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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2/25/19  11:47 pm
Commenter: Ariana Olazagasti, MOT, James Madison University

Validity is being questioned in the very field that OT originated in: We deserve to be QMHPs.

Occupational Therapy originated as a mental health profession providing occupation and activity-based interventions with the idea that meaningful tasks provide more motivation and better health outcomes in clients, both physiologically and psychosocially. While our scope of practice has widened, our holistic foundation and approach to intervention remains the same; psychosocial concepts of individual’s health, recovery, or rehabilitation must be addressed in order to provide true client-centered and effective care.  

Occupational therapists are not only trained in mental health, but also anatomical and neurological processes associated with physiological and psychological function. As a profession that began in the very field of mental health where their validity is currently being questioned, it is imperative that Occupational Therapists be able to pursue the qualifications of QMHP with minimal barriers so that they may continue to address the current mental health crisis that is sweeping the nation. The current legislation undermines the graduate-level degree that Occupational Therapists hold, as well as the value they hold in the field of health professions, and more importantly, that of mental health.

As an MOT student at James Madison University and possible future QMHP, I stand behind the move to change 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 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."