Dear Jamie Hoyle and Board of Counseling,

I am writing to you to address Emergency Regulations for QMHP-A and QMHP-C. The occupational therapy profession is rooted in mental health. Occupational therapy practitioners take a holistic view when treating individuals, considering the connection between mind and body, and consider the client’s surrounding environment and its impact on their roles, goals, and health (including mental health). We work towards getting the client engaged in activities meaningful to them to achieve health and well-being.

Occupational therapy practitioners continue to receive significant mental health training before entering the field. Current occupational therapy training is at the graduate level. Additionally, mental health courses are required as prerequisites and specific mental health coursework is imbedded during the graduate coursework and fieldwork experiences. The The Accreditation Council for Occupational Therapy Education (ACOTE) requires occupational therapy programs to educate students on human psychology and assesses their students’ ability to address a client’s psychosocial needs before they enter the profession.

With the significant mental health needs in the Virginia, we should allow more qualified health professionals trained in mental health principles to enter the field without unduly regulations. The requirement of 1,500 hours puts a significant burden on both practitioning practitioners and future practitioners. Other states, including Oregon, Maine and Massachusetts have no additional requirements for OTs to qualify for QMHP status beyond licensure.

As a profession 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 support in helping occupational therapists provide mental health services to our community.

Sincerely,

Taylor Schwab

Occupational Therapy Doctorate Student

Virginia Commonwealth University