As noted in the OPB review of this proposal "Formal education opportunities in the emerging substance abuse treatment profession have been scarce. Many of the most highly skilled counselors have gained their knowledge from a combination of courses, workshops, seminars, and independent study." The obtainment of knowledge and skill is evidenced by both examination and performance in the work setting. The experiential requirement and letters attesting to ability to practice independently for this waiver ensure the skills of an applicant. An examination is the best tool to measure specific knowledge. It is therefore unneccesary, overly restrictive, and makes the waiver too academically based to require *specific graduate level* coursework. First and foremost, specific knowledge requirements are best ensured by the exam, not by a course taken any number of years ago. Secondly, requiring this coursework to be at the graduate level ignores the accepted fact that "Formal education opportunities in the emerging substance abuse treatment profession have been scarce" stated by OPB above and in public comment repeatedly during the debate on this waiver. A more appropriate requirement would be graduate or undergraduate courses, or CEU's through seminars or independent study in these areas. Finally, while the areas of counseling, group, appraisal and diagnostic procedures, and research are indeed critical, demonstration of knowledge and skill is already being tested and ensured by years of experience, letters of attestment, and by the examination. Therefore, the proposed requirements for 30 graduate hours in specific areas are overly restrictive and make the waiver too academically based.