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
Stage Proposed
Comment Period Ends 4/5/2019
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2/24/19  8:01 pm
Commenter: Maria Binns Cannady-InnovAge PACE and St. Catherine University OTA Program

Reduce Restrictions on QMHP Requirement for Occupational Therapists in Virginia

Dr Hoyle,

I am writing to ask you to reduce the restriction on QMHP requirements for Occupational Therapists in Virginia.  I have been an Occupational Therapist in Virginia for over 20 years.  I work with the frail elderly population at the Program of All Inclusive Care for the Elderly.  I have also been an adjunct Lab Professor for St. Catherine University for 2 years.  Part of my lab instruction involves teaching Occupational Therapy Assistant Students interview and treatment strategies for working with mental health conditions.  


?     OT education is at the graduate level.  Since 2007, a master’s degree has been the educational requirement for entry into the profession. Currently 29 universities are accredited to offer Occupational Therapy Doctorate (OTD) degrees, including two in Virginia, Virginia Commonwealth University and Mary Baldwin University. Another 107 programs are in the development process to offer OTD degrees.  The remaining 177 schools offer programs at the Masters level, including five Virginia schools - Emory & Henry College, Jefferson College of Health Sciences, James Madison University, Radford University, and Shenandoah University.

?     The Accreditation Council for Occupational Therapy Education (ACOTE) sets standards for entry-level occupational therapy education programs and those standards include extensive requirements for coursework and at least one fieldwork experience focused on mental health

  • OTs are required to pass a national certification exam and are licensed in all states. OTs in Virginia are licensed by the Board of Medicine, which must be renewed every two years.    


  • While some states, like Oregon, Maine and Massachusettshave no additional requirements for OTs to qualify for QMHP status beyond licensure. Other states, including Illinois, require licensure and one year of clinical experience in a mental health settingMissouri recognizes OTswith Master’s degrees who have completed a practicum in a psychiatric settingor who have had one year of experience in a psychiatric setting.


?In countries where national health insurance exists, like the UK, Canada and Australia, health care team members are paid equivalently for the provision of mental healthcare services as for physical healthcare services. In those countries 50% of the OT workforce works in mental health. In the US the number of OT practitioners pursuing careers in mental health is under 5% because of the pay differential and the cost of education.

Again, please consider reducing these restrictions on OTs, as I feel this willl prohibit OTs from pursuing QMHP registration.  We need more health care professionals in the community who are willing to treat children and adults who have a variety of mental health conditions.



Maria Binns Cannady, OTR/L