Action | Time-limited Waiver of Certain Requirements |
Stage | Proposed |
Comment Period | Ended on 7/19/2002 |
3 comments
I would like to state for the record my belief that the proposed regulations for grandfathering of LSATPs are overly burdensome and restrictive.
Requiring certified (CSAC) individuals with 10 years of full-time experience (approximately 20,000 hours of practice!) to also have 30 hours of Master's level training in order to be grandfathered is entirely unnecessary. These individuals have been under the supervision of the Board of Counseling, have practiced safely and competently, have already taken and passed an exam (the CSAC exam), and would also be required to take and pass a Master's level equivalent exam (most likely the nationally-recognized MAC exam). The three reports from licensed mental health professionals that the applicant is competent to practice provide further insurance that only fully qualified individuals would be grandfathered.
It appears that the Board of Counseling has once again not listened to the comments from the field of substance abuse treatment (the public comments during the process were overwhelmingly against this restrictive proposal) and is continuing to be elitist and arbitrary.
Considering that one three-credit graduate course is approximately 40 hours of instruction--compared to the 2000 or so hours in a year of work experience--it is clear that supervised work experience is a viable alternative in obtaining knowledge. It is also clear that the BOC holds a narrow view of how expertise and knowledge are obtained: primarily in the graduate classroom.
I too, believe the proposed regulations for grandfathering of LSATP's are too restrictive, elitist, and drawn up with inadequate practical knowledge of the field of SA treatment in the Commonwealth.
Many, if not most, of the "front line" substance abuse treatment providers, have gained their knowledge and skills through a variety of "hands on", CEU, OJT, personal experience, and a mentored/supervised praticum. This was not always the method of choice rather, the most available method to become Certified to practice in this field. Few educational institutions offered a curricula leading to a degree in SA counseling. Indeed - few institutions offered courses targeting substance abuse counseling, although the uniqueness of this counseling is generally recognized in any academic discussion.
The proposed LSAT "grandfathering" does not adequately take this professional pathway into consideration rather, the proposal seeks to base waivers almost entirely on academic achievement. Again I state, this academic avenue has not been available in the past although the skill was required and the standards - as set down by the Board of Counseling - were met by the thousands of CSAC's who have helped so many of our citizens return to a productive and legal lifestyle.
In order to meet the academic requirements of the proposal within the time frame given, I, and many of my collegues would have to cease our full-time employment to take the time necessary for this purely academic pursuit. I feel this will seriously degrade the amount and quality of the care we now provide andsince many of the SA community will go untreated, very likely be detrimental to public safety.
These and similar comments have been made countless times over the past three years and I am very dissapointed the BOC view appears so narrow and so biased towards the graduate classroom as the only fountain of knowledge and expertise.