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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2/25/19  8:53 am
Commenter: Charlea Olmstead, MOTS, James Madison University

Occupational Therapists are QMHPs by trade and should be recognized as such in legislation

Regardless of the practice setting, diagnosis, etc., occupational therapists are addressing the psychosocial needs of our patients. We are trained to treat the whole person including the brain and mind. A foundation in mental health is crucial to attend to our patients' needs, thus our coursework and education speaks to neurological structures and functions; mental health diagnoses and dysfunctions; and neurological, cognitive, perceptual, and psychosocial assessments and interventions, to name a few. 

The current legislation regarding occupational therapists as QMPHs is unduely and unneccessary. By education, trade, and definition, occupational therapists are qualified to work as mental health care providers. Furthermore, other professions acting as gatekeepers to services that are already in OT's scope of practice can create competition or tension in the workplace, among professions, and among practictioners. Lastly, the current legislation undermines our profession as occupational therapists and fails to recognize it as a graduate level degree. 

For these reasons and more, I am advocating that 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 current Emergency Regulations to the following replacement:

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.