Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Counseling
 
chapter
Regulations Governing the Registration of Qualified Mental Health Professionals [18 VAC 115 ‑ 80]
Action Initial regulations for registration of Qualified Mental Health Professionals
Stage Proposed
Comment Period Ended on 4/5/2019
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4/5/19  8:19 pm
Commenter: Joni Watling

QMHP and Occupational Therapy
 

Thank you so much for the opportunity to address the Board in person in February.  There are a few things that I did not mention then that I would like to share now, on this last day of public comment.   

It was almost a year ago that I left my five-year position at Fairview / University of Minnesota Medical Center’s behavioral health department in Minneapolis, MN so my husband and I could relocate to Richmond, VA.   
At the facility, there was a robust psychiatric inpatient program – 6 adult units, 1 young adult, 1 geriatric unit and a child/adolescent unit, with more than a dozen occupational therapists employed as part of the interdisciplinary care team.  Outpatient day treatment employed another 4 occupational therapists.  The OT’s I mention are all in addition to the art, music, recreational & dance therapists also employed. Each unit also employed 2 social workers.  Members of the interdisciplinary team included registered dieticians, nurses, psychiatrists, psychologists, chaplains and pharmacologists.   Without a doubt, we all needed each other and the different perspectives each of us brought to practice and to providing culturally competent, quality, evidence-based patient care.   Incidentally, at last count Regions Hospital system in St. Paul, just over the bridge from UMMC, employed more than 20 occupational therapists combined for their inpatient, outpatient & substance abuse assessment, intervention and programming needs.  There are many other hospitals throughout the state with similar structure, although these institutions are by far the largest.

According to Mental Health America, Minnesota ranks #1 overall in mental health care rankings in comparison to Virginia, with an overall ranking of #33.   Is this due in part to occupational therapists being the norm, and not the exception, as part of mental health treatment team?   Maybe. It’s hard to say, but one certainly cannot discount a cause and effect correlation.  Minnesota’s Occupational Therapy emphasis has always been heavily mental health oriented.  The Minnesota Occupational Therapy Association holds monthly meetings & at least 90 percent of the time, the guest speaker and presentation is focused on a mental health, substance abuse or a recovery-based topic.   In comparison, because there are so few OT’s working in mental health here in Virginia (due to long existing norms & what has been an uptick in barriers to OT involvement due to QMHP regulations) the same cannot be said about Virginia’s state association (VOTA).  In particular, VOTA has strong outreach and continuing education related to school OT, in particular. 

I find myself in a strange position here in Virginia.  I am licensed in two states and teach mental health occupational therapy in an adjunct capacity at two different universities (Minnesota and Virginia). I have supervised dozens of fieldwork students & educated even more medical school students & nursing students about the role of occupational therapy – historically and currently in mental health and psychiatry.  Here, OT seems to just be pigeonholed into a physical disability /ADL or school setting paradigm. As a result, even though students are being trained and people such as myself have skill and expertise, we experience barriers – not only due to history, but due to the onerous current QMHP requirements which require 1,500 hours of supervision – often from someone with less experience working with the mental health population than we have.

Occupational therapists want to be involved in making a positive difference in the lives of others here in Virginia. There is deep need & there is a shortage of workers in mental health. With that in mind, please change the Part II Requirements for  Registration regulation  to include 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.

 Many thanks for your time and consideration. 
Joni Watling, MOT, OTR/L
Doctoral Candidate University of St. Augustine for Health Sciences
Adjunct Instructor, Virginia Commonwealth University 
Adjunct Instructor, University of Minnesota 

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