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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5/20/20  2:01 pm
Commenter: Shenay Wharton Eastern Shore CSB

grandfathering of LCSWs

I would be reluctant to see this petition move forward unless the clinicians have documented education and training in addictions. Being a licensed provider does not mean that they are also skilled in the treatment of substance use disorders. 

CommentID: 80163

5/21/20  7:55 am
Commenter: Candace Roney

Grandfathering LCSW

Addiction treatment is a specialized area of behavior health that requires academic and practical training.  I do not support grandfathering unless an adequate level of knowledge can be proven in the area. 


CommentID: 80167

5/29/20  6:39 pm
Commenter: Rebecca Hogg

Against waiving exam for LSATP for LCSW

MSW programs do not generally require a substance use course in order to reach graduation and LCSW in VA also does not require this education for initial licensure. Substance use counseling requires specialized training which an LCSW may not have and the SW exam does not cover. The LPC in VA requires a substance use course for licensure. Additionally, the LPC exam in VA is scenario based which is significantly different than the exam for social workers. I am not in favor of waiving the requirement of the MAC exam for LCSW applicants to earn the LSATP.

CommentID: 80173

5/31/20  11:00 pm
Commenter: Sharon Watson, LPC, LMFT, LSATP, NCC, ACS


To put it simply:

SATP Residency (200 hours supervision) + education & experience + exam = LSATP

LPC (200 hours supervision) + CSAC (100 hours supervision) + CSAC exam = LSATP


Does not and should not equate to:

LCSW (100 hours supervision) + NOTHING = LSATP


Becoming a Licensed Substance Abuse Treatment Practitioner requires either: 1. Substance abuse specific education, internship, and experience; 3,400 hours of total work and 2000 hours of face-to-face substance abuse treatment with 200 hours of supervision from a Supervisor with 20 hours of Clinical Supervision Training who also has met specific substance abuse education and experience requirements, and passing the examination; or 2. A license as an LPC plus certification as a CSAC; the LPC education requirement already requires a course in substance abuse, the same number of hours of work and supervision noted above and a CSAC which requires specific education, experience, the CSAC exam, and 100 hours of supervision over the course of 2000 hours of total work; therefore this option requires a total of 300 hours of supervision. 


It’s extremely important to note that in order to become an LCSW there is no requirement for substance abuse education and social work residents are required to only have 100 hours of supervision from a supervisor who is required to only have 14 hours of Clinical Supervision Training over the course of 3000 hours of work and 1,380 hours of face-to-face client contact, not the higher work and client contact hours or the 200 or 300 hours of supervision required for either of the scenarios above.  


This petition doesn’t request a waiver for the examination for an LCSW with any requirements for substance abuse education, experience, internship, or supervision specifically in substance abuse. 


Please do not denigrate licensure as an LSATP by allowing this petition to pass without requiring the same education and experience as those required for LSATP licensure or those required for endorsement that would include a CSAC in addition to licensure as a LCSW.

CommentID: 80175

6/1/20  3:02 pm
Commenter: Linda G. Ritchie, Ph.D; LMFT, LPC


I find it absurd that it is even being considered to allow a LCSW to become a Licensed Substance Abuse Treatment Practitioner without any documentation of education, training or experience in substance abuse treatment. To simply award the title of LSATP to a person because they are a LCSW  is a slap in the face to those clinicians who have invested their time, energy and money in training to gain the knowledge and proficiency required to be competent in the area of substance abuse treatment.  I fail to understand any reasoning that  would make approving this petition reasonable.


CommentID: 80178

6/6/20  5:04 pm
Commenter: Monica Whitlock

Strongly not im favor

I am strongly not in favor of this, they should not be except from all of the hard work that we had to put in to get our license.

CommentID: 80188

6/7/20  4:11 pm
Commenter: LaToya Ray, LPC

Training Requirements for LCSWs and Substance Abuse

I would suggest that LCSW engage in additional educational training and require additional substance abuse credentials as does the Virginia Board of Counseling. 

CommentID: 80189

6/7/20  4:17 pm
Commenter: Marjorie Knight, LPC

Opposed to LCSW approval as LSATP without education and supervision

I am opposed to the approval of LCSWs as LSATPs unless they have met the same stringent educational and supervision requirements met by LPCs.   

CommentID: 80190

6/7/20  4:28 pm
Commenter: Guy Strawder, LMFT, Revelations Counseling & Consulting

Strongly Oppose

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. 

CommentID: 80191

6/7/20  5:25 pm
Commenter: Mary Linda Sara, PhD

opposed to LCSW being grandfathered

I am absolutely opposed to having LCSWs being allowed to practice as substance abuse counselors. It is impossible to know when allowing LCSWs, as a group, who has adequate course work and supervision to practice in this specialty as recognized in Virginia.

I still have my Virginia license.

CommentID: 80192

6/7/20  6:42 pm
Commenter: Salma Abugideiri LPC

Opposed to LCSW’s being endorsed as LSATP

It does not make sense to me for any clinician to have a shortcut on the preparation and training for becoming a licensed or certified substance abuse therapist.

CommentID: 80193

6/7/20  6:55 pm
Commenter: Ed Andrews

Opposed to LCSW’s being endorsed as LSATP

Strongly opposed to allowing LCSW to become LSATP without any training and exam.

CommentID: 80194

6/7/20  6:57 pm
Commenter: Ed Andrews

Opposed to LCSW’s being endorsed as LSATP

Opposed to waiving Exam or grandfathering LCSW to be LSTAP.

CommentID: 80195

6/7/20  8:58 pm
Commenter: Kirsten M. Lundeberg, LPC, LMFT

Opposed to waiving Exam or grandfathering LCSW to be LSTAP.

I am opposed to waiving Exam or grandfathering LCSW to be LSTAP.

CommentID: 80196

6/7/20  9:25 pm

Opposed to LCSW endorsement as LSATP; they must test!

I am amazed at the number of professionals who have desired the LSATP for the  monetary gain, since the ARTS  but were never interested in the credential before. I AM OPPOSED TO LCSW's NOT HAVING TO TEST FOR THE LSATP - for several reasons (1) the LSATP is already given to the LPC's , who have no training in addicitons and only recently have been required to complete one (1) graduate level SUD class, (2) I had to test for the LSATP in 2004 after completion of graduate school and LSATP's are not given the opportunity  to obtain the LPC or any other graduate level credential without testing, (3) I dont think that the Board of Counseling has any respect for or maintains any integrity for addictions professionals because they are ALWAYS giving the LSATP to some other already credentialed professional and does nothing for us - those with only the LSATP.    If this seems hostile , it isa the waythat I  feel because it just seems so disrespectful to be in a profession for over 25 years without any recognition, respect or equitable opportunity for obtaining other graduate level credentials from the Board of Counseling - while my credential, the LSATP,  is just given away like candy to anyone who asks for it.  

CommentID: 80197

6/8/20  6:04 am
Commenter: MIchelle Market, LPC, CEDS

Opposed to waiving Exam or grandfathering LCSW to be LSTAP

I am opposed to waiving Exam or grandfathering LCSW to be LSTAP

CommentID: 80198

6/8/20  7:00 am
Commenter: Durriya Augelli

Opposed to waiving Exam or grandfathering LCSW to be LSTAP.

I am opposed to LCSWs being granted LSTAP licensure without the proper training, and without training that is equivalent to that required of other fields like LPC. I believe it sends the wrong message to the professional community about standards and quality of care.

CommentID: 80199

6/8/20  7:18 am
Commenter: Eric McClerren

Strongly oppose

I'm in favor of giving those with an LCSW a path toward addiction certification. We need more competently trained professionals to treat this population. However, I have to oppose the petition the way it currently stands. As Sharon Watson pointed out in her comment, it is possible for an individual to receive an LCSW credential without one single hour of addiction-specific training. To give someone a certification to treat addiction with no actual training in how to treat addiction would put many lives at risk. I would be in favor of any petition amended to include requirements for training in substance abuse treatment in line with what is required for LPC and LSATP.

CommentID: 80200

6/8/20  9:59 am
Commenter: Michelle M. May, LPC

OPPOSED to waiving the exam

I am opposed to waiving the exam for LCSWs for the LSTAP certification . We need to keep a high standard of training and education in order to most effectively help. 


CommentID: 80201

6/8/20  5:19 pm
Commenter: Colette Brooks


Strongly opposed waiving the exam and education requirments for LCSW to be LSTAP

CommentID: 80207

6/9/20  10:40 pm
Commenter: Nicole Jordan, LCSW


I am fully in favor of LCSWs being afforded a similar opportunity as LPCs, to waive the examination and be endorsed for LSATP. The Board of Counseling already outlines the path to endorsement to include training, education and experience working in substance abuse treatment. Many LCSWs DO work in the substance abuse field and are recognized by many insurance networks without the credential. LCSWs are still guided by ethical code to practice within our scope of expertise which would still require us to be trained and educated prior to providing services to this population. 

CommentID: 80218

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

6/10/20  2:54 pm
Commenter: Candice Arnold, LPC, LSATP

Strongly disagree

Working with clients with substance use disorders is a specialty.  I do not agree with this petition to allow for getting the LSATP licensure without taking the exam and meeting the additional requirements regarding hours, supervision, etc.  I believe it is imperative that therapists who work with clients with substance use disorders have had appropriate education, training and supervision prior to being licensed as an LSATP.  It is important that one has experience to be able to properly assess for substance use disorders, make appropriate recommendations for levels of care needed for treatment, know how to implement therapeutic techniques with clients and their and loved ones.  

CommentID: 80225

6/10/20  2:58 pm
Commenter: Chandell Miller, LPC resident, CSAC, NCAC II, SAP, NDS, ADS

Totally Opposed

I am totally opposed to LSCW's receiving an LSATP license.  Social Work is not counseling nor is it substance abuse.  Please stop forcing the practice of social work into counseling now substance abuse.  There are many individuals with an educational background in substance abuse and counseling that would be more appropriately suited for the LSATP license.  

The substance abuse counseling community suffers enough from jobs in addiction slotted to social workers.  General practitioners (MD) do not perform surgery for a reason, it's not their specialty. 

CommentID: 80226