I am a doctoral student in Occupational Therapy at Virginia Commonwealth University and I am writing to you to ask you to reconsider the supervision requirements outlined in the emergency regulations by the Virginia Board of Counseling for occupational therapists seeking registration as a Qualified Mental Health Provider (QMHP). As a student, I have taken courses that thoroughly covered various aspects of mental health. I have also gone through multiple clinical experiences in various settings that treat mental health conditions across the lifespan, ranging from acute conditions to community reintegration. Those clinical experiences are required for accreditation of the programs we go through, and part of the requirements include at least one experience serving clients in a mental health-based setting.

            Occupational therapy is a holistic practice that emphasizes the client’s lived experience, and mental health is a significant aspect of that. The practice itself was founded by a team that included two psychiatrists and began in public psychiatric hospitals. The members of that team understood the value of occupation on our lives and on our ability to restore our health and mental well-being. They recognized that the mind and body are inseparable and that disrupting our abilities to engage in occupation would negatively affect both our mind and body. This form of therapy bridges between different traditional healthcare and mental health services and is key in maintaining wellbeing for our clients.

            Occupational therapy has been included as a core component of quality mental health services by the Center for Medicare and Medicaid services, and must be offered at any community mental health center that bills under Medicare for partial hospitalization. It has also been included as a member of the behavioral health workforce by the Health Resources Service Administration in 2018. In a bipartisan Substance Use-Disorder Prevention that Promotes Opioid Recovery and Treatment (SUPPORT) for Patients and Communities Act (HR6) occupational therapy was recognized, as the act promotes non-opioid and non-pharmacological approaches to pain management.

Occupational therapists across the state are asking that the Part II Requirements for Registration regulation 18VAC115-80-40 B.5. Requirements for registration as a QMHP-A and 18VAC115-80-50 B.4. Requirements for registration as a QMHP-C be changed from the emergency regulations that currently read:

B. 5. A licensed occupational therapist with no less than 1,500 hours of supervised experience to be obtained within a five-year period immediately preceding application for registration and as specified in subsection C of this section. (Subsection C requires that the supervision occur of a licensed mental health professional or a person under supervision that has been approved by the Boards of Counseling, Psychology, or Social Work as a pre-requisite for licensure.)

AND

B. 4. A licensed occupational therapist with no less than 1,500 hours of supervised experience to be obtained within a five-year period immediately preceding application for registration and as specified in subsection C of this section.

And that they be replaced with criteria that has the potential to expand the behavioral health workforce. We suggest the following replacement:

18VAC115-80-40 B.5. and 18VAC115-80-50 B.4. Licensure as an occupational therapist by the Board of Medicine (§ 54.1-2900 of the Code of Virginia) with a master’s or doctoral degree, and an internship or practicum of at least 500 hours with persons with mental illness or one year of experience in a mental health setting.
 

Thank you for your time and consideration,

Nouran Amin, OTS

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