I would like to speak to the the proposed regulations for Occupational Therapists to become Qualified Mental Healthcare Providers for adults (QMHP-A) and children (QMHP-C). The current proposal would require an Occupational Therapist to have 1,500 hours of supervision by a social worker or other licensed mental health provider in Virginia. There are several important reasons why this requirement is excessive and unnecessary.

      The profession of Occupational Therapy began in mental health settings. It was officially founded by a team which included two psychiatrists, a nurse, a social worker, an architect, a crafts instructor, and a consumer. With this foundation occupational therapists recognize the importance of the mind-body connection, and use occupation to address both physical and mental health.

       Today, occupational therapists are required to obtain a Masters or Doctorate degree to enter the field. These programs must align with the Accreditation Council for Occupational Therapy Education (ACOTE) standards. One of the standards includes extensive requirements for coursework and at least one fieldwork experience focused on mental health. As a current student of Virginia Commonwealth University’s Occupational Therapy Doctorate program, I can personally attest to the significant and thorough educational focus on mental health.

      Occupational Therapy continues to be recognized as a profession well suited to provide mental health services. The Center for Medicare and Medicaid Services (CMS) included Occupational Therapy as a core component of mental health in 2013. In 2015, the Substance Abuse Mental Health Services Administration (SAMHSA) included occupational therapists in staffing suggestions for new Certified Community Behavioral Health Centers. Occupational therapy education programs became eligible to receive grant funding through the Behavioral Health Workforce Education Training Grant (BHWET) which was reauthorized by Congress in 2016. Last year, the Health Resources Service Administration (HRSA) included occupational therapy as a member of a behavioral health workforce. Occupational therapy was also included in the Substance Use-Disorder Prevention that Promotes Opioid Recovery and Treatment (SUPPORT) for Patients and Communities Act.

      It is also important to recognize the varying requirements for occupational therapists to become QMHPs. Some states have no additional requirements beyond licensure. Some states require one year of clinical experience in a mental health setting, while others require a practicum in a psychiatric setting.

      Important information can be drawn from other countries on the involvement of occupational therapy in mental health. In the UK, Canada, and Australia health care providers are paid equally for the provision of mental healthcare services and physical healthcare services. In those countries 50% of occupational therapists work in mental health. In the U.S. the number of OT practitioners pursuing careers in mental health is under 5%. This fact holds significant relation for occupational therapy students and new graduates in pursuing careers in mental health. In addition to the pay differential and cost of education, cumbersome state requirements will likely discourage occupational therapists from entering mental health; an area of healthcare that could benefit from increased inclusion of occupational therapists.

      As an occupational therapy student I have profound concern for the future of occupational therapy and the field of mental health. 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 to 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.

Thank you for your time and consideration.

Sincerely,

            Katherine Howe, OTS