With a strong foundation in mental health practice from our roots as a profession, we as occupational therapists believe that the emergency regulations for occupational therapists promulgated by the Board of Counseling are unduly and unnecessarily onerous. They will prohibit OTs from pursuing QMHP registration. 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 emergency regulations that currently read:

B. 5. A licensed occupational therapist with no less than 1,500 hours of supervised experience to be obtained within a five-year period immediately preceding application for registration and as specified in subsection C of this section. (Subsection C requires that the supervision occur of a licensed mental health professional or a person under supervision that has been approved by the Boards of Counseling, Psychology, or Social Work as a pre-requisite for licensure.)
AND
B. 4. A licensed occupational therapist with no less than 1,500 hours of supervised experience to be obtained within a five-year period immediately preceding application for registration and as specified in subsection C of this section.

And that they be replaced with criteria that has the potential to expand the behavioral health workforce. We suggest the following replacement:

18VAC115-80-40 B.5. and 18VAC115-80-50 B.4. 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.