When to register as an occupational therapist: requirements under the HPCAA

Background

The current law covering the practice of occupational therapy in New Zealand is the Health Practitioners Competence Assurance Act 2003 (HPCAA).

This law protects the health and safety of members of the public by providing the tools to make sure that health practitioners are competent and fit to practice. In order to use the title and work as an occupational therapist in New Zealand, individuals must be registered with the Occupational Therapy Board of New Zealand (OTBNZ), and hold a current practising certificate.

Download the full policy here on when to register as an occupational therapist, holding a practising certificate and the use of occupational therapy titles. This policy will help with:

• when you need to be registered and hold a current practising certificate
• when someone registered with the OTBNZ must hold a practising certificate
• when you can use the title occupational therapist
• deciding if someone is practising as an occupational therapist (regardless of their  title). 

Registration criteria

The criteria for registration with the OTBNZ makes sure that occupational therapists in New Zealand:

• have an appropriate occupational therapy qualification
• are competent to practice
• are of good character and are a ‘fit’ person to work as an occupational therapist.

Holding a practising certificate assures the public that the occupational therapist continues to meet the criteria for registration. The occupational therapist is required to  continue developing their professional skills.  

Individuals who do not hold an occupational therapy qualification

Only practitioners who are registered with the OTBNZ and hold a practising certificate can claim to be an occupational therapist and provide occupational therapy services in New Zealand. Unqualified individuals who claim to be an occupational therapist are committing an offence under section 7 of the HPCAA. 

People holding an occupational therapy qualification but not registered with the OTBNZ

Unregistered people must not claim to be an occupational therapist, or practice occupational therapy in New Zealand, even if they have completed an occupational therapy qualification. Anyone offering services to clients in New Zealand via telehealth (phone, videoconference etc.) are deemed to be practising in New Zealand and need to register with the OTBNZ regardless of their country of residence.

People in this category can state their qualification (e.g. Bachelor of Occupational Therapy). However, they must not suggest that this means they are registered or practising as an occupational therapist or providing occupational therapy services in New Zealand.

Practising without registration

Individuals claiming to be an occupational therapist are referred to the Ministry of Health for investigation which may result in prosecution and a fine not exceeding $10,000. Breaches of section 7 of the HPCAA will take into account:

• the context in which the qualification or title is used
• whether a member of the public seeking occupational therapy services would reasonably understand that person to be a registered occupational therapist.

Applications for employment

People seeking employment but not yet registered as an occupational therapistn may use their qualification for this purpose. However, they will need to be registered and hold a current practising certificate when employed (s7(4)).

People registered with the OTBNZ but not currently holding a practising certificate

Practitioners who are on the OTBNZ register must hold a practising certificate when they are performing any of the tasks/skills within the scope of practice of occupational therapy. This is the case even when the practitioner is employed under a different job title, the position is voluntary or the practitioner is not in direct contact with the public.

Virtual or telemedicine 

Anyone providing occupational therapy services to the public in New Zealand (including telehealth) must be registered with the OTBNZ and hold a current practising certificate. New Zealand registered practitioners who are providing occupational therapy to overseas clients should ensure that they are following the legislation of the country they are practising in. This includes registration with the relevant authorities. For further information about providing telehealth refer to the NZ Telehealth Forum and Resource Centre (https://www.telehealth.org.nz/).

Use of the term NZROT

Some occupational therapists use the acronym ‘NZROT’ (New Zealand Registered Occupational Therapist), alongside their name to show registration. This is the same as using the title ‘occupational therapist’ and the user must be registered. Guidance for use of the OTBNZ registered logo are available here.