Continuing Competence Requirements for OTs, State by State

Most states require OTs and OTAs to complete about 24 hours of continuing competence every two years, but no two states define those hours the same way. The differences that cause trouble are the mandatory topics, the limits on self-study, and the cycle dates. An OT licensed in several states usually has to satisfy each state's rules separately, and one course can count in several places only if it meets every state's standard.

How do seven states compare?

From each state's rules or board page, as of October 2026:

State	Hours and cycle	Mandatory topics and limits	Source
California	24 professional development units per two-year renewal	At least half directly related to delivering OT services; not required at the first renewal after initial licensure	16 CCR § 4161
Texas	24 contact hours every two years	An HHSC-approved human trafficking course each renewal; jurisprudence exam passed at renewal	40 Tex. Admin. Code §§ 367.1, 370.1
Florida	26 hours per biennium	2-hour medical errors course and 2-hour laws and rules course each biennium; 1 hour HIV/AIDS by first renewal; at least 14 hours live or interactive; no more than 12 home study	Fla. Admin. Code R. 64B11-5.001
Illinois	24 contact hours per prerenewal period (the 24 months before December 31 of the renewal year)	1 hour each of ethics, sexual harassment prevention and implicit bias awareness; 1 hour of dementia recognition for those treating adults 26 or older	68 Ill. Adm. Code 1315.145
New York	36 hours every three-year registration	At least 24 in professional subjects; no more than two-thirds through self-directed online study	NYSED Office of the Professions
Pennsylvania	24 contact hours per biennium	At least 2 hours of child abuse recognition and reporting; first biennium exempt except the child abuse hours	49 Pa. Code § 42.53
Tennessee	24 credits in the 24 months before renewal	1 hour on ethics and 1 hour on the Tennessee OT law	Tenn. Comp. R. & Regs. 1150-02-.12

Every state's page in our license index lists its renewal cycle and hours where we have verified them.

Where do the differences bite?

State-specific topics

Mandatory topics are the most common gap. A course on Florida's laws and rules does nothing for Tennessee's requirement on Tennessee's law, and Texas will only accept a human trafficking course approved by the Texas Health and Human Services Commission. Texas goes further: a human trafficking course "approved or offered by AOTA or TOTA may not be used to satisfy" that requirement unless it is on the HHSC list (40 Tex. Admin. Code § 367.1).

Live versus self-study

Florida requires at least 14 of its 26 hours "in person or from interactive, real-time courses," which can be a webinar that lets you interact with the instructor in real time, and caps home study at 12 hours. New York allows no more than two-thirds of its 36 hours through self-directed online study, so at least 12 must be live or synchronous. An OT who does all CE as recorded online modules will fall short in both.

What counts at all

Texas lists activities that never count, including breaks and meals, business meetings, exhibit hall time, orientation to a specific workplace, and general topics such as CPR, first aid and HIPAA (40 Tex. Admin. Code § 367.2). California requires that half of all units relate directly to delivering OT services.

Cycle dates

Two-year cycles rarely line up. Texas licenses renew every two years by the end of the birth month (§ 370.1), California's expire on the last day of the birth month in odd or even years matching your birth year (16 CCR § 4120), Pennsylvania's biennium runs July 1 to June 30, and Illinois counts back from December 31 of the renewal year. A course taken in March may fall in different cycles in different states. See keeping several OT licenses current.

Which activities besides courses count?

More than most OTs use. California lets you earn part of its 24 units outside formal courses, up to 12 units in total from these activities (16 CCR § 4161(c), (d)):

• supervising fieldwork students: one unit per Level I student, and one unit per 40 hours of Level II supervision, up to 12 units;
• presenting at workshops, seminars or conferences: two units per hour presented, up to six;
• attending a California Board of Occupational Therapy meeting: two units per meeting, up to six;
• publishing an article or textbook chapter, structured mentoring, and study groups, each with its own cap.

Texas counts accredited academic coursework at three contact hours per credit hour with a grade of A, B, C or Pass, and up to 10 hours for developing a college course (40 Tex. Admin. Code § 367.2). Florida awards up to eight contact hours per biennium for presenting or authoring a CE course and attending board meetings (Fla. Admin. Code R. 64B11-5.001(10)). Each state wants its own form of proof, such as a program director's letter or a signed attendance record, so collect it at the time.

Can one course count in several states?

Often yes, for the general hours. Several states accept AOTA-approved activities by name: Texas pre-approves activities approved or offered by AOTA or the Texas Occupational Therapy Association, and California accepts programs sponsored by AOTA or the Occupational Therapy Association of California. A general clinical course from an AOTA Approved Provider is a good candidate to count in many places.

Two limits apply. First, a course counts toward a state's mandatory topic only if it covers that state's specific content. Second, some states limit reuse across cycles: Texas says each activity "may be counted only one time in two renewal cycles" (§ 367.1(c)). Keep every certificate with the date, provider, hours and title, because audits ask for exactly those fields.

Do new licensees get a pass?

Sometimes, for the first cycle only. California's rule does not apply to the first renewal after initial licensure (16 CCR § 4161(e)). Pennsylvania exempts the first biennial period except the two hours of child abuse training (49 Pa. Code § 42.53(b)). Florida exempts those licensed in the second half of a biennium from the hours, except the medical errors course and the HIV/AIDS hour. An OT newly licensed by endorsement may assume the exemption covers them; read the rule, because most are tied to the date the license was issued, not to whether you are new to the profession.

How does the OT Compact handle continuing education?

Simply. The Commission's FAQ says "Practitioners only need to complete CEUs for their home state." A privilege in Maryland or Wisconsin does not add those states' CE rules. It does not remove state-specific practice rules, though, and a privilege expires with your home license, so missing your home state's CE can end every privilege at once. See renewing compact privileges.

Does NBCOT renewal count?

NBCOT certification renewal is its own requirement: 36 units every three years, with a renewal season from January to March, per NBCOT. A course can count toward both if it meets each standard, but renewing your NBCOT certification does not renew a state license, and most states do not require active NBCOT certification after licensure. See NBCOT renewal and state license renewal.

What happens in an audit?

Renewal usually runs on your attestation, with documentation checked later; Texas has a dedicated audit rule (40 Tex. Admin. Code § 367.3). Texas also says licensees "must provide proof of completion of contact hours at the Board's request" and that the licensee "is solely responsible for keeping accurate documentation of all continuing education" (40 Tex. Admin. Code § 367.1). Florida requires keeping signed course validation forms for home study for four years (Fla. Admin. Code R. 64B11-5.001(4)). A missing certificate is treated like a missing course.

How do we keep it straight?

Our Annual Renewal & CE Compliance service ($299 per license, per year) logs each course once and checks it against every state you hold, flags mandatory topics before the deadline, and files each renewal ahead of its date. We do not take courses or exams for you; we make sure the ones you take count where you need them.