I am an associate professor of counselor education at an R1 institution in Virginia. I have carefully reviewed the requirements for Licensed Substance Abuse Treatment Practitioners (LSATPs) and they are nearly identical to the standards set forth by CACREP for Licensed Professional Counselors (LPCs). Of all the proposed pathways in mental health that I have seen presented in recent years (some of which are equally insulting and terrifying), this seems straightforward and stringent, particularly given the standards set forth by the Virginia Board of Counseling.

Why would this not be an option for LSATPs? I suspect it is because the CACREP has a monopoly on graduate programs and the counseling profession in general. While I strongly support accreditation standards, we are in the midst of a public mental health crisis. I believe the CACREP has outdated standards and is in desperate need diverse and alternative pathways to help those, like LSATPs, earn LPC credentials. 

In our CACREP-accredited graduate program, our students take one class on substance use. They graduate able to either work provisionally in a school setting (two years before fully licensed) or provisionally as a resident counselor under the supervision of an LPC-S (3400 hours) and they see students and clients battling addictions. One could easily argue this is not nearly enough, but we don't because CACREP states it is fine and the graduate program checked a box. In fact, all of the areas the the CACREP mentioned in their comment are typically one class in graduate school. While there are specialization tracks, they are not necessary to become an LPC. 

The VA Board of Counseling could easily require a simple respecialization pathway, too. We need more licensed counselors in Virginia, not less.