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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3/13/19  6:54 pm
Commenter: Erica Jackson, James Madison University MOT

QMHP requirements for OT

Occupational Therapy is already recognized and practiced in mental health settings. It is a profession that was originally founded on the basis of fair treatment of those with psychiatric disorders during the Moral Treatment Era. Given this, the curriculum for an accredited Master’s program like that of James Madison University dedicates classes to mental health disorders, psychosocial perspectives, neuroscience, and mental health related level 1 fieldwork. This specific fieldwork accounts for roughly 100 hours of time spent with a mental health population, plus 10 credit hours of classes primarily focused on mental health/neuroscience. All this does not include the possibility of selecting a mental health level 2 fieldwork; accounting for 12 weeks of full-time work at the facility. In addition, Occupational Therapy takes a holistic approach so all classes incorporate mental health in some manner. Given this plethora of time spent on the topic, Occupational Therapists graduate with strong background knowledge in mental health practice. 

With such strong ties to mental health, Occupational Therapists are drawn towards these mental health practice settings; however, I am afraid the requirements for becoming a Qualified Mental Health Practitioner may lower the number of Occupational Therapists entering these practice areas. As the profession begins moving towards a doctorate level program, people are spending greater amounts of time and money to become registered and licensed Occupational Therapists so an additional 1,500 hour requirement seems to discredit the profession. Not only this, but supervision of these hours under another health care professional prompts concerns regarding interprofessional collaboration; an area that has been identified in the United States health care system as needing improvement. 

I am not against additional requirements for becoming a certified Qualified Mental Health Practitioner; however, I strongly believe these requirements should reflect the merit of an Occupational Therapy degree. Therefore, 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.