Agencies | Governor
Virginia Regulatory Town Hall
Department of Health Professions
Board of Counseling
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 Ends 4/5/2019
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2/22/19  10:47 pm
Commenter: Ann Moore, Shenandoah University

Occupational Therapist as QMHP


My name is Ann Moore. I am currently a master’s student in occupational therapy at Shenandoah University in Winchester, Virginia. I have one more year before I complete my degree and my plans are to practice here in Virginia after I graduate.

Occupational therapists have been working in the area of mental health helping clients develop the skills to live healthier, more satisfying daily lives since the profession began over 100 years ago. Occupational therapists have been recognized in federal legislation and by federal agencies as mental health providers and we need to do the same here in Virginia.

I am writing in support of the proposed changes to the emergency regulations for occupational therapists to register as qualified mental health providers for adults and children in the state of Virginia. I support a revision of 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 

Please consider revising the language to recognize OTs preparation at the graduate level and knowledge and practice experience in mental health. I support a change to: 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, your service to the Board of Counseling and to the Commonwealth of Virginia and your thoughtful consideration of this request. 


Ann Moore

1800 Weber Ave

Chesapeake, VA 23320


CommentID: 69248