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
3/8/19  3:09 pm
Commenter: Olivia Garcia, James Madison University

Regulation changes for QMHP

I am currently a first-year Master's student in the JMU occupational therapy program. As such, I have learned about the fascinating history of how occupational therapy came to be. The profession began in mental health and evolved into a widespread practice that can be applied to a variety of settings. The foundational concept of occupational therapy is to view a person holistically in order to provide care for the overall well-being of a client. Mental health is an essential part of occupational therapy and is woven into each setting, even those that are not strictly mental health.

In my program we spend an entire semester learning about psychosocial occupational therapy and at this time we are placed in our first level I fieldwork in relation to mental health. I believe the reason for this is because mental health is a crucial building block to all occupational therapy practices and should be considered by great therapists when treating a client for any particular reason. Therefore, recieving a QMHP certification should be more accessible to occupational therapists as it is a major part of the profession and the current regulations do not honor that as it does to other equally qualified professions. 

For that reason, I am strongly 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.