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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2/25/19  2:30 pm
Commenter: Taylor Neiser, MOTS James Madison University

Occupational Therapists as QMHP

I am a Master's of Occupational Therapy student at James Madison University. I have been learning about the wonderous field of psychosocial and mental health and our role as future OT's and have felt a passion awaken in me. I came into this program with the very strong mindset of becoming a Pediatric OT. I recognized my interest and curiosity in the mental health field as well but shyed away from it until this semester when I was placed at Western State Hospital for my first Level I placement. This placement has evolved my interest in mental health to a much more involved perspective. 

I am originally from Maryland but have gone to secondary school in Virginia, first at Lynchburg College and now at JMU. I feel at home in this part of the state and have plans to stay in this general area to practice. Learning about the current requirements of OT's to become QMHP strikes me as being slightly extra work that could potentially be more cost-effective instead of beneficial for all professionals involved. The professionals who must train and supervise us for the extensive 1500 hours would have even more responsibilities placed on them that would not be necessary. I believe a requirement of 500 hours would be more doable and beneficial to all involved because there are phenomenon that we as OT's must be taught in this field, but also we operate through the lens of person-first therapy, where we consider a person's values, psychosocial factors as some of the most central factors to their success. We are trained to view a person as an active agent that is also highly influenced by their psychosocial factors. We are also sensitized to the reality of many mental health conditions and are taught effective interactive skills to empathize with clients.

I feel that we as Occupational Therapists, will have the skills and tools necessary to be considered QMHP, and that the requirement of 1500 hours to be certified QMHP may be redundant while a requirement of 500 hours supervision and training may be more beneficial to all involved. 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.

Thank you for your time. 

Taylor Neiser, MOTS