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  3:26 pm
Commenter: Mikayla Moore, James Madison University


My name is Mikayla Moore. I am an OT student at James Madison University. Upon completion from JMU’s graduate program with my Masters of Occupational Therapy, I intend to practice in the state of Virginia.

Occupational Therapy’s roots are originally grounded as a mental health profession. OT also encompasses, anatomical and neurological processes to provide interventions with meaningful purposeful occupations to motivate and enhance physiological and psychosocial health outcomes in clients. Since our founding, OT’s scope of practice has widened to numerous types of settings, while maintaining our holistic and evidence-based approach to client-centered services and care. 

In graduate school for OT we complete an extensive semester focused on psychosocial wellness involving classes, fieldwork, assessments, guest speakers, community integration, volunteer opportunities, and case studies to enhance our knowledge and understanding of practice guided by psychosocial frames of reference. According to our ACOTE Accreditation standards, C. 1. 7 indicates that “at least one fieldwork experience must address practice in behavioral health, or psychological and social factors influencing engagement in occupation.” We are required a minimum of 40 hours of fieldwork for our psychosocial concentrated setting. I personally have already dedicated over 80 hours to my mental health fieldwork setting this semester. In addition, students have the choice to direct their 12 week long, level 2 fieldwork placements with a mental health focus which add up to 1000 hours before graduating from the program. Our educational and professional background supports the mental health needs of our clients. However, our validity is still questioned by additional requirements of 1,500 hours under supervision of a social worker or other licensed mental health provider in Virginia. Current legislation undermines graduate-level degree OTs hold, work OT students and therapists continually undertake to ensure effective practice, as well as OT’s rooted values in mental health. 

With the high standards addressed above, we feel that the OT’s should be able to pursue the qualifications of QMHP with minimal barriers and cost demands, so that we may keep clients’ best interests and continue addressing mental healthin traditional and non-traditional practice settings. 

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: 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