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
Stage Proposed
Comment Period Ends 4/5/2019
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2/19/19  1:23 pm
Commenter: Rachel Isak-Peer


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.