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.