Substance abuse treatment and prevention professionals we take a misstep in transition to new standards, are a varied group. It is no secret that for years, the literally millions of people will lose access to care substance abuse counseling field has struggled for because of depletion in an already depleted workforce. recognition as legitimate health professionals. This has already happened in Oklahoma, where Recognition and approval has been sought from legislation will require substance abuse counselors to policymakers, third-party insurers, clinical supervisors, hold a master’s degree (by 2013.) The new law in and other health professionals. Yet the field has had Oklahoma has the noblest of intentions, but is flawed. much trouble uniting under one banner, due in large While its intent was to benefit the consumer, by holding part to the fact that different standards of practice in different states abound. Here in Washington, the substance abuse workforce has many policy concerns. We still struggle to be included in legislation, regulations, and policy reports. We are a workforce that treats a disease with such a social stigma that criminal justice is as important a policy priority as public health. Those who work on other health issues do not need to divide their attentions or their resources as we do.
Just as any other health care profession, substance abuse counselors are regulated by their respective states. There are no federal guidelines as to who can practice substance abuse treatment, just as there are none for medicine, nursing, psychology, or social work. The Affordable Care Act did not change this. Nothing in the act mandates what level of education, or what level of certification, a substance abuse counselor must have in order to provide clinical services. The states remain the sole adjudicator when it comes to determining who may practice substance abuse treatment, and who may be reimbursed by Medicaid for it. Some states require licensure, some require a master’s degree, and, much to the dismay of some in the profession, some states have little or no standards. As the essential benefits to be provided by the ACA continue to be formulated, it remains to be seen what standards will be required of the profession by the newly formed insurance exchanges.
All of the aforementioned points force us to ask ourselves some interesting questions when it comes to formulating policy strategies and priorities. If we are to have unified standards, what should they be? A specific credential? A designated level of education? These are tough questions to answer. Tougher still would be figuring out how to transition to these standards, while still providing care to a desperate population. Our workforce is stretched thin, and is aging. There is a severe shortage, especially in rural and tribal areas.
So therein lays the paradox. Some believe we need to move forward as a field, with high standards of education and credentialing, if we want to be recognized on the same plane as other health professionals. Others point out that he need for services is so great, that if counselors to what it believes is a higher standard, there is the realistic possibility that the law will do more harm than good. There is already a workforce shortage in the state (and the rest of the nation) and those who already have trouble finding professional treatment will now face even more of an uphill climb.
Compounding the problem is misinformation: A March 11 article in The Oklahoman newspaper said that the rule changes were required by new federal Medicaid standards. But that was inaccurate. No such federal standard exists. Steven Buck, ODMHSAS Deputy Commissioner for Communications and Prevention, told ADAW that there are no new federal standards that require a master’s degree (see ADAW, March 21). “I’m not aware of any federal standards.” According to the Centers for Medicare and Medicaid Services (CMS), there are no such standards. “There is an Affordable Care Act modification to Public Health Services rules requiring Master’s degrees, but no revision to Title 19 of the Social Security Act, which is Medicaid,” said Mary Kahn, senior public affairs specialist for CMS. “States are allowed to determine who they want to be providers,” she told ADAW.
Of course, third-party payers can make their own rules, and set their own standards for who is reimbursed. Also, Federally Qualified Health Centers may establish their own regulations, as they answer to the Health Resources and Services Administration. Yet we see the damage that has been done as a result of misinformation: an entire state has made a regulatory change based on what some believed to be a federal regulation, which in reality never existed. Why the Oklahoma regulators and legislators thought there was a new federal policy is a question yet to be answered.
So the field is caught between the largest of rocks and the most immovable of hard places: do we advocate for higher standards, which may in the long run benefit the field and the consumer, or do we address the immediate need, which is a nation of consumers that urgently needs treatment? As Hamlet would say, “Ay, there’s the rub.” Ideally, the answer is both. This will take a tremendous amount of strategy, brainstorming, advocacy, and communication. We must deliver information to the field, and to policy makers, which is accurate and timely. National, state, and local organizations that represent the substance abuse counselor workforce can
lead the way, but are well aware of the challenges they face.
Andrew Kessler is the Principal at Slingshot Solutions LLC, a consulting firm specializing in behavioral health advocacy. He represents several associations involved in substance abuse workforce issues, including IC&RC and CAADAC.
