I strongly oppose the petition for this rule. From a clinical perspective, the hours required for this specialized field of practice are extensive, and they appear to have been scrutinized and established previously by the Board for the purpose of engendering greater competency among licensed professionals in treatment of substance use disorders. If the requirements are watered-down for one credential, then the precedence is set for others--and the result is a lowered level of competency throughout the Commonwealth to meet an essential need. If the purpose of waiving the exam and education to increase the number of licensed practitioners with this specialized training in the Commonwealth to meet the need, I would request the Board would take a more thoughtful approach on the training and number of direct client hours under supervised residency in substance abuse treatment that would be amenable to all licensed practitioners in the state. 

I am not currently an LSATP, but I know the the commitment in training, education, residency and examination are quite extensive. I find it very discouraging for our profession that we are picking winners and losers among different credentials that can circumvent these requirements for what appear to be arbitrary factors.