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.