16.5 NBCOT Practice Standards & the Candidate/Certificant Code of Conduct
Key Takeaways
- The NBCOT blueprint names the NBCOT Practice Standards and Code of Conduct by name; the enforceable document is the NBCOT Candidate/Certificant Code of Conduct, which contains nine principles and binds candidates and applicants as well as certificants.
- Certificants must disclose any criminal, legal, or other disciplinary matter to NBCOT within 60 days of the matter.
- Principle 9 prohibits misusing NBCOT intellectual property, and discussing or disclosing exam content — including posting it to a discussion forum, a study site, or an AI application — is an explicit violation.
- Principle 8 prohibits posting protected health information or anything, including photos, that could reveal a client's identity or the therapeutic relationship, without the client's written consent.
- NBCOT sanctions range from ineligibility for certification and reprimand through censure, probation, suspension, and revocation, but NBCOT cannot revoke a state license — only a state regulatory board can.
NBCOT Practice Standards & the Candidate/Certificant Code of Conduct
The final knowledge statement in the COTA content outline is the application of ethical decision-making and professional behaviors guided by the NBCOT Practice Standards and Code of Conduct. Notice whose document that is. Candidates who study only the AOTA Code of Ethics have prepared the wrong instrument for this knowledge statement.
The enforceable NBCOT document is the NBCOT Candidate/Certificant Code of Conduct, most recently revised in July 2022. Its scope statement is important: wherever the document says certificant, the term includes applicants and candidates. It binds you from the moment you apply for the exam, not from the moment you pass it.
1. The Nine Principles
| # | Principle | What It Governs in Practice |
|---|---|---|
| 1 | Certificants shall provide accurate, truthful, and timely representations to NBCOT | Exam and renewal applications, renewal audit forms, character review answers, cooperation with NBCOT investigations, and information about credentials, licenses, and education. Includes disclosing any criminal, legal, or other disciplinary matter within 60 days. |
| 2 | Certificants shall abide by all exam-related security policies | No copying or removing exam content; no prohibited devices or materials in the testing room |
| 3 | Certificants shall be accurate, truthful, and complete in all communications with clients, employers, regulatory agencies, and others | Covers professional work, education, credentials, research, and contributions to the field — this is the principle violated by résumé inflation and by falsified documentation |
| 4 | Certificants shall comply with state and federal laws, regulations, and statutes governing occupational therapy practice | State practice acts, HIPAA, IDEA, ADA, Medicare rules |
| 5 | Certificants shall not have pled guilty to or been found guilty of a serious crime | Grounds for ineligibility or sanction independent of any state board action |
| 6 | Certificants shall not engage in behavior or conduct, lawful or otherwise, that makes them a threat or potential threat to the health, well-being, or safety of recipients or potential recipients of occupational therapy services | Reaches conduct that is not itself illegal |
| 7 | Certificants shall not practice while their ability to practice is impaired by chemical (legal or illegal) drug or alcohol abuse | Includes legally prescribed medication that impairs practice |
| 8 | Certificants shall not electronically post protected health information or anything, including photos, that may reveal a client's identity or the personal or therapeutic relationship, without written consent | The social media principle. NBCOT notes that any statement about a client, regardless of intent, may carry enough detail for someone in that community to identify them — which also implicates HIPAA. |
| 9 | Certificants shall not misuse NBCOT's intellectual property, certification marks, logos, or copyrighted materials | Explicitly includes discussing or disclosing exam content; copying, uploading, downloading, or sharing NBCOT study tool, continuing competency tool, or website content through any platform including web-based study tools, AI applications, social media, forums, or email; using an NBCOT certification mark when not actively certified; and displaying NBCOT logos without written consent |
[!WARNING] Two of these catch new graduates more than any others. Principle 9: posting "here's what was on my exam" to a forum, a group chat, or an AI tool is a Code violation that can void a score and bar certification. Principle 8: a de-identified-sounding post — "my 40-year-old patient who lost his arm in the mill fire last month" — is identifiable to anyone in that town.
2. Enforcement, Sanctions & Jurisdiction
NBCOT's Qualifications and Compliance Review program administers the Procedures for Enforcement. NBCOT has jurisdiction over anyone who is currently OTR or COTA certified, has applied for certification, has applied for the Occupational Therapist Eligibility Determination, has applied for an Early Determination Review, or is an expired certificant applying for late renewal.
Sanctions available to NBCOT include:
- Ineligibility for certification — the individual is barred from becoming NBCOT certified, either for a set duration or indefinitely.
- Reprimand — a formal expression of disapproval retained in the certificant's file but not publicly announced.
- Censure — a formal expression of disapproval that is made public.
- Probation — certification continues under stated conditions.
- Suspension — certification is removed for a defined period; the certification mark may not be used.
- Revocation — certification is terminated.
Failing to respond to the enforcement procedures is itself treated as a Principle 1 violation and is independent grounds for sanction.
Jurisdiction: Three Bodies, Three Different Powers
| Body | Who It Covers | What It Can Take Away | What It Cannot Do |
|---|---|---|---|
| NBCOT | Certificants, applicants, and candidates | The OTR/COTA certification and the right to use the certification mark | Cannot revoke a state license or bar you from practice where certification is not required for continued licensure |
| State regulatory board | Everyone practicing in that state | The legal license to practice in that state | Has no authority over the national certification credential |
| AOTA | Members only | AOTA membership | Has no legal authority over either license or certification |
A single incident can trigger all three concurrently, and each proceeds independently.
3. NBCOT Standards vs. AOTA Code of Ethics: Using Both
The two documents overlap heavily but are organized differently, and the exam expects you to know which is which.
| Situation | AOTA Code of Ethics Frame | NBCOT Code of Conduct Frame |
|---|---|---|
| Falsifying treatment minutes to bill an extra unit | Violates Principle 5, Veracity | Violates Principle 3 (truthful communications with employers and regulatory agencies) and Principle 4 (compliance with federal law) |
| Posting a client photo to social media without consent | Violates Autonomy and confidentiality obligations | Violates Principle 8 explicitly |
| Treating clients while impaired by alcohol | Violates Nonmaleficence | Violates Principle 7 explicitly |
| Sharing exam questions in an online study group | Not directly addressed | Violates Principles 2 and 9 |
| Not disclosing a DUI conviction to NBCOT at renewal | Not directly addressed | Violates Principle 1 (60-day disclosure duty) |
Practical Compliance Habits
- Answer the character and conduct affirmation truthfully at every renewal, and calendar the 60-day disclosure clock the moment any legal or disciplinary matter arises.
- Keep documentation of renewal units for the possibility of a random renewal audit.
- Never use the COTA certification mark during a lapse in certification — drop the "C" and use OTA or OTA/L, as permitted by the state license.
- Do not discuss specific exam content with anyone after testing, however informally.
- Get written consent before any post, photo, presentation, or case write-up that could identify a client.
Three weeks after passing the COTA exam, a new graduate posts a summary of several specific exam questions to an online study forum to help future candidates. Which NBCOT Candidate/Certificant Code of Conduct principles does this violate, and what is the potential consequence?
A COTA is arrested and later convicted of a misdemeanor unrelated to occupational therapy practice. Under the NBCOT Candidate/Certificant Code of Conduct, what is the certificant's obligation?
A COTA posts on social media: 'Rough day — my 82-year-old stroke patient in room 4 finally fed herself for the first time since her husband's funeral last week.' No name or photograph is included. How should this be evaluated?
A state regulatory board suspends a COTA's license for one year following a documented billing fraud finding. What is the effect on the practitioner's NBCOT certification and AOTA membership?
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