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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3/7/19  12:18 pm
Commenter: McKenna Weeks, OTS, James Madison University

Occupational Therapists as QMHP

I am a current occupational therapy student at James Madison University in Harrisonburg, VA. I have lived in Virginia all my life, and I plan to practice here after successful completion of the program. 

Occupational therapy programs across the country use a structured curriculum to prepare students to practice in a variety of settings including mental health. We are trained to treat clients in a holistic manner. This allows us to plan interventions that address the person as a whole to reach a state of physical, mental, and social well-being. According to the Occupational Therapy Practice Framework 3rd edition, we are competent to consider a variety of specific and global mental functions when working with clients regardless of the practice setting. These functions include thought (control and content of thought, awareness of reality vs. delusions, logical and coherent thought), higher-level cognitive (judgment, concept formation, metacognition, executive functions, praxis, cognitive flexibility, insight), emotional (regulation and range of emotions), attention, memory, consciousness, orientation, perception, temperament and personality, and more.

At JMU, we dedicate an entire semester to learning about mental health conditions, assessments, and interventions and relate them to various psychosocial frames of reference. As graduate-level professionals that receive this education in addition to hours of clinical observation and fieldwork, I believe that we deserve to be recognized as Qualified Mental Health Professionals. Occupational therapy has proven to be a successful mental health intervention for numerous years as this is where our profession originated and continues to thrive.

For these reasons, 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 

to 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.