Agencies | Governor
Virginia Regulatory Town Hall
Department of Health Professions
Board of Counseling
Regulations Governing the Registration of Qualified Mental Health Professionals [under development] [18 VAC 115 ‑ 80]
Action Initial regulations for registration of Qualified Mental Health Professionals
Stage Proposed
Comment Period Ends 4/5/2019
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2/21/19  9:42 pm
Commenter: Carlyn Tillage, Mary Baldwin University - MDCHS

Occupational Therapists as QMHP

I am an occupational therapy doctorate student at Murphy Deming College of Health Sciences at Mary Baldwin University. Occupational therapy uses occupation (anything that is meaningful to a person and occupies their time i.e., showering, dressing, driving to work or the grocery store, participating in work activities, leisure pursuits, and many others) as a therapeutic intervention. My profession was founded in the mental health field, and I believe should be a QMHP in the state of Virginia.

The Accreditation Council for Occupational Therapy Education (ACOTE) sets standards for entry-level occupational therapy education, which includes requirements for coursework and at least one fieldwork supervised by a licensed professional in mental health. I personally completed coursework on mental health conditions including but not limited to major depressive disorder, anxiety, eating disorders, schizophrenia, and bipolar disorder. I learned evidence-based treatments to use with individuals diagnosed with mental health disorders, the dynamics of how to run mental health groups, how to help individuals with mental health disorders reintegrate back into the community, the importance of teaching and training living and vocational skills, and much more. At the end of that semester, I completed my fieldwork at Catawba Hospital in Virginia. When individuals are reintegrated back into the community won’t they need basic living skills, won’t they need vocational skills? Occupational therapists can help.

Occupational therapists are licensed by the Virginia Board of Medicine. This license states that we as occupational therapists are qualified to work in mental and physical health. Occupational therapists are more than qualified, licensed professionals to be a QMHP in the state of Virginia.

I am asking that 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 to read

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, 

Carlyn Tillage, OTS

Mary Baldwin University

Murphy Deming College of Health Sciences