid credential issued under the laws, rules, and regulations in effect on or before December 31, 1971, which authorizes the same areas as in subparagraphs (ii) and (iii).
6. Completion of a minimum of three years of successful, full-time classroom teaching experience in the public schools, including, but not limited to, service in state- or county-operated schools, or in private schools of equivalent status or three years of experience in the fields of pupil personnel, health, clinical or rehabilitative, or librarian services;
7. Completion of an entry-level program of specialized and professional preparation in administrative services approved by the Commission on Teacher Credentialing (CTC) or a one-year internship in a program of supervised training in administrative services, approved by the CTC;
8. Current employment in an administrative position after completion of professional preparation whether full or part-time, in a public school or private school of equivalent status. The CTC encourages school districts to consider the recency of preparation or professional growth in school administration as one of the criteria for employment; and
9. Specifies that a preliminary administrative services credential is valid for 5 years from the date of initial employment in an administrative position and is not renewable.

Proposed Law:

This bill provides that a valid license to practice occupational or physical therapy, verification of meeting the basic skills requirement, and three years of experience as a school-based occupational therapist or physical therapist satisfies the requirements for a preliminary services credential with a specialization in administrative services.

Related Legislation:

AB 2386 (Rubio, 2017-18) would have required the CTC to convene a workgroup to consider whether developing a service credential with a specialization in OT or PT is warranted, and, if it was, requirements for that credential. The bill was held in the Assembly Appropriations Committee.

Staff Comments:

Schools employ occupational and physical therapists as either classified staff or through contracts for non-classroom based roles. Occupational therapists are health professionals who support a child’s engagement and participation in educational activities, play, and social interactions. To be licensed to practice in California, occupational therapists must earn a master’s degree, pass the National Board for Certification in Occupational Therapy examination, and obtain a license through the California Board of Occupational Therapy. Physical therapists are health professionals who correct, facilitate, or adapt a child’s functional performance in motor control and coordination, functional mobility, and the use of assistive devices. To be licensed to practice in California, physical therapists must earn a master’s degree and pass national and state licensure examinations. Currently, there is no credential requirement for occupational and physical therapists to serve in public schools. Additionally, they do not currently have the opportunity to obtain a credential to hold an administrative and leadership position in school. This bill would authorize occupational and physical therapists to be eligible for a preliminary services credential in administrative services based upon their licensure to practice occupational therapy or physical therapy.

-- END --

SENATE COMMITTEE ON EDUCATION

Senator Josh Newman, Chair

2023 - 2024 Regular

Bill No: Hearing Date: June 5, 2024

Subject: .

SUMMARY

This bill provides that a license to practice occupational or physical therapy, meeting the basic skills requirement, and three years of experience as a school-based occupational therapist (OT) or physical therapist (PT) satisfies the requirements for a preliminary services credential with a specialization in administrative services.

BACKGROUND

Existing law:

1. Specifies that the minimum requirements for the preliminary services credential in administrative services are all of the following:
2. Possession of one of the following:
3. A valid teaching credential requiring the possession of a baccalaureate degree and a professional preparation program including student teaching;
4. A valid designated subjects career technical education, adult education, or special subjects teaching credential, provided the candidate also possesses a baccalaureate degree;
5. A valid services credential with a specialization in pupil personnel, health, or clinical or rehabilitative services or a valid services credential authorizing service as a teacher librarian; or
6. A valid credential issued under the laws, rules, and regulations in effect on or before December 31, 1971, which authorizes the same areas as in subparagraphs (ii) and (iii).
7. Completion of a minimum of three years of successful, full-time classroom teaching experience in the public schools, including, but not limited to, service in state- or county-operated schools, or in private schools of equivalent status or three years of experience in the fields of pupil personnel, health, clinical or rehabilitative, or librarian services;
8. Completion of an entry-level program of specialized and professional preparation in administrative services approved by the Commission on Teacher Credentialing (CTC) or a one-year internship in a program of supervised training in administrative services, approved by the CTC;
9. Current employment in an administrative position after completion of professional preparation whether full or part-time, in a public school or private school of equivalent status. The CTC encourages school districts to consider the recency of preparation or professional growth in school administration as one of the criteria for employment; and
10. Specifies that a preliminary administrative services credential is valid for 5 years from the date of initial employment in an administrative position and is not renewable. (Education Code (EC) 44270)
11. Prohibits the CTC from issuing an initial credential, permit, certificate, or renewal of an emergency credential to a person to serve in the public schools unless the person has demonstrated proficiency in basic reading, writing, and mathematics skills in the English language, as specified. (EC 44252 (b))
12. Specifies that the minimum requirements for a services credential with a specialization in health are:
13. Five years, or its equivalent, of college or university education, or five years of professional preparation approved by the CTC;
14. Possession of a valid license, certificate, or registration, appropriate to the health service to be designated, issued by the California agency authorized by law to license, certificate, or register persons to practice that health service in California; and
15. Such additional requirements as may be prescribed by the CTC.
16. Authorizes the holder of a services credential with a specialization in health to perform, at all grade levels, the health service approved by the CTC as designated on the credential. Services as an audiometrist, occupational therapist, or physical therapist are not deemed health services. (EC 44267)
17. Specifies that the minimum requirements for a services credential in a specialization in clinical or rehabilitative services are:
18. A baccalaureate degree or higher degree from an institution approved by the CTC;
19. A fifth year, or its equivalent, of college or university education; and
20. Such specialized and professional preparation as the CTC may require.
21. Authorizes the holder of a services credential with a specialization in clinical or rehabilitative services to perform, at all grade levels, the service approved by the CTC as designated on the credential. This includes, but is not limited to, speech, language, and hearing services. (EC 44268)
22. Defines “related services” as transportation, and such developmental, corrective, and other supportive services (including speech-language pathology and audiology services, interpreting services, psychological services, physical and occupational therapy, recreation, including therapeutic recreation, social work services, school nurse services designed to enable an individual with exceptional needs to receive a free appropriate public education as described in the individualized education program (IEP) of the child, counseling services, including rehabilitation counseling, orientation, and mobility services, and medical services, except that such medical services are for diagnostic and evaluation purposes only) as may be required to assist an individual with exceptional needs to benefit from special education, and includes the early identification and assessment of disabling conditions in children. (EC 56363)
23. Specifies that occupational therapy services encompass occupational therapy assessment, treatment, education of, and consultation with, individuals who have been referred for occupational therapy services subsequent to diagnosis of disease or disorder (or who are receiving occupational therapy services as part of an IEP pursuant to the federal Individuals with Disabilities Education Act (IDEA). Occupational therapy assessment identifies performance abilities and limitations that are necessary for self-maintenance, learning, work, and other similar meaningful activities. Occupational therapy treatment is focused on developing, improving, or restoring functional daily living skills, compensating for and preventing dysfunction, or minimizing disability. (Business and Professions Code (BPC) 2570.2).
24. Specifies that physical therapy encompasses the physical or corrective treatment of any bodily or mental condition of any person by the use of the physical, chemical, and other properties of heat, light, water, electricity, sound, massage, and active, passive, and resistive exercise, and shall include physical therapy evaluation, treatment planning, instruction, and consultative services. The practice of physical therapy includes the promotion and maintenance of physical fitness to enhance the bodily movement related health and wellness of individuals through the use of physical therapy interventions. (BPC 2620)

ANALYSIS

This bill provides that a valid license to practice occupational or physical therapy, verification of meeting the basic skills requirement, and three years of experience as a school-based OT or PT satisfies the requirements for a preliminary services credential with a specialization in administrative services.

STAFF COMMENTS

1. Need for the bill. According to the author, “Occupational Therapists (OTs) and Physical Therapists (PTs) have been providing related services to students in public schools since the 1970s and are the only Individuals with Disabilities Education Act (IDEA)-mandated professionals not included in a credential opportunity afforded to teachers and all other related services providers. This is based on a statute that was written at a time prior to IDEA and districts’ employment of OTs and PTs. Currently, OTs and PTs working in school systems are not authorized to obtain a base credential, thereby rendering them ineligible to pursue an administrative services credential or participate in many higher-level positions. Creating a pathway for OTs and PTs who desire to obtain an administrative services credential will allow qualified personnel an opportunity to move into administrative roles and share their unique expertise at a leadership level.”
2. The role of OTs and PTs in schools. According to the California Department of Education’s 2012 guidelines, OTs and PTs collaborate with educational teams to help students access the general education curriculum, meet state standards, pursue postsecondary education, and achieve independence after graduation. In schools, OTs focus on enhancing students' participation in daily activities such as education, play, and social interactions, while PTs work on improving motor skills, posture, mobility, and the use of assistive devices.

These therapies are often specified in a student’s i IEP as related services necessary for benefiting from special education. Schools employ OTs and PTs either as classified staff or through contracts for non-classroom based roles. The California Longitudinal Pupil Achievement Data System (CALPADS) defines OTs as professionals who help students develop and maintain daily living and working skills, and PTs as professionals who treat physical impairments through methods like exercise and heat therapy.

Occupational therapy services have been offered in California schools since the 1970s, with 3,000 of the 16,000 licensed OTs practicing in school settings. Similarly, physical therapy services have been provided in schools since the 1970s, with over 1,700 of the 22,000 licensed PTs working in educational environments.

1. The role of the CTC. The CTC is an independent governmental entity that is responsible for accrediting educator credential preparation programs, issuing credentials and permits for service in California public schools, and administering credential discipline when necessary.

Current pupil personnel services (PPS) credentials authorized by the CTC include:

• 1. School nurses;
  2. Teacher librarians;
  3. School counselors;
  4. School social workers;
  5. School psychologists;
  6. Speech language pathologists;
  7. Audiologists; and
  8. Orientation and mobility specialists.

1. Expanding opportunities for OTs and PTs in schools. OTs and PTs do not currently have the opportunity to earn a credential in their field. This bill would authorize OTs and PTs to be eligible for a preliminary services credential in administrative services based upon their licensure to practice occupational therapy or physical therapy.

In a report to the CTC for its February 2022 meeting, staff noted that the CTC has been asked by many in the OT and PT sector to consider the development of a credential for individuals that serve as OTs and PTs. Requests for a credential are based on a desire for individuals serving as OTs or PTs to advance in their careers, enter the certificated employee salary scale, and hold Administrative Services positions.

Currently, there is no credential requirement for OTs and PTs to serve in California’s public schools. There is also no avenue for such individuals to obtain an Administrative Services Credential, as the statutory requirements for the credential require possession of a teaching or services credential issued by the CTC. The lack of a pathway for OTs and PTs who provide special education related services in the public schools prevents these educators from being able to take on certificated leadership roles, as a basic credential is required for OTs and PTs to gain access to an administrative credential under current law.

1. Arguments in support. The Occupational Therapy Association of California and the California Physical Therapy Association write, in a joint letter, “OTs and PTs have been providing educationally-related services to students in public schools since the 1970s and are the only Individual with Disabilities Education Act mandated professionals who are not included in a credential opportunity afforded to other related service providers and teachers. Currently, OTs and PTs working in the school systems are not authorized to obtain a base credential, thereby rendering them ineligible to pursue an administrative service credential. This measure would allow OTs and PTs to pursue administrative and leadership positions. Their unique training and expertise can contribute meaningfully at a systems level to support access and inclusion of all students.”

“Thus, Education Code Section 44270 needs to be modified to increase professional equity for OTs and PTs and ultimately support improved outcomes for all students. Passage of AB 2725 is a crucial step in supporting children and families by providing a pathway for OTs and PTs to advance within the educational system.”

SUPPORT

California Physical Therapy Association (Co-Sponsor)
Occupational Therapy Association of California (Co-Sponsor)
Los Angeles County Office of Education

12 individuals

OPPOSITION

None received

-- END --

Date of Hearing: May 1, 2024

ASSEMBLY COMMITTEE ON APPROPRIATIONS

Buffy Wicks, Chair

ABPCA Bill Id:AB 2725

Author:(Blanca Rubio) – As Amended Ver:April 15, 2024

Urgency: No State Mandated Local Program: No Reimbursable: No

SUMMARY:

This bill creates a pathway for a school-based occupational therapist (OT) or a school-based physical therapist (PT) to obtain a credential that would allow them to pursue administrative and leadership positions in schools.

Specifically, this bill adds a valid license to practice occupational therapy or a valid license to practice physical therapy, verification of meeting a basic skills requirement, and three years of experience as a school-based OT or PT to the minimum requirements for a preliminary services credential with a specialization in administrative services.

FISCAL EFFECT:

Special Fund costs to the Commission on Teacher Credentialing (CTC) of $138,000 in the first year and $136,000 ongoing to create resources, answer inquiries from the public and LEAs, update the system, and process the additional applications.

COMMENTS:

1. Purpose. According to the author:

Currently, OTs and PTs working in school systems are not authorized to obtain a base credential, thereby rendering them ineligible to pursue an administrative services credential or participate in many higher-level positions. Creating a pathway for OTs and PTs who desire to obtain an administrative services credential will allow qualified personnel an opportunity to move into administrative roles and share their unique expertise at a leadership level.

1. Background. In schools, OTs are health professionals who support a child’s engagement and participation in educational activities, play, and social interactions. These services are mandated for students with special needs under the federal Individuals with Disabilities Act (IDEA). To be licensed to practice in California, OTs must earn a master’s degree, pass the National Board for Certification in Occupational Therapy examination, and obtain a license through the California Board of Occupational Therapy.

PTs are health professionals who correct, facilitate, or adapt a child’s functional performance in motor control and coordination, functional mobility, and the use of assistive devices. These services are mandated for students with special needs under the federal IDEA. To be licensed to practice in California, PTs must earn a master’s degree and pass national and state licensure examinations. Currently, there is no credential requirement for OTs and PTs to serve in public schools.

In order to become a school administrator, current law requires an individual to hold a credential and meet other requirements. Currently, there is no avenue for OTs and PTs serving in schools to obtain a credential to hold administrative and leadership positions, as current statute requires an individual to possess a credential issued by the CTC.

This bill allows school-based OTs and PTs to pursue an administrative services credential if they meet certain requirements. This would provide a pathway for OTs and PTs to hold administrative positions.

1. Related Legislation. AB 381 (Blanca Rubio) authorizes OTs and PTs to be eligible for a service credential with a specialization in health. The bill was held in this committee.

1. Prior Legislation. AB 2386 (Rubio), of the 2017-18 Legislative Session, would have required the CTC to convene a workgroup to consider whether developing a service credential with a specialization in OT or PT is warranted, and, if it was, requirements for that credential. The bill was held in this committee.

AB 1087 (Irwin), of the 2017-18 Legislative Session, would have required the CTC to develop a services credential with a specialization in occupational therapy and physical therapy services. The bill was referred to, but not heard by, the Assembly Education Committee.

Analysis Prepared by: Natasha Collins / APPR. / (916) 319-2081

Date of Hearing: April 10, 2024

ASSEMBLY COMMITTEE ON EDUCATION

Al Muratsuchi, Chair

ABPCA Bill Id:AB 2725 (

Author:Blanca Rubio) – As Amended Ver:March 18, 2024

SUBJECT: Teacher credentialing: administrative services credential: occupational and physical therapists

SUMMARY: Adds to the minimum requirements for a preliminary services credential with a specialization in administrative services, a valid license to practice occupational therapy or a valid license to practice physical therapy, verification of meeting a basic skills requirement as determined by the Commission on Teacher Credentialing (CTC), and three years of experience as a school-based occupational therapist (OT) or physical therapist (PT). Specifically, this bill:

1. Adds to the minimum requirements for a preliminary services credential with a specialization in administrative services, a valid license to practice occupational therapy issued by the California Board of Occupational Therapy or a valid license to practice physical therapy issued by the Physical Therapy Board of California, verification of meeting a basic skills requirement as determined by the CTC, and three years of experience as a school-based OT or PT.

EXISTING LAW:

1. Specifies that the minimum requirements for the preliminary services credential in administrative services are all of the following:
2. Possession of one of the following:
3. A valid teaching credential requiring the possession of a baccalaureate degree and a professional preparation program including student teaching;
4. A valid designated subjects career technical education, adult education, or special subjects teaching credential, provided the candidate also possesses a baccalaureate degree;
5. A valid services credential with a specialization in pupil personnel, health, or clinical or rehabilitative services or a valid services credential authorizing service as a teacher librarian; or
6. A valid credential issued under the laws, rules, and regulations in effect on or before December 31, 1971, which authorizes the same areas as in subparagraphs (ii) and (iii).
7. Completion of a minimum of three years of successful, full-time classroom teaching experience in the public schools, including, but not limited to, service in state- or county-operated schools, or in private schools of equivalent status or three years of experience in the fields of pupil personnel, health, clinical or rehabilitative, or librarian services;
8. Completion of an entry-level program of specialized and professional preparation in administrative services approved by the CTC or a one-year internship in a program of supervised training in administrative services, approved by the CTC;
9. Current employment in an administrative position after completion of professional preparation whether full or part-time, in a public school or private school of equivalent status. The CTC encourages school districts to consider the recency of preparation or professional growth in school administration as one of the criteria for employment; and
10. Specifies that a preliminary administrative services credential is valid for 5 years from the date of an initial employment in an administrative position and is not renewable. (Education Code (EC) 44270)
11. Prohibits the CTC from issuing an initial credential, permit, certificate, or renewal of an emergency credential to a person to serve in the public schools unless the person has demonstrated proficiency in basic reading, writing, and mathematics skills in the English language, as specified. (EC 44252 (b))
12. Specifies that the minimum requirements for a services credential with a specialization in health are:
13. Five years, or its equivalent, of college or university education, or five years of professional preparation approved by the CTC;
14. Possession of a valid license, certificate, or registration, appropriate to the health service to be designated, issued by the California agency authorized by law to license, certificate, or register persons to practice that health service in California; and
15. Such additional requirements as may be prescribed by the CTC.
16. Authorizes the holder of a services credential with a specialization in health to perform, at all grade levels, the health service approved by the CTC as designated on the credential. Services as an audiometrist, occupational therapist, or physical therapist are not deemed health services. (EC 44267)
17. Specifies that the minimum requirements for a services credential in a specialization in clinical or rehabilitative services are:
    1. A baccalaureate degree or higher degree from an institution approved by the CTC;
    2. A fifth year, or its equivalent, of college or university education; and
    3. Such specialized and professional preparation as the CTC may require.
18. Authorizes the holder of a services credential with a specialization in clinical or rehabilitative services to perform, at all grade levels, the service approved by the CTC as designated on the credential. This includes but is not limited to, speech, language, and hearing services. (EC 44268)
19. Defines “related services” as transportation, and such developmental, corrective, and other supportive services (including speech-language pathology and audiology services, interpreting services, psychological services, physical and occupational therapy, recreation, including therapeutic recreation, social work services, school nurse services designed to enable an individual with exceptional needs to receive a free appropriate public education as described in the individualized education program (IEP) of the child, counseling services, including rehabilitation counseling, orientation, and mobility services, and medical services, except that such medical services are for diagnostic and evaluation purposes only) as may be required to assist an individual with exceptional needs to benefit from special education, and includes the early identification and assessment of disabling conditions in children. (EC 56363)
20. Specifies that occupational therapy services encompass occupational therapy assessment, treatment, education of, and consultation with, individuals who have been referred for occupational therapy services subsequent to diagnosis of disease or disorder (or who are receiving occupational therapy services as part of an IEP pursuant to the federal Individuals with Disabilities Education Act (IDEA). Occupational therapy assessment identifies performance abilities and limitations that are necessary for self-maintenance, learning, work, and other similar meaningful activities. Occupational therapy treatment is focused on developing, improving, or restoring functional daily living skills, compensating for and preventing dysfunction, or minimizing disability. (Business and Professions Code (BPC) 2570.2).
21. Specifies that physical therapy encompasses the physical or corrective treatment of any bodily or mental condition of any person by the use of the physical, chemical, and other properties of heat, light, water, electricity, sound, massage, and active, passive, and resistive exercise, and shall include physical therapy evaluation, treatment planning, instruction, and consultative services. The practice of physical therapy includes the promotion and maintenance of physical fitness to enhance the bodily movement related health and wellness of individuals through the use of physical therapy interventions. (BPC 2620)

FISCAL EFFECT: Unknown

COMMENTS:

Need for the bill. According to the author, “Occupational Therapists (OTs) and Physical Therapists (PTs) have been providing related services to students in public schools since the 1970s and are the only Individuals with Disabilities Education Act (IDEA)-mandated professionals not included in a credential opportunity afforded to teachers and all other related services providers. This is based on a statute that was written at a time prior to IDEA and districts’ employment of OTs and PTs. Currently, OTs and PTs working in school systems are not authorized to obtain a base credential, thereby rendering them ineligible to pursue an administrative services credential or participate in many higher-level positions. Creating a pathway for OTs and PTs who desire to obtain an administrative services credential will allow qualified personnel an opportunity to move into administrative roles and share their unique expertise at a leadership level.”

Therapy services being provided in schools today. According to the California Department of Education’s (CDE) Guidelines for Occupational Therapy and Physical Therapy in California Public Schools, 2012, OTs and PTs work with the educational team to support a child’s ability to gain access to the general education curriculum, meet state standards, participate in postsecondary education, and become functional independent citizens upon graduation. In school-based practice, OTs are health professionals whose purpose in a public school setting is to support a child’s engagement and participation in daily occupations, which include activities of daily living, education, prevocational work, play, rest, leisure, and social participation. PTs are health professionals whose purpose is to correct, facilitate, or adapt the child’s functional performance in motor control and coordination, posture and balance, functional mobility, accessibility, and the use of assistive devices.

Occupational therapy and physical therapy are designated services that are sometimes identified by a student’s individualized educational program (IEP). Such services fall under the umbrella of related services and are required in order to assist an individual with exceptional needs to benefit from special education. Local educational agencies (LEAs) currently employ OTs and/or PTs as either classified staff or contracted employees to serve in non-classroom based assignments. The CDE’s California Longitudinal Pupil Achievement Data System (CALPADS) documentation defines OTs as “a healthcare professional employed by an LEA trained to treat injured, ill, or disabled patients through the therapeutic use of everyday activities. They help these patients develop, recover, improve, as well as maintain the skills needed for daily living and working.” Similarly, PTs in public schools are defined as “a health care professional employed by an LEA who is trained in the treatment of disease, injury, or deformity by physical methods such as massage, heat treatment, and exercise.”

According to the Occupational Therapy Association of California, occupational therapy services have been provided to students in public schools since the 1970s. There are currently 16,000 OTs licensed to practice in California and 3,000, or 20% of these, are estimated to practice in school-based settings.

According to the California Physical Therapy Association, physical therapy services have been provided in schools since the 1970s. There are 22,000 PT practitioners currently licensed in California and approximately 8% of these, or over 1,700, practice in school-based settings.

Licensure requirements. Historically services have been provided in public schools by OTs and PTs that are licensed by their respective boards within the California Department of Consumer Affairs – the Board of Occupational Therapy for OTs, and the Physical Therapy Board of California for PTs. Much like the teaching profession, licensed PTs are required to graduate from a professional degree program at an accredited postsecondary institution, or institutions approved by the Physical Therapy Board, complete a professional education program including academic course work and clinical internship in physical therapy, and pass the Federation of State Boards of Physical Therapy examination. The same is true for OTs, who must complete an accredited university program with a bachelor’s or master’s degree in an occupational therapy related field, including a 24-week internship and passage of the Occupational Therapist Registered (OTR) exam.

Role of the CTC. The CTC is an independent governmental entity that is responsible for accrediting educator credential preparation programs, issuing credentials and permits for service in California public schools, and administering credential discipline when necessary.

Current pupil personnel services (PPS) credentials authorized by the CTC include:

• School nurses;
• Teacher librarians;
• School counselors;
• School social workers;
• School psychologists;
• Speech language pathologists;
• Audiologists; and
• Orientation and mobility specialists.

OTs and PTs do not currently have the opportunity to earn a credential in their field. This bill would authorize OTs and PTs to be eligible for a preliminary services credential in administrative services based upon their licensure to practice occupational therapy or physical therapy.

In a report to the CTC for its February 2022 meeting, staff noted that the CTC has been asked by many in the OT and PT sector to consider the development of a credential for individuals that serve as OTs and PTs. Requests for a credential are based on a desire for individuals serving as OTs or PTs to advance in their careers, enter the certificated employee salary scale, and hold Administrative Services positions.

Currently, there is no credential requirement for OTs and PTs to serve in California’s public schools. There is also no avenue for such individuals to obtain an Administrative Services Credential, as the statutory requirements for the credential require possession of a teaching or services credential issued by the CTC. The lack of a pathway for OTs and PTs who provide special education related services in the public schools prevents these educators from being able to take on certificated leadership roles, as a basic credential is required for OTs and PTs to gain access to an administrative credential under current law.

Recommended Committee Amendments. Staff recommends that the bill be amended as follows:

1. Use a cross-reference to the basic skills requirement in the Code rather than referring to the discretion of the CTC.

Arguments in support. The Occupational Therapy Association of California and the California Physical Therapy Association write, in a joint letter, “OTs and PTs have been providing educationally-related services to students in public schools since the 1970s and are the only Individual with Disabilities Education Act mandated professionals who are not included in a credential opportunity afforded to other related service providers and teachers. Currently, OTs and PTs working in the school systems are not authorized to obtain a base credential, thereby rendering them ineligible to pursue an administrative service credential. This measure would allow OTs and PTs to pursue administrative and leadership positions. Their unique training and expertise can contribute meaningfully at a systems level to support access and inclusion of all students.

Thus, Education Code Section 44270 needs to be modified to increase professional equity for OTs and PTs and ultimately support improved outcomes for all students. Passage of AB 2725 is a crucial step in supporting children and families by providing a pathway for OTs and PTs to advance within the educational system.”

Related legislation. AB 381 (Blanca Rubio) of the 2023-24 Session would have authorized OTs and PTs to be eligible for the services credential with a specialization in health. This bill was held in the Assembly Appropriations Committee.

AB 2386 (Rubio) of the 2017-18 Session would have required the CTC to convene a workgroup to consider whether developing a service credential with a specialization in OT or PT is warranted, and, if it is, requirements for that credential. It required the CTC to provide a report on its findings by January 1, 2020. This bill was held in the Assembly Appropriations Committee.

AB 1087 (Irwin) of the 2017-18 Session would have required the CTC to develop a services credential with a specialization in OT and PT services. This bill was held in the Assembly Education Committee.

AB 2221 (Bloom), Chapter 490, Statutes of 2018, makes numerous changes to the Occupational Therapy Practice Act, including definitions relating to scope of practice OTs and occupational therapy assistants (OTAs), supervision ratios and duties, methods the California Board of Occupational Therapy (CBOT) may verify advanced practice requirements, and requirements related to the use of doctoral degree titles.

REGISTERED SUPPORT / OPPOSITION:

Support

American Federation of State, County and Municipal Employees

California Federation of Teachers

California Labor Federation

California Physical Therapy Association

California School Employees Association

California State Council of The Service Employees International Union

Occupational Therapy Association of California

40 Individuals

Opposition

None on file

Analysis Prepared by: Debbie Look / ED. / (916) 319-2087