The requirement that only a licensed professional can supervise a QMHP-E's experience towards becoming a QMHP-A or QMHP-C is particularly onerous considering the current shortage of licensed mental health professionals in the state of Virginia and could lead to a shortage of QMHP's as well. 

Please consider changing 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.

My name is Nicole Ail. I am currently a Masters student in occupational therapy at Shenandoah University in Winchester, Virginia . I have two more years before I complete my degree and my plans are to practice here in Virginia after I graduate. I have an interest in working in mental health and will be completing field work in mental health within the next year. Mental health plays a very critical role in client's needs and it is essential and neccessary to provide as much care as possible, and as soon as possible, to all of those in need.

Occupational therapists have been working in the area of mental health helping clients develop the skills to live healthier, more satisfying daily lives since the profession began over 100 years ago. Occupational therapists have  been recognized in federal legislation and by federal agencies as  mental health providers and we need to do the same here in Virginia.

I am writing in support of the proposed changes to the emergency regulations for occupational therapists to register as qualified mental health providers for adults and children in the state of Virginia. I support a revision of Part II Requirements for Registration regulation 18VAC115-80-40 B.5 to be 500 hours instead of 1,500 in order to help as many in need as soon as possible. Requirements for registration as a QMHP-A and 18VAC115-80-50 B.4. Requirements for registration as a QMHP-C 

Thank you for your time, your service to the Board of Counseling and to the Commonwealth of Virginia and your thoughtful consideration  of this request. 

Sincerely,

Nicole Ail 

224 Hackberry Drive

Stephens City, VA 22655

nail18@su.edu

By the time I had graduated with my master's in occupational therapy from VCU, I had over 60 hours of supervised Level I Fieldwork in mental health settings, and then one of my internships was in mental health (3 month placement), so I felt competent to work with individuals with mental health diagnoses. Therefore, the current regulations requiring 1,500 hours of supervision by a social worker or other licensed mental health provider for occupational therapists to register as a QMHP in Virginia seem excessive. 

I respectfully request 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 considering this request.

As a mental health occupational therapist that works for the Commonwealth of Virginia, I find it particularly troubling that we have not been included as a qualified professional under the current QMHP guidelines specific by the Commonwealth of Virginia. On one hand, the state is saying we are experts in the area of psychosocial rehabilitation, living skills, vocational skills, sensory modulation and that we play a vital role in our clients’ recovery process, but then the other is saying we are not qualified enough to be included in the QMHP, a basic credential.

Occupational therapy was founded in public psychiatric hospitals over a century ago, and the birth of Psychosocial Rehabilitation Programming in Virginia is rooted here at Western State Hospital, which is attributed largely to our Occupational Therapy Department!  It is demeaning that we have had such difficulty being included.

Our license clearly starts we are qualified to work in mental and physical health.

Additionally, occupational therapist are the most qualified professional to supervise mental health skill building programs (MH-SIS), which solely  focus on our domain: Areas of occupation (ADLS, IADLS, social participation, work and school, rest and sleep, leisure and play. With the QMHP we could finally be considered for these jobs. OTs are crossed trained, we can recognize co-occurring issues contributing to mental illness such as traumatic brain injury, or sensory processing disorders.

OTs can evaluate (and later adapt) the lived environment of home, work, school and community to identify the strengths and barriers contributing to an individual’s current status.

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.

Please look at changing the current wording to this: 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, Stephanie Williams OTD, OTR/L, CHT

Hello, my name is Suzy Gordon and I am currently an occupational therapy doctoral student at Virginia Commonwealth University. I will graduate in May and be seeking a job in mental health upon graduating. Mental health is important as it plays a very critical role in client's needs and it is essential and neccessary to provide as much care as possible, and as soon as possible, to all of those in need.

Occupational therapists have been working in the area of mental health helping clients develop the skills to live healthier, more satisfying daily lives since the profession began over 100 years ago. Occupational therapists have  been recognized in federal legislation and by federal agencies as  mental health providers and we need to do the same here in Virginia.

I am writing in support of the proposed changes to the emergency regulations for occupational therapists to register as qualified mental health providers for adults and children in the state of Virginia. I support a revision of Part II Requirements for Registration regulation 18VAC115-80-40 B.5 to be 500 hours instead of 1,500 in order to help as many in need as soon as possible. Requirements for registration as a QMHP-A and 18VAC115-80-50 B.4. Requirements for registration as a QMHP-C 

Thank you for your time, your service to the Board of Counseling and to the Commonwealth of Virginia and your thoughtful consideration  of this request. 

Sincerely,

Suzy Gordon, OTDS

Virginia Commonwealth University 

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.

I am an occupational therapy doctorate student at Murphy Deming College of Health Sciences at Mary Baldwin University. Occupational therapy uses occupation (anything that is meaningful to a person and occupies their time i.e., showering, dressing, driving to work or the grocery store, participating in work activities, leisure pursuits, and many others) as a therapeutic intervention. My profession was founded in the mental health field, and I believe should be a QMHP in the state of Virginia.

The Accreditation Council for Occupational Therapy Education (ACOTE) sets standards for entry-level occupational therapy education, which includes requirements for coursework and at least one fieldwork supervised by a licensed professional in mental health. I personally completed coursework on mental health conditions including but not limited to major depressive disorder, anxiety, eating disorders, schizophrenia, and bipolar disorder. I learned evidence-based treatments to use with individuals diagnosed with mental health disorders, the dynamics of how to run mental health groups, how to help individuals with mental health disorders reintegrate back into the community, the importance of teaching and training living and vocational skills, and much more. At the end of that semester, I completed my fieldwork at Catawba Hospital in Virginia. When individuals are reintegrated back into the community won’t they need basic living skills, won’t they need vocational skills? Occupational therapists can help.

Occupational therapists are licensed by the Virginia Board of Medicine. This license states that we as occupational therapists are qualified to work in mental and physical health. Occupational therapists are more than qualified, licensed professionals to be a QMHP in the state of Virginia.

I am asking 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 to read

18VAC115-80-40 B.5. and 18VAC115-80-50 B.4. 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, 

Carlyn Tillage, OTS

Mary Baldwin University

Murphy Deming College of Health Sciences

I am an occupational therapy doctorate student at Murphy Deming College of Health Sciences at Mary Baldwin University. Occupational therapy uses occupation as its core means of therapeutic intervention. Occupations are those life roles and routines that have meaning to clients and can include everyday tasks such as showering, preparing meals, and getting dressed, to more complex roles such as work, education, and leisure activities. My profession was founded in the mental health field during the era of the reconstruction aids, as meaingful occupation was used to enhance quality of life and overall well-being for servicemen returning from the war. In light of our roots and how OT presently continues to be a vital tool in mental health rehabilitation, I believe OTs should receive recongnition as QMHPs in the state of Virginia.

The Accreditation Council for Occupational Therapy Education (ACOTE) sets standards for entry-level occupational therapy education, which includes requirements for coursework and at least one fieldwork supervised by a licensed professional in mental health. I personally completed didactic coursework on mental health conditions including but not limited to major depressive disorder, anxiety, eating disorders, schizophrenia, and bipolar disorder. In addition to this course, our curriculum also requires that we complete didactic coursework specifically addressing the various psychosocial aspects of health. Through these courses I have learned evidence-based treatments to use with individuals diagnosed with mental health disorders, how to facilitate mental health treatment groups, and the valueable role that OT has in helping these clients return to community and vocational roles. At the end of that semester, I completed my fieldwork at Virginia Baptist Hospital in Lynchburg. On weekends I have also worked at Western State Hospital as part of the weekend programming staff to facilitate carry-over of the group therapy programs that occur with the weekday rehab team. I developed rapport with my clients and heard stories of how they struggled to maintain a daily routine, how they felt isolated within their community, and struggled to maintain employment, balance finances, and even cook daily meals. These struggles within this population are the core of the OT profession. We have a role. We can help.

Occupational therapists are licensed by the Virginia Board of Medicine. This license states that we as occupational therapists are qualified to work in mental and physical health. Occupational therapists are more than qualified, licensed professionals to be a QMHP in the state of Virginia.

I am asking 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 to read

18VAC115-80-40 B.5. and 18VAC115-80-50 B.4. 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, 

Amanda McGoye, OTS

Mary Baldwin University

Murphy Deming College of Health Sciences

My name is Ann Moore. I am currently a master’s student in occupational therapy at Shenandoah University in Winchester, Virginia. I have one more year before I complete my degree and my plans are to practice here in Virginia after I graduate.

Occupational therapists have been working in the area of mental health helping clients develop the skills to live healthier, more satisfying daily lives since the profession began over 100 years ago. Occupational therapists have been recognized in federal legislation and by federal agencies as mental health providers and we need to do the same here in Virginia.

I am writing in support of the proposed changes to the emergency regulations for occupational therapists to register as qualified mental health providers for adults and children in the state of Virginia. 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 

Please consider revising the language to recognize OTs preparation at the graduate level and knowledge and practice experience in mental health. I support a change 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.

Thank you for your time, your service to the Board of Counseling and to the Commonwealth of Virginia and your thoughtful consideration of this request. 

Sincerely,

Ann Moore

1800 Weber Ave

Chesapeake, VA 23320

amoore172@su.edu

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 

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.

We are 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.

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

Occupational therapists work with people of all ages to promote independence and functionality in their everyday lives regardless of injury, illness, or diagnoses.  We take three semesters of courses that are dedicated to different specialty areas, one of which is psychosocial and mental health OT practice.  We are taking two classes focusing specifically on this area of practice: Psychosocial Perspectives in Occupational Therapy and a case-based learning course with cases heavy in the psychosocial and mental health practice of occupational therapy.  However, psychosocial aspects of treatment are embedded throughout the entire program.

As an occupational therapy student, I am trained to treat each individual holistically and to put their best interest and goals at the heart of my client-centered practice.  We are trained as generalists, so we will be prepared to practice in a wide variety of settings as stated in ACOTE standard 5.1.  Mental health settings are included in this standard.  One component of our training that facilitates this readiness is our completion of “at least one fieldwork experience (either Level I or Level II) must address practice in behavioral health, or psychological and social factors influencing engagement in occupation” as stated in ACOTE standard 7.1. 

Master’s and Doctoral occupational therapy programs yield therapists prepared to work in mental health settings to provide care for individuals with psychosocial goals who are working towards independent and meaningful lives.  Occupational therapists who hold a master’s degree or higher should be able to register for the QMHP title under the same requirements as those who hold a master’s degree from a psychology, social work, counseling, substance abuse, or marriage and family therapy program.  Occupational therapists have been practicing in mental health since the foundation of the profession, whose founders included psychiatrist Dr. William Dunton and social worker Eleanor Clark Slagle. 

Individuals receiving mental health services in Virginia would benefit from occupational therapists with QMHP certicfication.  The services we provide are geared towards living independent, full lives that all individuals deserve the chance to lead.

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.

I am an occupational therapy student who has completed one 480 hour fieldwork in a transitional living facility for individuals with Schizophrenia or Bipolar Disorder, a 480 hour fieldwork in long-term care for individuals with severe traumatic brain injury (some whose injuries were the self-inflicted results of mental health issues and many of whom have developed mental health problems since their injury), and who is currently in the midst of a 560 hour Doctoral Capstone project working with individuals recovering from substance use disorder, homelessness, and a history of incarceration. My academic and experiential education has prepared me to work successfully with this population. I believe that the current emergency regulations for occupational therapists promulgated by the Board of Counseling are unduly and unnecessarily onerous. They will prohibit current and future occupational therapists like myself from pursuing QMHP registration.

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 emergency regulations that currently read:

B. 5. A licensed occupational therapist with no less than 1,500 hours of supervised experience to be obtained within a five-year period immediately preceding application for registration and as specified in subsection C of this section. (Subsection C requires that the supervision occur of a licensed mental health professional or a person under supervision that has been approved by the Boards of Counseling, Psychology, or Social Work as a pre-requisite for licensure.)

AND

B. 4. A licensed occupational therapist with no less than 1,500 hours of supervised experience to be obtained within a five-year period immediately preceding application for registration and as specified in subsection C of this section.

And that they be replaced with criteria that has the potential to expand the appropriately qualified behavioral health workforce. We suggest the following replacement:

18VAC115-80-40 B.5. and 18VAC115-80-50 B.4. 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.

Occupational therapists have been eligible for licensure as a QMHP without extra requirements in a handful of states including Oregon, Maine, and Massachusetts. Entry level Occupational Therapy degrees are currently at the minimum of a Masters level. 29 universities including Virginia Commonwealth University have already achieved accreditation at an entry level doctoral degree. Another 107 programs nationwide are in the process of developing an OTD degree. The Accreditation Council for Occupational Therapy Education (ACOTE) sets the standards for entry-level occupational therapy education programs and they include extensive requirements that include at least one mental health fieldwork experience.

Occupational Therapy is a profession that was founded by two psychiatrists, a nurse, a social worker, an architect, a crafts instructor, and a consumer who recognized the value of engagement in occupation to restore health and well-being. Mental Health is and has always been the core of occupational therapy services and intensely connected with physical health and participation in the community at-large.

Our society is in the midst of an opioid epidemic. In 2016, 64,070 Americans died from a drug overdose. This is more than the 58,220 soldiers who died in the entire Vietnam War, and is even more than the 50,682 who died in the worst year of the AIDS crisis. In 2016, in Virginia alone, 1,130 of our fellow citizens died of an opioid-related overdose. This is way too high. We need as many people working with these individuals as we can to turn this epidemic around. The current emergency regulations are preventing qualified occupational therapists from serving our population and our state.  

I am a student of the Occupational Therapy Program at James Madison University, in which I will receive a Master’s degree upon graduation. I plan to practice in Virginia after I graduate in December 2020. According to the accreditation standards for a master’s degree-level educational program for occupational therapists, “at least one fieldwork experience must address practice in behavioral health, or psychological and social factors influencing engagement in occupation” as stated in ACOTE standard C.1.7. I am currently completing a psychosocial level I fieldwork in which many of my classmates are in traditional mental health settings. Throughout the rest of my time in school I will be completing two more level I fieldworks with a minimum of 40 hours in each, as well as, two level II fieldworks with about 480 hours each (both are 3 months in duration). Any of these fieldworks could be completed in a mental health setting.

As a student in an occupational therapy program, we also trained to work in a variety of different settings including practice in a mental health setting, as stated in ACOTE standard A.5.1. We take courses throughout the program that ready us for work in the psychosocial and mental health fields, as well as having psychosocial aspects built into every course that we take.

Occupational therapy as a profession was founded in the field of mental health and has continued to practice in this area for over 100 years. Occupational therapists who hold a master’s level degree or higher should be able to obtain the title of QMHP under the same requirements as individuals who hold a masters degree in the fields of psychology, social work, counseling, substance abuse, or marriage and family therapy program.

Occupational therapy intervention within the field of mental health is crucial and we are trained with the knowledge and skills to help individuals seeking services to improve their lives, level of independence, and their integration into society.

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 

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.

Thank you for your time and consideration of this request.  

Dr Hoyle,

I am writing to ask you to reduce the restriction on QMHP requirements for Occupational Therapists in Virginia.  I have been an Occupational Therapist in Virginia for over 20 years.  I work with the frail elderly population at the Program of All Inclusive Care for the Elderly.  I have also been an adjunct Lab Professor for St. Catherine University for 2 years.  Part of my lab instruction involves teaching Occupational Therapy Assistant Students interview and treatment strategies for working with mental health conditions.  

EDUCATION AND LICENSURE

?     OT education is at the graduate level.  Since 2007, a master’s degree has been the educational requirement for entry into the profession. Currently 29 universities are accredited to offer Occupational Therapy Doctorate (OTD) degrees, including two in Virginia, Virginia Commonwealth University and Mary Baldwin University. Another 107 programs are in the development process to offer OTD degrees.  The remaining 177 schools offer programs at the Masters level, including five Virginia schools - Emory & Henry College, Jefferson College of Health Sciences, James Madison University, Radford University, and Shenandoah University.
 

?     The Accreditation Council for Occupational Therapy Education (ACOTE) sets standards for entry-level occupational therapy education programs and those standards include extensive requirements for coursework and at least one fieldwork experience focused on mental health
 

• OTs are required to pass a national certification exam and are licensed in all states. OTs in Virginia are licensed by the Board of Medicine, which must be renewed every two years.    

 QMHP REQUIREMENTS IN OTHER STATES

• While some states, like Oregon, Maine and Massachusettshave no additional requirements for OTs to qualify for QMHP status beyond licensure. Other states, including Illinois, require licensure and one year of clinical experience in a mental health setting. Missouri recognizes OTswith Master’s degrees who have completed a practicum in a psychiatric settingor who have had one year of experience in a psychiatric setting.

MENTAL HEALTH OT WORLDWIDE

?In countries where national health insurance exists, like the UK, Canada and Australia, health care team members are paid equivalently for the provision of mental healthcare services as for physical healthcare services. In those countries 50% of the OT workforce works in mental health. In the US the number of OT practitioners pursuing careers in mental health is under 5% because of the pay differential and the cost of education.

Again, please consider reducing these restrictions on OTs, as I feel this willl prohibit OTs from pursuing QMHP registration.  We need more health care professionals in the community who are willing to treat children and adults who have a variety of mental health conditions.

Respectfully, 

Maria Binns Cannady, OTR/L

Regardless of the practice setting, diagnosis, etc., occupational therapists are addressing the psychosocial needs of our patients. We are trained to treat the whole person including the brain and mind. A foundation in mental health is crucial to attend to our patients' needs, thus our coursework and education speaks to neurological structures and functions; mental health diagnoses and dysfunctions; and neurological, cognitive, perceptual, and psychosocial assessments and interventions, to name a few. 

The current legislation regarding occupational therapists as QMPHs is unduely and unneccessary. By education, trade, and definition, occupational therapists are qualified to work as mental health care providers. Furthermore, other professions acting as gatekeepers to services that are already in OT's scope of practice can create competition or tension in the workplace, among professions, and among practictioners. Lastly, the current legislation undermines our profession as occupational therapists and fails to recognize it as a graduate level degree. 

For these reasons and more, 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.

I am a Master's of Occupational Therapy student at James Madison University. I have been learning about the wonderous field of psychosocial and mental health and our role as future OT's and have felt a passion awaken in me. I came into this program with the very strong mindset of becoming a Pediatric OT. I recognized my interest and curiosity in the mental health field as well but shyed away from it until this semester when I was placed at Western State Hospital for my first Level I placement. This placement has evolved my interest in mental health to a much more involved perspective. 

I am originally from Maryland but have gone to secondary school in Virginia, first at Lynchburg College and now at JMU. I feel at home in this part of the state and have plans to stay in this general area to practice. Learning about the current requirements of OT's to become QMHP strikes me as being slightly extra work that could potentially be more cost-effective instead of beneficial for all professionals involved. The professionals who must train and supervise us for the extensive 1500 hours would have even more responsibilities placed on them that would not be necessary. I believe a requirement of 500 hours would be more doable and beneficial to all involved because there are phenomenon that we as OT's must be taught in this field, but also we operate through the lens of person-first therapy, where we consider a person's values, psychosocial factors as some of the most central factors to their success. We are trained to view a person as an active agent that is also highly influenced by their psychosocial factors. We are also sensitized to the reality of many mental health conditions and are taught effective interactive skills to empathize with clients.

I feel that we as Occupational Therapists, will have the skills and tools necessary to be considered QMHP, and that the requirement of 1500 hours to be certified QMHP may be redundant while a requirement of 500 hours supervision and training may be more beneficial to all involved. We are 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. 

Taylor Neiser, MOTS

Occupational Therapy originated as a mental health profession providing occupation and activity-based interventions with the idea that meaningful tasks provide more motivation and better health outcomes in clients, both physiologically and psychosocially. While our scope of practice has widened, our holistic foundation and approach to intervention remains the same; psychosocial concepts of individual’s health, recovery, or rehabilitation must be addressed in order to provide true client-centered and effective care.  

Occupational therapists are not only trained in mental health, but also anatomical and neurological processes associated with physiological and psychological function. As a profession that began in the very field of mental health where their validity is currently being questioned, it is imperative that Occupational Therapists be able to pursue the qualifications of QMHP with minimal barriers so that they may continue to address the current mental health crisis that is sweeping the nation. The current legislation undermines the graduate-level degree that Occupational Therapists hold, as well as the value they hold in the field of health professions, and more importantly, that of mental health.

As an MOT student at James Madison University and possible future QMHP, I stand behind the move to change 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 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."

We are 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.

Changes to requirements for registration as a QMHP-C

We are 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.

We are 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.

With a strong foundation in mental health practice from our roots as a profession, we as occupational therapists believe that the emergency regulations for occupational therapists promulgated by the Board of Counseling are unduly and unnecessarily onerous. They will prohibit OTs from pursuing QMHP registration. We are 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 emergency regulations that currently read:

B. 5. A licensed occupational therapist with no less than 1,500 hours of supervised experience to be obtained within a five-year period immediately preceding application for registration and as specified in subsection C of this section. (Subsection C requires that the supervision occur of a licensed mental health professional or a person under supervision that has been approved by the Boards of Counseling, Psychology, or Social Work as a pre-requisite for licensure.)
AND
B. 4. A licensed occupational therapist with no less than 1,500 hours of supervised experience to be obtained within a five-year period immediately preceding application for registration and as specified in subsection C of this section.

And that they be replaced with criteria that has the potential to expand the behavioral health workforce. We suggest the following replacement:

18VAC115-80-40 B.5. and 18VAC115-80-50 B.4. 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.

My name is Gretchen Ward, I am an occupational therapist working with children, youth, and young adults at 2 private clinics in the state of VA. I previously was employed by Grafton Integrated Health Network working in behavioral health care and have 9 years of occupational therapy experience in school based and early intervention practice. I am a member of the AOTA School Based Mental Health community of practice and serve as the Policy and Advocacy coordinator for the AOTA Children and Youth Special Interest section. I also serve as the Communications Chairperson for the Virginia Occupational Therapy Association. 

Mental Health is at the core of our profession as occupational therapitsts and the holistic approach of how mental, physical, and social aspects of a person impact their well being is what sets occupational therapy apart from other health professions. Students of occupational therapy complete at least one clinical learning experience in the area of mental health and are required to learn psychosocial skills in order to complete their education. I was excited to see the Virginia was leading the way recognizing occupational therapists as qualified mental health professionals, however was dismayed when I attempted to register to find an additional requirement of 1500 hours of supervision, that is not clearly defined. This requirement is an undue burden that does not take into consideration the level of education or experience of many practicing occupational therapists. 

We are 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.

This change of requirement would account for the experience of those who have been working in mental health settings and the clinical component of the education for future occupational therapists looking to work in mental health. 

Thank you for the opportunity to comment and your consideration, 

Gretchen R. Ward, MS, OTR/L 

9144 Kershaw Ct. 

Manassas, VA 20110 

I am currently a student of the Master's of Occupational Therapy Program at James Madison University. I plan to practice in the state of Virginia upon completion of this program. After spending the summer session discussing the history of occuaptional therapy in the field of mental health, this topic is extremely confusing that we should have to argue to stay in the field we began in. Mental health is one of the largest parts of occupaitonal therapy and it is addressed in every setting with each client based on their specific needs. It is unreasonable to require that a different profession be in charge of our qualification in this area. In each OT program, students are trained in assessments, interventions, and mindfulness of the mental health aspects involved in each area of OT. We are trained to become professionals in this topic in order to assist our future clients. If OTs become QMHPs then there will be more resources for this mental health crisis we are currently facing. We are a holistic profession that believes in treating the mind as much as the body. This revision should be made in order to allow OTs to become QMHPs. 

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 

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.

Thank you for your time and consideration of this request.  

I am an occupationaly therapy doctoral student at Murphy Deming College of Health Sciences at Mary Baldwin University writing on behalf of my future profession. For over 100 years now, occupational therapy has proven an effective intervention for those with mental illness. In all OT programs across the country--both master's or doctorate level--students receive countless hours of education on psychosocial rehabilitative care for patients of all diagnoses, but especially those with mental illness. To obtain a state license to practice occupational therapy, one must display deep levels of understanding of how to provide patient-centered, individualized therapy to those with mental illness. Mental health is where our profession started; it is a setting in which the purpose of occupational therapy shines through. 

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. 

We are 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.

I am an OT student at James Madison University, and upon graduation with my Master of Occupational Therapy I intend to practice in the state of Virginia.

Mental health and well-being is undeniably an integral part of occupational therapy practice; the profession itself was founded, in part, by mental health practitioners. Additionally, 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.” While this indicates a minimum of 40 hours of fieldwork with a mental health concentration, a student could direct their level 2 fieldwork placements to have gathered 1000 hours of fieldwork with a mental health emphasis before graduating from the program. In the JMU OT program we have an entire semester concentrated on psychosocial and mental health, with classes, fieldwork, and gathering of materials in preparation for practice all guided by psychosocial frames of reference. Psychosocial issues are continuously addressed outside of this semster also. Although trained as generalists, we are well educated and prepared to provide support and treatment for the mental health needs of our clients. Approaching all clients with a holistic perspective, even clients who are not seen in a traditional mental health setting will have their mental wellbeing considered by their occupational therapist.

The title of QMHP should be allowed to occupational therapists who graduate with a master's degree or higher under the same requirements as those who graduate in psychology, social work, counseling, substance abuse, or marriage and family therapy program. To deny us this is to deny the validity of occupational therapy as an equal graduate program and profession, and undermines the extensive work occupational therapy students undertake to ensure they can effectively address the mental health needs of their clients. It is not in the best interest of our clients to have extra barriers to gain QMHP status, as it could likely lead to increased costs of treatment due to increased cost on the therapist's part to gain this title. Across the United States there is already far too little access to quality mental health care, and it does not make sense to create even more barriers.

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

We are 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.

As occupational therapy practitioners with many years of experience in working and teaching courses in mental health OT, and who have pursued legislation to attain QMHP status through the lobbying efforts of our Virginia Occupational Therapy Association, we believe that the emergency regulations for occupational therapists promulgated by the Board of Counseling are unduly and unnecessarily onerous. They will prohibit OTs from pursuing QMHP registration. We are 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 emergency regulations that currently read:: B. 5. A licensed occupational therapist with no less than 1,500 hours of supervised experience to be obtained within a five-year period immediately preceding application for registration and as specified in subsection C of this section. (Subsection C requires that the supervision occur of a licensed mental health professional or a person under supervision that has been approved by the Boards of Counseling, Psychology, or Social Work as a pre-requisite for licensure.) AND B. 4. A licensed occupational therapist with no less than 1,500 hours of supervised experience to be obtained within a five-year period immediately preceding application for registration and as specified in subsection C of this section. And that they be replaced with criteria that has the potential to expand the behavioral health workforce. We suggest the following replacement: 18VAC115-80-40 B.5. and 18VAC115-80-50 B.4. 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.

TAs occupational therapy practitioners with many years of experience in working and teaching courses in mental health OT, and who have pursued legislation to attain QMHP status through the lobbying efforts of our Virginia Occupational Therapy Association, we believe that the emergency regulations for occupational therapists promulgated by the Board of Counseling are unduly and unnecessarily onerous. They will prohibit OTs from pursuing QMHP registration. We are 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 emergency regulations that currently read:: B. 5. A licensed occupational therapist with no less than 1,500 hours of supervised experience to be obtained within a five-year period immediately preceding application for registration and as specified in subsection C of this section. (Subsection C requires that the supervision occur of a licensed mental health professional or a person under supervision that has been approved by the Boards of Counseling, Psychology, or Social Work as a pre-requisite for licensure.) AND B. 4. A licensed occupational therapist with no less than 1,500 hours of supervised experience to be obtained within a five-year period immediately preceding application for registration and as specified in subsection C of this section. And that they be replaced with criteria that has the potential to expand the behavioral health workforce. We suggest the following replacement: 18VAC115-80-40 B.5. and 18VAC115-80-50 B.4. 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.ype over this text and enter your comments here. You are limited to approximately 3000 words.

We feel that the requirements of gaining 1,500 hours under the supervision of a social worker or other licensed mental health provider in Virginia are burdensome for a professional with a master degree or higher. In our graduate work, our studies of mental health are extensive and of high importance. 

We are 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.

   I am a Master of Occupational Therapy student from James Madison University. I plan to practice in the state of Virginia for the entirety of my career following completion of the program.

   Occupational Therapy as a profession is rooted in the fields of psychology, social work, medical practice, and rehabilitation. We are trained to see individuals in a holistic manner, looking at the needs of people from both the physical and psychosocial aspect in order to truly improve a person’s quality of life and/or independence. This is pulled directly from the QMHP Frequently Asked Questions page provided on the Commonwealth of Virginia Board of Counseling’s website as qualifications for QMHP-A prior to December 31, 2017: “Master’s degree in psychology, social work, counseling, substance abuse, or marriage and family therapy from an accredited college or university, you need: • To submit a transcript • Evidence you have had an internship or practicum of at least 500 hours of experience with persons who have a mental illness. (Verification of Internship/Practicum for QMHP form)” (VA Dept. of Health Professions, 2018). It doesn’t make sense to me that other fields that Occupational Therapy is rooted and grounded in by theory, intervention, evidence-based practices, and overarching goals are only required to have a Master’s degree and provide evidence of at least 500 hours of experience with persons who have a mental illness when we as Master’s of Occupational Therapy students will complete our program obtaining over 1,000 hours of clinical experience. Occupational Therapists work with people who are experiencing mental health crises and difficulties in all settings, practices, and with all populations. We devote an entire semester of our graduate program with a primary focus on mental health issues and how to address those as practitioners. Even though we have one semester devoted to this, we continually learn and practice those skills in every course we take and within every fieldwork, clinical experience, and volunteer experiences we partake in throughout the program. It seems excessive to place more requirements upon OTs who wish to gain the QMHP title in order to do the same job they have already been prepared to do. These proposed requirements may take time away from much needed research in the field of Occupational Therapy to show evidence that a holistic approach to treating individuals is more effective at increasing the quality of life and decreasing the mental health crises facing our nation today than other traditional approaches to health care. The requirements also undermine the training that we have completed in our graduate program and throughout our approach to leading holistic lives filled with balance between physical and mental health.

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 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.

We are 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.

The regulations that require 1500 hours of supervision are the main area of concern for me as an occupational therapist. I work in outpatient therapy, and know of no other health professional who is available to directly supervise me on a daily basis in order to obtain these hours. I would also not be able to pay them for these hours, and therefore I have no idea how I could motivate someone to come to my setting to actively supervise me. I am unable to practice in any other location to acheive these hours, because my work hours are set. The training and supervision we receive on Fieldwork Level 2 (6 months total) during our eduction (Masters level) should qualify us for this title. 

We are 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.

The requirement that an LMHP-Type provider must supervise a QMHP-E's experience towards becoming either a QMHP-A or QMHP-C will be detrimental to the public behavioral healthcare system.  There is currently a shortage of licensed mental health professionals in Virginia's public behavioral healthcare system.  Continuing this requirement is excessive. 

Occupational therapists (OTs) in Virginia are now permitted to serve as Qualified Mental Healthcare Providers for adults (QMHP-A) and children (QMHP-C). Unfortunately, the proposed regulations for how an OT can become a QMHP include unduly onerous requirements that do not recognize that OTs enter the profession only after graduate-level training. Because of their training and the history of the profession, OTs are well qualified to serve as mental health providers. Given the shortage of providers for much-needed mental health care, it's vital for Virginia to take steps to expand the pool of professionals who can provide this care.

Currently, the regulations require OTs to have 1,500 hours of supervision by a social worker or other licensed mental health provider in Virginia in order to apply. I ask 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 consideration. 

Please consider that the roots of occupational therapy lie in mental health. Students currently being prepared to enter the field are undergoing appropriate preparation, from acadamic work to fieldwork, to enter the workforce in the field of mental health.

We are 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.

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.

I am currently a first-year Master's student in the JMU occupational therapy program. As such, I have learned about the fascinating history of how occupational therapy came to be. The profession began in mental health and evolved into a widespread practice that can be applied to a variety of settings. The foundational concept of occupational therapy is to view a person holistically in order to provide care for the overall well-being of a client. Mental health is an essential part of occupational therapy and is woven into each setting, even those that are not strictly mental health.

In my program we spend an entire semester learning about psychosocial occupational therapy and at this time we are placed in our first level I fieldwork in relation to mental health. I believe the reason for this is because mental health is a crucial building block to all occupational therapy practices and should be considered by great therapists when treating a client for any particular reason. Therefore, recieving a QMHP certification should be more accessible to occupational therapists as it is a major part of the profession and the current regulations do not honor that as it does to other equally qualified professions. 

For that reason, I am strongly 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.

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.

Occupational Therapy is already recognized and practiced in mental health settings. It is a profession that was originally founded on the basis of fair treatment of those with psychiatric disorders during the Moral Treatment Era. Given this, the curriculum for an accredited Master’s program like that of James Madison University dedicates classes to mental health disorders, psychosocial perspectives, neuroscience, and mental health related level 1 fieldwork. This specific fieldwork accounts for roughly 100 hours of time spent with a mental health population, plus 10 credit hours of classes primarily focused on mental health/neuroscience. All this does not include the possibility of selecting a mental health level 2 fieldwork; accounting for 12 weeks of full-time work at the facility. In addition, Occupational Therapy takes a holistic approach so all classes incorporate mental health in some manner. Given this plethora of time spent on the topic, Occupational Therapists graduate with strong background knowledge in mental health practice. 

With such strong ties to mental health, Occupational Therapists are drawn towards these mental health practice settings; however, I am afraid the requirements for becoming a Qualified Mental Health Practitioner may lower the number of Occupational Therapists entering these practice areas. As the profession begins moving towards a doctorate level program, people are spending greater amounts of time and money to become registered and licensed Occupational Therapists so an additional 1,500 hour requirement seems to discredit the profession. Not only this, but supervision of these hours under another health care professional prompts concerns regarding interprofessional collaboration; an area that has been identified in the United States health care system as needing improvement. 

I am not against additional requirements for becoming a certified Qualified Mental Health Practitioner; 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.

.

The supervision requirements continue to be too stringent.  Requiring a QMHP to have been supervised by someone with a license will continue to create hiring hardships.  It is appreciated that experience and supervision in other juristictions will now be allowed to count.

We often get staff that have significant experience providing services in another country.  The present language does not allow for consideration of that experience.  The regulatory language should be trained to allow for that experience.

Thanks

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.

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

My name is Jalisa Johnson. I am currently a Master of Occupational Therapy student at James Madison University, whom plans to practice and serve in the state of Virginia upon receiving licensure. One facet of occupational therapy that I cherish is our advocacy for mental health. Mental health is a fundamental aspect of occupational therapy, as it is embedded in the foundation of our profession. It globally impacts functional independence, solidifying the necessity for occupational therapy involvement, advocacy, and services. The role of occupational therapy and its importance in mental health is continually expressed within each course of my MOT program, as well as in my fieldwork placements.

All Occupational Therapists are required to take and pass a national exam and obtain licensure prior to practicing. This national exam encompasses all aspects of the human being, including the influences of mental health and management. With that being said, I believe Occupational Therapists are currently servicing as QMHPs and specific training to enhance our skills and practice is welcomed and valued. With that being said, the undue requirement of 1500 hours deserves review and amending prior to implementing this regulation.

We are 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 attention and consideration.

Sincerely,

Jalisa Johnson, MS, MOTS

The current regulations require that an applicant's experience be supervised by a Virginia licensed mental health provider or a person that is approved for supervision toward licensure in Virginia.  This creates a significant recruitment barrrier, preventing employers from giving fair consideration to applicants with experience from out of state.  Out of State experience should be considered based on equivalency of roles.