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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2/26/19  11:56 am
Commenter: Gretchen Ward, Independent Contractor,

Requirements for QMHP registration for OT

My name is Gretchen Ward, I am an occupational therapist working with children, youth, and young adults at 2 private clinics in the state of VA. I previously was employed by Grafton Integrated Health Network working in behavioral health care and have 9 years of occupational therapy experience in school based and early intervention practice. I am a member of the AOTA School Based Mental Health community of practice and serve as the Policy and Advocacy coordinator for the AOTA Children and Youth Special Interest section. I also serve as the Communications Chairperson for the Virginia Occupational Therapy Association. 

Mental Health is at the core of our profession as occupational therapitsts and the holistic approach of how mental, physical, and social aspects of a person impact their well being is what sets occupational therapy apart from other health professions. Students of occupational therapy complete at least one clinical learning experience in the area of mental health and are required to learn psychosocial skills in order to complete their education. I was excited to see the Virginia was leading the way recognizing occupational therapists as qualified mental health professionals, however was dismayed when I attempted to register to find an additional requirement of 1500 hours of supervision, that is not clearly defined. This requirement is an undue burden that does not take into consideration the level of education or experience of many practicing occupational therapists. 

We 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 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.

This change of requirement would account for the experience of those who have been working in mental health settings and the clinical component of the education for future occupational therapists looking to work in mental health. 

Thank you for the opportunity to comment and your consideration, 

Gretchen R. Ward, MS, OTR/L 

9144 Kershaw Ct. 

Manassas, VA 20110 


CommentID: 69278