I am writing in regards to the current regulations for occupational therapists to become Qualified Mental Healthcare Providers for adults (QMHP-A) and children (QMHP-C). I am requesting that the current burdensome requirements be changed due to the qualifications practicing occupational therapists hold upon graduating from accredited programs and the benefits they received working in.

As a student of Virginia Commonwealth University’s Occupational Therapy Doctorate program, I know first hand the ways in which an education from an accredited OT program prepares you for work in mental health settings. From learning about our profession’s roots in mental health on the first day of class to participating in a psychosocial fieldwork in my second year of the program, I have absorbed knowledge and experience that promotes a deeper understanding of the lived experience of those dealing with a mental health issue. Using evidence-based practice as well as empathetic listening - two important skills developed in OT school - I feel equipped to work with individuals with various psychosocial diagnoses and know that with a year of mentorship after of school, I would excel in this setting.

Unfortunately, only 5% of all practicing OTs work in mental health settings, as the pay differential is so great that it can hardly compensate for the cost of a masters or doctoral level education. This is unfair to the individuals who are struggling with mental health disorders and who need OT services now. With a QMHP certification, occupational therapists will better be able to negotiate for fair compensation and will further promote occupational therapy as a profession that belongs in the mental health sphere.

Therefore, I am asking that the 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.

Thank you for your time and consideration of this important issue facing our profession and, in turn, the individuals in our community who benefit from mental health-based occupational therapy services.

Sincerely,
Sara Brockman