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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3/16/19  1:45 pm
Commenter: Caroline Puglia, MOTS, James Madison University

Occupational Therapists as QMHP

I am currently a first year student in the James Madison University Occupational Therapy Program. I am writing in support of the revision for the requirements for occupational therapists to become Qualified Mental Health Professionals.

Occupational Therapy treats their clients holistically. The psychosocial component of rehabilitation is essential, and contributes greatly to achieving independence in the client’s occupations. We dedicate a semester of occupational therapy school to understanding the importance and complexities of the psychosocial aspects when working with future clients.

Occupational therapists are trained to work with individuals of mental illness and cognitive impairments. We understand how these factors impact the person’s environment (socially and physically) as well as themselves as a person, and the occupational they participate in. Many work in facilities that focus on mental health such as psychiatric facilities and specific areas in hospitals. The goal of occupational therapy in this population is to help create healthy habits and routines, as well as create goals to support their independence, and well being, in society. Our field is client centered, and implements treatment plans based on the individual’s specific needs. We work together with other mental health specialists such as psychologists, psychiatrists, and social workers to achieve our client’s goals.

The current requirements to become a qualified mental health professional as an occupational therapist discredits the importance of mental health to the occupational therapy field. With the time and money required to become an occupational therapist, the added 1,500 hours with supervision may lower the amount of occupational therapists entering these practice fields. Mental health is a challenging field, which does require additional experience. However I strongly believe these requirements should reflect the merit of an occupational therapy degree. Therefore I am advocating that 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 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.