Agencies | Governor
Virginia Regulatory Town Hall
Department of Health Professions
Board of Counseling
Regulations Governing the Registration of Qualified Mental Health Professionals [under development] [18 VAC 115 ‑ 80]
Action Initial regulations for registration of Qualified Mental Health Professionals
Stage Proposed
Comment Period Ends 4/5/2019
Previous Comment     Next Comment     Back to List of Comments
2/24/19  4:09 pm
Commenter: Kate van Emmerik, James Madison University Occupational Therapy Program

Occupational Therapists as QMHPs

I am a first-year student in the James Madison University Occupational Therapy Program.  I am writing in support of the revision of requirements for occupational therapists to become Qualified Mental Health Professionals. 

Occupational therapists work with people of all ages to promote independence and functionality in their everyday lives regardless of injury, illness, or diagnoses.  We take three semesters of courses that are dedicated to different specialty areas, one of which is psychosocial and mental health OT practice.  We are taking two classes focusing specifically on this area of practice: Psychosocial Perspectives in Occupational Therapy and a case-based learning course with cases heavy in the psychosocial and mental health practice of occupational therapy.  However, psychosocial aspects of treatment are embedded throughout the entire program.

As an occupational therapy student, I am trained to treat each individual holistically and to put their best interest and goals at the heart of my client-centered practice.  We are trained as generalists, so we will be prepared to practice in a wide variety of settings as stated in ACOTE standard 5.1.  Mental health settings are included in this standard.  One component of our training that facilitates this readiness is our completion of “at least one fieldwork experience (either Level I or Level II) must address practice in behavioral health, or psychological and social factors influencing engagement in occupation” as stated in ACOTE standard 7.1. 

Master’s and Doctoral occupational therapy programs yield therapists prepared to work in mental health settings to provide care for individuals with psychosocial goals who are working towards independent and meaningful lives.  Occupational therapists who hold a master’s degree or higher should be able to register for the QMHP title under the same requirements as those who hold a master’s degree from a psychology, social work, counseling, substance abuse, or marriage and family therapy program.  Occupational therapists have been practicing in mental health since the foundation of the profession, whose founders included psychiatrist Dr. William Dunton and social worker Eleanor Clark Slagle. 

Individuals receiving mental health services in Virginia would benefit from occupational therapists with QMHP certicfication.  The services we provide are geared towards living independent, full lives that all individuals deserve the chance to lead.

I support a revision of 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 

to be changed to:

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.

CommentID: 69256