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.