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.