Virginia Regulatory Town Hall
Department of Health Professions
Board of Counseling
Regulations Governing the Practice of Licensed Substance Abuse Treatment Practitioners [18 VAC 115 ‑ 60]
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6/10/20  1:58 pm
Commenter: John-Mike Nelson, PhD, LPC, LASTP, MAC, SAP


I am writing to you to state that I strongly oppose the petition that asking for LCSWs to be endorsed into licensure as a LSATP without taking the examination and without having education and experience in substance abuse treatment.  As a substance abuse specialist for the past 15 years, I understand the need for more professionals working with this population.  At the same time, substance abuse is a vast and complicated area needing many MANY hours of education and training to adequately provide help for those suffering from substance use disorders.  I have worked with many consumers that have actually been damaged by working with ill-equipped mental health professionals that have a "basic" understanding (or none at all) of the complications of substance use.  They have walked away from those sessions with unprepared clinicians with reinforced guilt, shame, embarrassment, and trauma.  I believe this is solely due to lack of training, education, and experience provided by helping professionals.

By waiving the requirements for LCSWs without the same rigorous requirements as any other individual that attempts to acquire the LSATP credential, you will be putting the substance using population in jeopardy.  This is exactly what we all attempt to prevent for our consumers.  If an LCSW is able to use those credentials, it will falsely be presenting to consumers that they are highly trained substance abuse specialists who have undergone rigorous training and education.  This gives a false sense of security giving this vulnerable population!  The damage that may be done in those sessions, if the LCSW is unequipped to work with this population, will hinder any success consumers may have a chance of!  

Please do not waive the requirements for LCSWs to be endorsed for LSATP credentials without the same training/examination/supervision requirements as all others who hold this credential.  It is up to the board of counseling to protect the populations we attempt to help and I strongly believe that by allowing this petition to go through, the Board will be extremely jeopardizing the well-being of substance using populations.

CommentID: 80224