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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2/27/19  9:27 pm
Commenter: Rebekah Vanzo, OTS, James Madison University

Occupational Therapists are QMHPs

I am an OT student at James Madison University, and upon graduation with my Master of Occupational Therapy I intend to practice in the state of Virginia.

Mental health and well-being is undeniably an integral part of occupational therapy practice; the profession itself was founded, in part, by mental health practitioners. Additionally, ACOTE Accreditation standards C. 1. 7 indicates that “at least one fieldwork experience must address practice in behavioral health, or psychological and social factors influencing engagement in occupation.” While this indicates a minimum of 40 hours of fieldwork with a mental health concentration, a student could direct their level 2 fieldwork placements to have gathered 1000 hours of fieldwork with a mental health emphasis before graduating from the program. In the JMU OT program we have an entire semester concentrated on psychosocial and mental health, with classes, fieldwork, and gathering of materials in preparation for practice all guided by psychosocial frames of reference. Psychosocial issues are continuously addressed outside of this semster also. Although trained as generalists, we are well educated and prepared to provide support and treatment for the mental health needs of our clients. Approaching all clients with a holistic perspective, even clients who are not seen in a traditional mental health setting will have their mental wellbeing considered by their occupational therapist.

The title of QMHP should be allowed to occupational therapists who graduate with a master's degree or higher under the same requirements as those who graduate in psychology, social work, counseling, substance abuse, or marriage and family therapy program. To deny us this is to deny the validity of occupational therapy as an equal graduate program and profession, and undermines the extensive work occupational therapy students undertake to ensure they can effectively address the mental health needs of their clients. It is not in the best interest of our clients to have extra barriers to gain QMHP status, as it could likely lead to increased costs of treatment due to increased cost on the therapist's part to gain this title. Across the United States there is already far too little access to quality mental health care, and it does not make sense to create even more barriers.

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: 69290