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
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2/24/19  6:45 pm
Commenter: Taylor Reamy, James Madison University Occupational Therapy Program

Occupational Therapists as QMHP's

I am a student of the Occupational Therapy Program at James Madison University, in which I will receive a Master’s degree upon graduation. I plan to practice in Virginia after I graduate in December 2020. According to the accreditation standards for a master’s degree-level educational program for occupational therapists, “at least one fieldwork experience must address practice in behavioral health, or psychological and social factors influencing engagement in occupation” as stated in ACOTE standard C.1.7. I am currently completing a psychosocial level I fieldwork in which many of my classmates are in traditional mental health settings. Throughout the rest of my time in school I will be completing two more level I fieldworks with a minimum of 40 hours in each, as well as, two level II fieldworks with about 480 hours each (both are 3 months in duration). Any of these fieldworks could be completed in a mental health setting.

As a student in an occupational therapy program, we also trained to work in a variety of different settings including practice in a mental health setting, as stated in ACOTE standard A.5.1. We take courses throughout the program that ready us for work in the psychosocial and mental health fields, as well as having psychosocial aspects built into every course that we take.

Occupational therapy as a profession was founded in the field of mental health and has continued to practice in this area for over 100 years. Occupational therapists who hold a master’s level degree or higher should be able to obtain the title of QMHP under the same requirements as individuals who hold a masters degree in the fields of psychology, social work, counseling, substance abuse, or marriage and family therapy program.

Occupational therapy intervention within the field of mental health is crucial and we are trained with the knowledge and skills to help individuals seeking services to improve their lives, level of independence, and their integration into society.

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 

be changed to the following requirement:

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 of this request.