I am an occupational therapy student requesting a change in the qualifications required for OTs to become QMHPs. For over one hundred years, OTs have worked with individuals experiencing barriers to the things they need and want to do. OTs recognize that you cannot just treat a physical symptom without also considering the individual’s emotional and mental state. In fact, this connection between the mind and the body is foundational to the effectiveness of OT practice and was central to the establishment the profession. As OTs, we use occupations, or activities of personal meaning, to facilitate healing, skill building, and successful engagement with life. We utilize these unique skills in working with people across diagnoses and life stages, including in settings focused on mental health, through our education and related experiences. In particular, we are educated on psychiatric diagnoses, mental health settings, assessments, and treatments. We are further required to complete a semester-long clinical experience focused on mental health by the Accreditation Council for OT Education. Following a 2.5 year master’s or 3 year doctorate in OT, we are qualified mental health professionals. We are uniquely qualified to help people live their best lives by preventing disability and helping people adapt to life circumstances through fostering client-centered occupations that facilitate healing and growth.

       The current stringent requirements on OTs to become QMHPs in Virginia are not representative of the expansive training we receive to address individuals’ mental health needs. Our unique ability to contribute to mental health teams is already recognized by Medicare, as OT services have always been included as a billable service for individuals with mental health diagnoses. In 2013, the Center for Medicare and Medicaid services additionally required community mental health centers wishing to bill under Medicare partial hospitalization to offer OT services, thus recognizing OT as a core component of quality mental health. It is also worth noting that some states do not have any additional requirements for OTs to become QMHPs beyond the standard licensure that all OTs must maintain. Comparing this to the 1,500 hours of supervised experience currently required of OTs in Virginia further elucidates why this is not a reasonable, necessary, or prudent requirement. This requirement places undue burden on other professionals to serve in supervisory positions for longer than needed and on the OTs, who must go through approximately nine additional months of inessential training to provide services they have already been trained to administer. As currently written, requirements for OTs to become QMHPs in

      Virginia therefore not only limit the scope of our practice, but also prevent many individuals from receiving the comprehensive services they need and deserve. This requirement does not serve to protect individuals but rather decreases the quality of life they could be experiencing if they had better access to the range of services they need, including OT.

       I therefore request that requirements for registration as a QMHP-A and 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 time and attention on this important matter.