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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2/28/19  1:24 pm
Commenter: Lauren Carper, James Madison University

Occupational Therapists as QMHP

   I am a Master of Occupational Therapy student from James Madison University. I plan to practice in the state of Virginia for the entirety of my career following completion of the program.

   Occupational Therapy as a profession is rooted in the fields of psychology, social work, medical practice, and rehabilitation. We are trained to see individuals in a holistic manner, looking at the needs of people from both the physical and psychosocial aspect in order to truly improve a person’s quality of life and/or independence. This is pulled directly from the QMHP Frequently Asked Questions page provided on the Commonwealth of Virginia Board of Counseling’s website as qualifications for QMHP-A prior to December 31, 2017: “Master’s degree in psychology, social work, counseling, substance abuse, or marriage and family therapy from an accredited college or university, you need: • To submit a transcript • Evidence you have had an internship or practicum of at least 500 hours of experience with persons who have a mental illness. (Verification of Internship/Practicum for QMHP form)” (VA Dept. of Health Professions, 2018). It doesn’t make sense to me that other fields that Occupational Therapy is rooted and grounded in by theory, intervention, evidence-based practices, and overarching goals are only required to have a Master’s degree and provide evidence of at least 500 hours of experience with persons who have a mental illness when we as Master’s of Occupational Therapy students will complete our program obtaining over 1,000 hours of clinical experience. Occupational Therapists work with people who are experiencing mental health crises and difficulties in all settings, practices, and with all populations. We devote an entire semester of our graduate program with a primary focus on mental health issues and how to address those as practitioners. Even though we have one semester devoted to this, we continually learn and practice those skills in every course we take and within every fieldwork, clinical experience, and volunteer experiences we partake in throughout the program. It seems excessive to place more requirements upon OTs who wish to gain the QMHP title in order to do the same job they have already been prepared to do. These proposed requirements may take time away from much needed research in the field of Occupational Therapy to show evidence that a holistic approach to treating individuals is more effective at increasing the quality of life and decreasing the mental health crises facing our nation today than other traditional approaches to health care. The requirements also undermine the training that we have completed in our graduate program and throughout our approach to leading holistic lives filled with balance between physical and mental health.

I support a revision of 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 to the following requirement:

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.