Existing law requires the Commission on Teacher Credentialing to 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.

This bill would provide that the possession of a valid license to practice occupational therapy or physical therapy, as specified, may be used to satisfy the above-described credential requirement, but a preliminary services credential issued to an individual based, in part, on one of those licenses would not authorize the supervision or evaluation of teachers, except under specified circumstances.

Under existing law, another of the minimum requirements for a preliminary services credential with a specialization in administrative services is the completion of 3 years of successful, full-time experience in specified teaching and school related services.

The bill would increase the required minimum experience for this credential to 5 years and would add experience as a school-based occupational therapist or physical therapist as a means to satisfy that requirement, but would authorize a school district, county office of education, or charter school to request a waiver of up to 2 years of that experience for a candidate who meets specified criteria.

This bill would incorporate additional changes to Section 44270 of the Education Code proposed by AB 959 to be operative only if this bill and AB 959 are enacted and this bill is enacted last.

Existing law requires the Commission on Teacher Credentialing to 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.

This bill would provide that the possession of a valid license to practice occupational therapy or physical therapy, as specified, may be used to satisfy the above-described credential requirement, but a preliminary services credential issued to an individual based, in part, on one of those licenses would not authorize the supervision or evaluation of teachers, except under specified circumstances.

Under existing law, another of the minimum requirements for a preliminary services credential with a specialization in administrative services is the completion of 3 years of successful, full-time experience in specified teaching and school related services.

The bill would increase the required minimum experience for this credential to 5 years and would add experience as a school-based occupational therapist or physical therapist as a means to satisfy that requirement, but would authorize a school district, county office of education, or charter school to request a waiver of up to 2 years of that experience for a candidate who meets specified criteria.

This bill would incorporate additional changes to Section 44270 of the Education Code proposed by AB 959 to be operative only if this bill and AB 959 are enacted and this bill is enacted last.

Existing law requires the Commission on Teacher Credentialing to 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.

This bill would provide that the possession of a valid license to practice occupational therapy or physical therapy, as specified, may be used to satisfy the above-described credential requirement, but a preliminary services credential issued to an individual based, in part, on one of those licenses would not authorize the supervision or evaluation of teachers, except under specified circumstances.

Under existing law, another of the minimum requirements for a preliminary services credential with a specialization in administrative services is the completion of 3 years of successful, full-time experience in specified teaching and school related services.

The bill would increase the required minimum experience for this credential to 5 years and would add experience as a school-based occupational therapist or physical therapist as a means to satisfy that requirement, but would authorize a school district, county office of education, or charter school to request a waiver of up to 2 years of that experience for a candidate who meets specified criteria.

Existing law requires the Commission on Teacher Credentialing to 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 certain work experience, as provided. credentials.

This bill would provide that the possession of a valid license to practice occupational therapy or physical therapy and verification of meeting a basic skills requirement, therapy, as specified, and 3 years of experience as a school-based occupational therapist or physical therapist may be used to satisfy the above-described respective requirements for credential requirement, but a preliminary services credential with a specialization in administrative services, as provided. issued to an individual based, in part, on one of those licenses would not authorize the supervision or evaluation of teachers, except under specified circumstances.

Existing law requires the Commission on Teacher Credentialing to 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 certain work 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 the above-described respective requirements for a preliminary services credential with a specialization in administrative services, as provided.

 THIRD READING  

Bill No: AB 1009

Author: Blanca Rubio (D)

Amended: 9/4/25 in Senate

Vote: 21

SENATE EDUCATION COMMITTEE: 6-0, 6/11/25

AYES: Pérez, Ochoa Bogh, Cabaldon, Choi, Cortese, Laird

NO VOTE RECORDED: Gonzalez

SENATE APPROPRIATIONS COMMITTEE: 7-0, 8/29/25

AYES: Caballero, Seyarto, Cabaldon, Dahle, Grayson, Richardson, Wahab

ASSEMBLY FLOOR: 69-0, 5/8/25 (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 authorizes occupational therapists (OTs) and physical therapists (PTs) who meet specified requirements to be eligible for a preliminary administrative services credential.

Senate Floor amendments of 9/4/25 incorporate chaptering-out language to avoid conflicts with AB 959 (Hadwick, 2025). Specifically, the amendments provide that the changes made by this bill will only become operative if both this bill and AB 959 are enacted and this bill is enacted last.

ANALYSIS:

Existing law:

1. Specifies the following minimum requirements for obtaining a preliminary administrative services credential. (Education Code § 44270)
2. Possession of one of the following:
   1. A valid teaching credential, including student teaching.
   2. A valid designated subjects credential in career technical education, adult education, or special subjects with a bachelor’s degree.
   3. A valid services credential in pupil personnel, health, clinical or rehabilitative services, or as a teacher librarian.
   4. A credential issued prior to December 31, 1971, authorizing services similar to those above.
3. Completion of three years of successful full-time experience in classroom teaching, pupil personnel, health, clinical or rehabilitative services, or as a librarian.
4. Completion of an approved specialized administrative preparation program or internship.
5. Current employment in an administrative role post-preparation.
6. Requires that a preliminary administrative credential is valid for five years and nonrenewable.

This bill:

1. Adds a valid occupational therapy license (issued by the California Board of Occupational Therapy) or physical therapy license (issued by the Physical Therapy Board of California) as a pathway to qualify for a preliminary administrative services credential.
2. Specifies that a preliminary administrative services credential issued based on this bill shall not authorize the supervision or evaluation of teachers unless the employing local educational agency (LEA) makes a determination, as specified.
3. Allows five years of experience as a school-based OT or PT to satisfy the existing experience requirement for a preliminary administrative services credential.
4. Authorizes an LEA to request a waiver of up to two years of the experience required for specified candidates.
5. Makes various changes to avoid conflicts with AB 959 (Hadwick, 2025). Specifically, the amendments provide that the changes made by this bill will only become operative if both this bill and AB 959 are enacted and this bill is enacted last.

Comments

1. Need for this 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. Historical Credentialing Gap. This bill addresses a credentialing gap arising from historical frameworks that predate widespread school-based employment of OTs and PTs. While these professionals are mandated by federal IDEA law to provide specialized support services, unlike similarly situated professionals—such as school psychologists, nurses, counselors, and speech-language pathologists—they remain excluded from credential eligibility. Establishing an administrative credential pathway aligns the credentialing opportunities for OTs and PTs with other specialized service providers already eligible for administrative roles.

Under current law, there is no credential required or offered specifically for OTs and PTs to provide mandated related services in schools. Consequently, OTs and PTs cannot meet the current statutory credential requirement to pursue administrative services credentials, thereby limiting their career advancement into formal leadership roles.

1. Credential Requirement vs. Credential Opportunity. The Governor’s prior veto message on AB 2725 (Rubio) of 2024, a substantively similar measure, raised an important distinction: there is currently no explicit state requirement that OTs and PTs must hold an administrative services credential to assume supervisory or administrative roles in school districts. School districts retain local discretion to create supervisory roles or assign administrative duties to these professionals based on human resources policies or collective bargaining agreements. However, this flexibility has not resulted in uniform professional recognition, equitable salary schedules, or clear pathways to certificated administrative positions for OTs and PTs across the state.
2. Professional Equity and Career Mobility. Given its context, this bill appears primarily motivated by goals of professional equity and career advancement. By providing OTs and PTs access to the administrative services credential, this bill seeks to enable these professionals to advance into certificated leadership roles, fostering greater parity with other related-service providers. This change may also have ancillary benefits, such as improved retention and recruitment of highly skilled therapists within the public education system, ultimately enhancing student support through more diversified administrative expertise.
3. Addressing Prior Legislative Concerns. Although this bill seeks to address professional equity, the Governor’s veto of the substantively similar AB 2725 (Rubio of 2024) expressed skepticism about the need for a legislated statewide credential pathway for OTs and PTs. The veto message emphasized that there is no state requirement for these professionals to hold an administrative services credential in order to serve in supervisory roles, and encouraged the Commission on Teacher Credentialing (CTC) to develop distinct pathways for license holders without traditional teacher preparation backgrounds.

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

According to the Senate Appropriations Committee, the CTC estimates General Fund costs of $127,000 each year for 1.0 position to create resources, provide technical assistance to local educational agencies (LEAs) and the public, and process additional applications.

SUPPORT: (Verified 9/4/25)

California Physical Therapy Association (co-source)
Occupational Therapy Association of California (co-source)
Association of California School Administrators
California School Employees Association
California State Council of Service Employees International Union
National Board for Certification in Occupational Therapy
Physical Therapy Board of California
San Francisco Unified School District
SELPA Administrators of California

OPPOSITION: (Verified 9/4/25)

None received

ASSEMBLY FLOOR: 69-0, 5/8/25

AYES: Addis, Aguiar-Curry, Ahrens, Alanis, Alvarez, Ávila Farías, Bains, Bauer-Kahan, Bennett, Berman, Bonta, Bryan, Calderon, Caloza, Castillo, Chen, Connolly, Davies, DeMaio, Dixon, Elhawary, Ellis, Fong, Gabriel, Garcia, Gipson, Mark González, Hadwick, Haney, Harabedian, Hart, Hoover, Jackson, Kalra, Krell, Lackey, Lee, Lowenthal, Macedo, McKinnor, Muratsuchi, Nguyen, Ortega, Pacheco, Papan, Patel, Patterson, Pellerin, Petrie-Norris, Quirk-Silva, Ramos, Ransom, Michelle Rodriguez, Rogers, Blanca Rubio, Schiavo, Schultz, Sharp-Collins, Solache, Soria, Stefani, Ta, Tangipa, Valencia, Ward, Wicks, Wilson, Zbur, Rivas

NO VOTE RECORDED: Arambula, Boerner, Carrillo, Flora, Gallagher, Jeff Gonzalez, Irwin, Celeste Rodriguez, Sanchez, Wallis

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

8/16/26 14:34:17

**** END ****

CONCURRENCE IN SENATE AMENDMENTS

CSA1 Bill Id:AB 1009

Author:(Blanca Rubio)

As Amended Ver:September 4, 2025

Majority vote

SUMMARY

Authorizes occupational therapists (OTs) and physical therapists (PTs) to be eligible for a preliminary administrative services credential.

Senate Amendments

1. Modify the proposed qualifications for OTs and PTs to meet the minimum requirements for a preliminary administrative services credential, as specified.
2. Increase the minimum experience requirement from three years to five years.
3. Authorize a waiver of up to two years of the minimum experience requirement.
4. Specify that a preliminary administrative services credential does not authorize the supervision or evaluation of teachers unless the employing local educational agency (LEA) determines that the individual possesses additional educational or job experience, leadership training, or an advanced degree that qualifies the individual for the responsibilities of a school administrator.
5. Incorporate additional changes proposed by AB 959 (Hadwick) of this Session to be operative only if this bill and AB 959 are enacted and this bill is enacted last.

COMMENTS

OTs and PTs do not currently have the opportunity to earn an administrative credential. 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 who 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 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.

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."

Arguments in Support

The Occupational Therapy Association of California and the California Physical Therapy Association write, "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 teachers and other related services providers. 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.

AB 1009 modifies current law to increase professional equity for OTs and PTs by allowing them to qualify to obtain an administrative services credential. Passage of AB 1009 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 $127,000 each year for 1.0 position to create resources, provide technical assistance to local educational agencies (LEAs) and the public, and process additional applications."

VOTES:

ASM EDUCATION: 9-0-0

YES: Muratsuchi, Hoover, Addis, Alvarez, Bonta, Castillo, Garcia, Lowenthal, Patel

ASM APPROPRIATIONS: 14-0-1

YES: Wicks, Sanchez, Arambula, Calderon, Caloza, Dixon, Elhawary, Fong, Mark González, Hart, Pacheco, Solache, Ta, Alanis

ABS, ABST OR NV: Pellerin

ASSEMBLY FLOOR: 69-0-10

YES: Addis, Aguiar-Curry, Ahrens, Alanis, Alvarez, Ávila Farías, Bains, Bauer-Kahan, Bennett, Berman, Bonta, Bryan, Calderon, Caloza, Castillo, Chen, Connolly, Davies, DeMaio, Dixon, Elhawary, Ellis, Fong, Gabriel, Garcia, Gipson, Mark González, Hadwick, Haney, Harabedian, Hart, Hoover, Jackson, Kalra, Krell, Lackey, Lee, Lowenthal, Macedo, McKinnor, Muratsuchi, Nguyen, Ortega, Pacheco, Papan, Patel, Patterson, Pellerin, Petrie-Norris, Quirk-Silva, Ramos, Ransom, Michelle Rodriguez, Rogers, Blanca Rubio, Schiavo, Schultz, Sharp-Collins, Solache, Soria, Stefani, Ta, Tangipa, Valencia, Ward, Wicks, Wilson, Zbur, Rivas

ABS, ABST OR NV: Arambula, Boerner, Carrillo, Flora, Gallagher, Jeff Gonzalez, Irwin, Celeste Rodriguez, Sanchez, Wallis

UPDATED

VERSION: September 4, 2025

CONSULTANT: Debbie Look / ED. / (916) 319-2087 FN: 0002053

 THIRD READING  

Bill No: AB 1009

Author: Blanca Rubio (D)

Amended: 9/4/25 in Senate

Vote: 21

SENATE EDUCATION COMMITTEE: 6-0, 6/11/25

AYES: Pérez, Ochoa Bogh, Cabaldon, Choi, Cortese, Laird

NO VOTE RECORDED: Gonzalez

SENATE APPROPRIATIONS COMMITTEE: 7-0, 8/29/25

AYES: Caballero, Seyarto, Cabaldon, Dahle, Grayson, Richardson, Wahab

ASSEMBLY FLOOR: 69-0, 5/8/25 (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 authorizes occupational therapists (OTs) and physical therapists (PTs) who meet specified requirements to be eligible for a preliminary administrative services credential.

Senate Floor amendments of 9/4/25 incorporate chaptering-out language to avoid conflicts with AB 959 (Hadwick, 2025). Specifically, the amendments provide that the changes made by this bill will only become operative if both this bill and AB 959 are enacted and this bill is enacted last.

ANALYSIS:

Existing law:

1. Specifies the following minimum requirements for obtaining a preliminary administrative services credential. (Education Code § 44270)
2. Possession of one of the following:
   1. A valid teaching credential, including student teaching.
   2. A valid designated subjects credential in career technical education, adult education, or special subjects with a bachelor’s degree.
   3. A valid services credential in pupil personnel, health, clinical or rehabilitative services, or as a teacher librarian.
   4. A credential issued prior to December 31, 1971, authorizing services similar to those above.
3. Completion of three years of successful full-time experience in classroom teaching, pupil personnel, health, clinical or rehabilitative services, or as a librarian.
4. Completion of an approved specialized administrative preparation program or internship.
5. Current employment in an administrative role post-preparation.
6. Requires that a preliminary administrative credential is valid for five years and nonrenewable.

This bill:

1. Adds a valid occupational therapy license (issued by the California Board of Occupational Therapy) or physical therapy license (issued by the Physical Therapy Board of California) as a pathway to qualify for a preliminary administrative services credential.
2. Specifies that a preliminary administrative services credential issued based on this bill shall not authorize the supervision or evaluation of teachers unless the employing local educational agency (LEA) makes a determination, as specified.
3. Allows five years of experience as a school-based OT or PT to satisfy the existing experience requirement for a preliminary administrative services credential.
4. Authorizes an LEA to request a waiver of up to two years of the experience required for specified candidates.
5. Makes various changes to avoid conflicts with AB 959 (Hadwick, 2025). Specifically, the amendments provide that the changes made by this bill will only become operative if both this bill and AB 959 are enacted and this bill is enacted last.

Comments

1. Need for this 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. Historical Credentialing Gap. This bill addresses a credentialing gap arising from historical frameworks that predate widespread school-based employment of OTs and PTs. While these professionals are mandated by federal IDEA law to provide specialized support services, unlike similarly situated professionals—such as school psychologists, nurses, counselors, and speech-language pathologists—they remain excluded from credential eligibility. Establishing an administrative credential pathway aligns the credentialing opportunities for OTs and PTs with other specialized service providers already eligible for administrative roles.

Under current law, there is no credential required or offered specifically for OTs and PTs to provide mandated related services in schools. Consequently, OTs and PTs cannot meet the current statutory credential requirement to pursue administrative services credentials, thereby limiting their career advancement into formal leadership roles.

1. Credential Requirement vs. Credential Opportunity. The Governor’s prior veto message on AB 2725 (Rubio) of 2024, a substantively similar measure, raised an important distinction: there is currently no explicit state requirement that OTs and PTs must hold an administrative services credential to assume supervisory or administrative roles in school districts. School districts retain local discretion to create supervisory roles or assign administrative duties to these professionals based on human resources policies or collective bargaining agreements. However, this flexibility has not resulted in uniform professional recognition, equitable salary schedules, or clear pathways to certificated administrative positions for OTs and PTs across the state.
2. Professional Equity and Career Mobility. Given its context, this bill appears primarily motivated by goals of professional equity and career advancement. By providing OTs and PTs access to the administrative services credential, this bill seeks to enable these professionals to advance into certificated leadership roles, fostering greater parity with other related-service providers. This change may also have ancillary benefits, such as improved retention and recruitment of highly skilled therapists within the public education system, ultimately enhancing student support through more diversified administrative expertise.
3. Addressing Prior Legislative Concerns. Although this bill seeks to address professional equity, the Governor’s veto of the substantively similar AB 2725 (Rubio of 2024) expressed skepticism about the need for a legislated statewide credential pathway for OTs and PTs. The veto message emphasized that there is no state requirement for these professionals to hold an administrative services credential in order to serve in supervisory roles, and encouraged the Commission on Teacher Credentialing (CTC) to develop distinct pathways for license holders without traditional teacher preparation backgrounds.

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

According to the Senate Appropriations Committee, the CTC estimates General Fund costs of $127,000 each year for 1.0 position to create resources, provide technical assistance to local educational agencies (LEAs) and the public, and process additional applications.

SUPPORT: (Verified 9/4/25)

California Physical Therapy Association (co-source)
Occupational Therapy Association of California (co-source)
Association of California School Administrators
California School Employees Association
California State Council of Service Employees International Union
National Board for Certification in Occupational Therapy
Physical Therapy Board of California
San Francisco Unified School District
SELPA Administrators of California

OPPOSITION: (Verified 9/4/25)

None received

ASSEMBLY FLOOR: 69-0, 5/8/25

AYES: Addis, Aguiar-Curry, Ahrens, Alanis, Alvarez, Ávila Farías, Bains, Bauer-Kahan, Bennett, Berman, Bonta, Bryan, Calderon, Caloza, Castillo, Chen, Connolly, Davies, DeMaio, Dixon, Elhawary, Ellis, Fong, Gabriel, Garcia, Gipson, Mark González, Hadwick, Haney, Harabedian, Hart, Hoover, Jackson, Kalra, Krell, Lackey, Lee, Lowenthal, Macedo, McKinnor, Muratsuchi, Nguyen, Ortega, Pacheco, Papan, Patel, Patterson, Pellerin, Petrie-Norris, Quirk-Silva, Ramos, Ransom, Michelle Rodriguez, Rogers, Blanca Rubio, Schiavo, Schultz, Sharp-Collins, Solache, Soria, Stefani, Ta, Tangipa, Valencia, Ward, Wicks, Wilson, Zbur, Rivas

NO VOTE RECORDED: Arambula, Boerner, Carrillo, Flora, Gallagher, Jeff Gonzalez, Irwin, Celeste Rodriguez, Sanchez, Wallis

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

9/8/25 21:29:519/8/25 21:29:51

**** END ****

 THIRD READING  

Bill No: AB 1009

Author: Blanca Rubio (D)

Amended: 8/29/25 in Senate

Vote: 21

SENATE EDUCATION COMMITTEE: 6-0, 6/11/25

AYES: Pérez, Ochoa Bogh, Cabaldon, Choi, Cortese, Laird

NO VOTE RECORDED: Gonzalez

SENATE APPROPRIATIONS COMMITTEE: 7-0, 8/29/25

AYES: Caballero, Seyarto, Cabaldon, Dahle, Grayson, Richardson, Wahab

ASSEMBLY FLOOR: 69-0, 5/8/25 (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 authorizes occupational therapists (OTs) and physical therapists (PTs) who meet specified requirements to be eligible for a preliminary administrative services credential.

ANALYSIS:

Existing law:

1. Specifies the following minimum requirements for obtaining a preliminary administrative services credential. (Education Code § 44270)
2. Possession of one of the following:
   1. A valid teaching credential, including student teaching.
   2. A valid designated subjects credential in career technical education, adult education, or special subjects with a bachelor’s degree.
   3. A valid services credential in pupil personnel, health, clinical or rehabilitative services, or as a teacher librarian.
   4. A credential issued prior to December 31, 1971, authorizing services similar to those above.
3. Completion of three years of successful full-time experience in classroom teaching, pupil personnel, health, clinical or rehabilitative services, or as a librarian.
4. Completion of an approved specialized administrative preparation program or internship.
5. Current employment in an administrative role post-preparation.
6. Requires that a preliminary administrative credential is valid for five years and nonrenewable.

This bill:

1. Adds a valid occupational therapy license (issued by the California Board of Occupational Therapy) or physical therapy license (issued by the Physical Therapy Board of California) as a pathway to qualify for a preliminary administrative services credential.
2. Specifies that a preliminary administrative services credential issued based on this bill shall not authorize the supervision or evaluation of teachers unless the employing local educational agency (LEA) makes a determination, as specified.
3. Allows five years of experience as a school-based OT or PT to satisfy the existing experience requirement for a preliminary administrative services credential.
4. Authorizes an LEA to request a waiver of up to two years of the experience required for specified candidates.

Comments

1. Need for this 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. Historical Credentialing Gap. This bill addresses a credentialing gap arising from historical frameworks that predate widespread school-based employment of OTs and PTs. While these professionals are mandated by federal IDEA law to provide specialized support services, unlike similarly situated professionals—such as school psychologists, nurses, counselors, and speech-language pathologists—they remain excluded from credential eligibility. Establishing an administrative credential pathway aligns the credentialing opportunities for OTs and PTs with other specialized service providers already eligible for administrative roles.

Under current law, there is no credential required or offered specifically for OTs and PTs to provide mandated related services in schools. Consequently, OTs and PTs cannot meet the current statutory credential requirement to pursue administrative services credentials, thereby limiting their career advancement into formal leadership roles.

1. Credential Requirement vs. Credential Opportunity. The Governor’s prior veto message on AB 2725 (Rubio, 2024), a substantively similar measure, raised an important distinction: there is currently no explicit state requirement that OTs and PTs must hold an administrative services credential to assume supervisory or administrative roles in school districts. School districts retain local discretion to create supervisory roles or assign administrative duties to these professionals based on human resources policies or collective bargaining agreements. However, this flexibility has not resulted in uniform professional recognition, equitable salary schedules, or clear pathways to certificated administrative positions for OTs and PTs across the state.
2. Professional Equity and Career Mobility. Given its context, this bill appears primarily motivated by goals of professional equity and career advancement. By providing OTs and PTs access to the administrative services credential, this bill seeks to enable these professionals to advance into certificated leadership roles, fostering greater parity with other related-service providers. This change may also have ancillary benefits, such as improved retention and recruitment of highly skilled therapists within the public education system, ultimately enhancing student support through more diversified administrative expertise.
3. Addressing Prior Legislative Concerns. Although this bill seeks to address professional equity, the Governor’s veto of the substantively similar AB 2725 (Rubio, 2024) expressed skepticism about the need for a legislated statewide credential pathway for OTs and PTs. The veto message emphasized that there is no state requirement for these professionals to hold an administrative services credential in order to serve in supervisory roles, and encouraged the Commission on Teacher Credentialing (CTC) to develop distinct pathways for license holders without traditional teacher preparation backgrounds.

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

According to the Senate Appropriations Committee, the CTC estimates General Fund costs of $127,000 each year for 1.0 position to create resources, provide technical assistance to local educational agencies (LEAs) and the public, and process additional applications.

SUPPORT: (Verified 8/29/25)

California Physical Therapy Association (Co-Source)
Occupational Therapy Association of California (Co-Source)
Association of California School Administrators
California School Employees Association
California State Council of Service Employees International Union
National Board for Certification in Occupational Therapy
Physical Therapy Board of California
San Francisco Unified School District
SELPA Administrators of California

OPPOSITION: (Verified 8/29/25)

None received

ASSEMBLY FLOOR: 69-0, 5/8/25

AYES: Addis, Aguiar-Curry, Ahrens, Alanis, Alvarez, Ávila Farías, Bains, Bauer-Kahan, Bennett, Berman, Bonta, Bryan, Calderon, Caloza, Castillo, Chen, Connolly, Davies, DeMaio, Dixon, Elhawary, Ellis, Fong, Gabriel, Garcia, Gipson, Mark González, Hadwick, Haney, Harabedian, Hart, Hoover, Jackson, Kalra, Krell, Lackey, Lee, Lowenthal, Macedo, McKinnor, Muratsuchi, Nguyen, Ortega, Pacheco, Papan, Patel, Patterson, Pellerin, Petrie-Norris, Quirk-Silva, Ramos, Ransom, Michelle Rodriguez, Rogers, Blanca Rubio, Schiavo, Schultz, Sharp-Collins, Solache, Soria, Stefani, Ta, Tangipa, Valencia, Ward, Wicks, Wilson, Zbur, Rivas

NO VOTE RECORDED: Arambula, Boerner, Carrillo, Flora, Gallagher, Jeff Gonzalez, Irwin, Celeste Rodriguez, Sanchez, Wallis

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

9/2/25 18:13:16

**** END ****

SENATE COMMITTEE ON APPROPRIATIONS

Senator Anna Caballero, Chair

2025 - 2026 Regular Session

AB 1009 (Blanca Rubio) - Teacher credentialing: administrative services credential: occupational and physical therapists

Bill Summary:

This bill authorizes occupational therapists (OTs) and physical therapists (PTs) to be eligible for a preliminary administrative services credential.

*********** ANALYSIS ADDENDUM – SUSPENSE FILE ***********

The following information is revised to reflect amendments

adopted by the committee on August 29, 2025

Fiscal Impact:

The CTC estimates General Fund costs of $127,000 each year for 1.0 position to create resources, provide technical assistance to local educational agencies (LEAs) and the public, and process additional applications.

Author Amendments:

Modify the proposed qualifications for occupational and physical therapists to meet the minimum requirements for a preliminary administrative services credential, as specified, including an increase to the minimum experience requirement; authorize a waiver of up to two years of the minimum experience requirement; and specify that a preliminary administrative services credential shall not authorize the supervision or evaluation of teachers except under specified circumstances.

-- END --

SENATE COMMITTEE ON

Senator Anna Caballero, Chair

2025 - 2026 Regular Session

AB 1009 (Blanca Rubio) - Teacher credentialing: administrative services credential: occupational and physical therapists

Bill Summary:

This bill authorizes occupational therapists (OTs) and physical therapists (PTs) to be eligible for a preliminary administrative services credential.

Fiscal Impact:

The CTC estimates General Fund costs of $127,000 each year for 1.0 position to create resources, provide technical assistance to local educational agencies (LEAs) and the public, and process additional applications.

Background:

Existing law specifies the following minimum requirements for obtaining a preliminary administrative services credential:

1. Possession of one of the following: a valid teaching credential, including student teaching; a valid designated subjects credential in career technical education, adult education, or special subjects with a bachelor’s degree; a valid services credential in pupil personnel, health, clinical or rehabilitative services, or as a teacher librarian; or a credential issued prior to December 31, 1971, authorizing services similar to those above.
2. Completion of three years of successful full-time experience in classroom teaching, pupil personnel, health, clinical or rehabilitative services, or as a librarian.
3. Completion of an approved specialized administrative preparation program or internship.
4. Current employment in an administrative role post-preparation.

Existing law requires that a preliminary administrative credential is valid for five years and nonrenewable.

Proposed Law:

This bill adds a valid occupational therapy license issued by the California Board of Occupational Therapy or a valid license to practice physical therapy license issued by the Physical Therapy Board of California and verification of basic skills as a qualification to meet the minimum requirements for a preliminary administrative services credential. The bill also allows three years of experience as a school-based OT or PT to satisfy the existing experience requirement for a preliminary administrative services credential.

Related Legislation:

AB 2725 (Rubio, 2024), similar to this bill, would have allowed school-based occupational or physical therapists to satisfy the requirements and pursue a preliminary services credential with a specialization in administrative services if they met specific requirements. The bill was vetoed by the Governor with the following 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.”

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 Sasha Renée Pérez, Chair

2025 - 2026 Regular

Bill No: AB 1009 Hearing Date: June 11, 2025

Subject: Teacher credentialing: administrative services credential: occupational and physical therapists.

SUMMARY

This bill authorizes occupational therapists (OTs) and physical therapists (PTs) who meet specified requirements to be eligible for a preliminary administrative services credential.

BACKGROUND

Existing law specifies the following minimum requirements for obtaining a preliminary administrative services credential. (Education Code §44270)

1. Possession of one of the following:
   1. A valid teaching credential, including student teaching.
   2. A valid designated subjects credential in career technical education, adult education, or special subjects with a bachelor’s degree.
   3. A valid services credential in pupil personnel, health, clinical or rehabilitative services, or as a teacher librarian.
   4. A credential issued prior to December 31, 1971, authorizing services similar to those above.
2. Completion of three years of successful full-time experience in classroom teaching, pupil personnel, health, clinical or rehabilitative services, or as a librarian.
3. Completion of an approved specialized administrative preparation program or internship.
4. Current employment in an administrative role post-preparation.

Existing law requires that a preliminary administrative credential is valid for five years and nonrenewable.

Under current law, there is no credential required or offered specifically for OTs and PTs to provide mandated related services in schools. Consequently, OTs and PTs cannot meet the current statutory credential requirement to pursue administrative services credentials, thereby limiting their career advancement into formal leadership roles.

ANALYSIS

This bill:

1. Adds a valid occupational therapy license (issued by the California Board of Occupational Therapy) or physical therapy license (issued by the Physical Therapy Board of California) and verification of basic skills as a pathway to qualify for a preliminary administrative services credential.
2. Allows three years of experience as a school-based OT or PT to satisfy the existing experience requirement for a preliminary administrative services credential.

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. Historical Credentialing Gap. This bill addresses a credentialing gap arising from historical frameworks that predate widespread school-based employment of OTs and PTs. While these professionals are mandated by federal IDEA law to provide specialized support services, unlike similarly situated professionals—such as school psychologists, nurses, counselors, and speech-language pathologists—they remain excluded from credential eligibility. Establishing an administrative credential pathway aligns the credentialing opportunities for OTs and PTs with other specialized service providers already eligible for administrative roles.
3. Credential Requirement vs. Credential Opportunity. The Governor’s prior veto message on AB 2725 (Rubio, 2024), a substantively similar measure, raised an important distinction: there is currently no explicit state requirement that OTs and PTs must hold an administrative services credential to assume supervisory or administrative roles in school districts. School districts retain local discretion to create supervisory roles or assign administrative duties to these professionals based on human resources policies or collective bargaining agreements. However, this flexibility has not resulted in uniform professional recognition, equitable salary schedules, or clear pathways to certificated administrative positions for OTs and PTs across the state.
4. Professional Equity and Career Mobility. Given its context, this bill appears primarily motivated by goals of professional equity and career advancement. By providing OTs and PTs access to the administrative services credential, the bill seeks to enable these professionals to advance into certificated leadership roles, fostering greater parity with other related-service providers. This change may also have ancillary benefits, such as improved retention and recruitment of highly skilled therapists within the public education system, ultimately enhancing student support through more diversified administrative expertise.
5. Addressing Prior Legislative Concerns. Although this bill seeks to address professional equity, the Governor’s veto of the substantively similar AB 2725 (Rubio, 2024) expressed skepticism about the need for a legislated statewide credential pathway for OTs and PTs. The veto message emphasized that there is no state requirement for these professionals to hold an administrative services credential in order to serve in supervisory roles, and encouraged the Commission on Teacher Credentialing (CTC) to develop distinct pathways for license holders without traditional teacher preparation backgrounds.

As part of the Governor’s 2025-26 May Revision budget proposal, funding is proposed to support this direction. Specifically, the proposal includes $455,000—$322,000 of which is ongoing—and two new positions for the CTC’s Professional Services Division to support work related to updating and adding a non-teaching pathway to the Administrative Services Credential. The proposal also includes $133,000 in one-time funding for convening a temporary workgroup to inform this process.

This budget proposal signals the Administration’s intent for the CTC to take up this issue through its own processes. However, this funding has not yet been adopted by the Legislature, and any final decision will be subject to the outcome of budget negotiations and reconciliation with the Administration. Depending on how that process unfolds, the author may wish to consider whether to proceed with this bill in parallel, delay action pending the outcome of the CTC’s workgroup, or clarify how the bill complements or accelerates those efforts.

SUPPORT

California Physical Therapy Association (Co-Sponsor)
Occupational Therapy Association of California (Co-Sponsor)
Association of California School Administrators
San Francisco Unified School District
SELPA Administrators of California

OPPOSITION

None received

-- END --

Date of Hearing: April 30, 2025

ASSEMBLY COMMITTEE ON APPROPRIATIONS

Buffy Wicks, Chair

ABPCA Bill Id:AB 1009

Author:(Blanca Rubio) – As Introduced Ver:February 20, 2025

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 an administrative credential. Specifically, this bill adds the following to the minimum requirements for a preliminary services credential with a specialization in administrative services issued by the California Commission on Teacher Credentialing (CTC): 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.

FISCAL EFFECT:

General Fund costs to the CTC of $129,000 in the first year and $127,000 ongoing for additional staff who will create resources, provide technical assistance, and oversee processing of additional applications.

COMMENTS:

1. Purpose. 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.

1. Background. In schools, OTs are health professionals who support a child’s engagement and participation in educational activities, play, and social interactions. The federal Individuals with Disabilities Act (IDEA) mandates these services for students with special needs. Licensed OT practitioners in California 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 in schools 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. Federal IDEA also mandates these services for students with special needs. Licensed PT practitioners in California must earn a master’s degree and pass national and state licensure examinations. Currently, the law does not require either OTs or PTs have a credential in order to serve in public schools.

Current law requires an individual to hold a credential and meet other requirements to obtain an administrative credential issued by the CTC. However, there is no avenue for OTs and PTs serving in schools to obtain such a credential to hold administrative and leadership positions.

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

Analysis Prepared by: Aaron Heredia / APPR. / (916) 319-2081

Date of Hearing: April 9, 2025

ASSEMBLY COMMITTEE ON EDUCATION

Al Muratsuchi, Chair

ABPCA Bill Id:AB 1009 (

Author:Blanca Rubio) – As Introduced Ver:February 20, 2025

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

SUMMARY: Authorizes occupational therapists (OT) or physical therapists (PT) to be eligible for a preliminary services credential with a specialization in administrative services by specifying that a valid license to practice occupational therapy or a valid license to practice physical therapy, verification of meeting a basic skills, and three years of experience as a school-based OT or PT qualify as meeting the minimum requirements for the credential. Specifically, this bill:

1. Authorizes OTs or PTs to be eligible for a preliminary services credential with a specialization in administrative services by specifying that 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, and three years of experience as a school-based OT or PT qualify as meeting the minimum requirements for the credential.

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. (EC 44267)
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. (EC 44268)
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.”

OTs and PTs do not currently have the opportunity to earn an administrative credential. 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 who 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 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.

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.

Administrative roles in schools. A recent research paper (Franko, 2023) notes that up to 25% of all OTs work in school. In 45 of 50 states, OTs do not meet state qualifications to pursue formal administrative leadership roles (e.g., director of transition services or special education director) in public school systems with an occupational therapy degree alone. Related service providers, such as school social workers, counselors, psychologists, nurses, and speech pathologists, have the option, in most states, to earn the education credentials needed to pursue administrative credentials and administrative positions. In contrast, OTs who work alongside these providers and are grouped among them in federal legislation (e.g., the Individuals With Disabilities Act and the Every Student Succeeds Act) are not included in state-level legislation as professionals eligible to obtain education credentialing that opens the door to formal administrative leadership positions.

The author notes that, OTs would benefit from pursuing administrative positions through increased recognition, a better seat at the table for practicing school-based therapists, increased pay, and an ability to develop programming to benefit staff, students, and the community. The benefits would also apply to students and schools by increasing the pool of individuals interested in administrative roles, making school jobs more attractive to OTs, leading to increased recruitment and retention, and providing more consistent service to students. (Franko, 2023)

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.

Arguments in support. The Occupational Therapy Association of California and the California Physical Therapy Association write, “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 teachers and other related services providers. 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.

AB 1009 modifies current law to increase professional equity for OTs and PTs by allowing them to qualify to obtain an administrative services credential. Passage of AB 1009 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 2725 (B. Rubio) of the 2023-24 Session was substantively similar to this bill. It was vetoed by the Governor with the following 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 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. For these reasons, I cannot sign this bill.

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

Association of California School Administrators

California Physical Therapy Association

Occupational Therapy Association of California

1 individual

Opposition

None on file

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