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.

 

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.

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.