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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3/10/19  2:35 pm
Commenter: Hannah Turner, James Madison University MOTS

OT's are QMHP's

To Whom It May Concern:

            My name is Hannah Turner. I am a current Master’s of Occupational Therapy student at James Madison University.  I intend to spend my professional career practicing in the state of Virginia upon successful completion of our highly regarded program. 

            Our attention has been brought to consideration of the requirements set forth regarding OT’s as registered QMHPs in the state of Virginia. These onerous prerequisites represent unjust considerations for the level training and experience of Occupational Therapy professionals in Virginia. The following points outline qualifications held by the profession as a whole that indeed support the view of OT’s as QMHP’s by trade.

Occupational Therapy holds basic foundational tenants in psychiatry and mental health. The profession considers the body AND mind holistically for treatment. We are held to high standards and attain reputable credentials qualifying us for mental health profession titles. Entry level is expected to be masters level or above with the entire profession moving toward the latter. ACOTE presents requirements for an entire semester of OT education to be focused on mental health and psychosocial efforts with at least one 12-week fieldwork experience in the mental health field of study. Occupational Therapy provides mental health services as a stronghold to our professional ideals. Medicare/Medicaid services recognize OT as a CORE component of quality mental health treatment and holistic service. Even the difficult-to-navigate world of insurance and policies view OT as a billable service for mental health diagnoses. OT is bridging the gap between physical and behavioral health. Why does the currently proposed legislation not reflect the esteem OT has gathered in the realm of mental health and psychosocial treatment? Health services administration include OT as an integral part of the interdisciplinary behavioral health workforce team. Even authorized grant money is allocated toward mental health fieldwork training annually. Other participating states have set forth far less restrictive requirements. OT is represented in approximately half of mental health efforts and services worldwide. As a current OTS and future practicing OT in the state of Virginia…it is my hope that my home state will choose to reflect the respect and esteem the profession of Occupational Therapy has tirelessly worked toward since the foundation of the profession itself. Occupational Therapists arequalified mental health professionals by trade. I support the proposed change set forth from 

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 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.