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.