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NASADAD Letter to Congress regarding Faith-based Addiction Programs

NASADAD sent a letter to Congress asking them to not support language in a Community Renewal Bill that allows the Secretary of DHHS to exempt any faith-based treatment counselor from state licensing requirements.

July 13, 2000

Dear Senator or Representative:

On behalf of the National Association of State Alcohol and Drug Abuse Directors (NASADAD), I am writing to oppose sections of Title IV of S. 2779, the American Community Renewal and New Markets Act or the House companion bill. Language in this section related to the licensure of substance abuse professionals would amend authorities of the Substance Abuse and Mental Health Services Administration (SAMHSA) under Title V of the Public Health Service Act and override the authority of States to govern basic health care standards for substance abuse treatment professionals within their jurisdiction. NASADAD represents the concerns of State Alcohol and Drug Abuse Directors who administer the $4 billion public alcohol and drug prevention and treatment system.

The Title IV (Faith Based Substance Abuse Treatment) finds that "establishing formal educational qualifications for counselors and other personnel in drug treatment programs may undermine the effectiveness of such programs" and that " formal educational requirements may hinder or prevent the provision of needed drug treatment services." Of great concern is a provision that allows the Secretary of Health and Human Services to require a State to waive their educational qualifications for substance abuse professionals if the "State has failed to demonstrate empirically that the educational qualifications in question are necessary to the operation of a successful program."

Faith Based Providers Are Welcome and Utilized

States welcome and currently use a wide range of faith-based providers and counselors to provide substance abuse prevention and treatment services. Faith based providers have been and will continue to be a key component of the health network utilized by States that provides services to prevent and treat alcohol and drug addiction. NASADAD worked closely with Chairman Frist, Member of the Senate Labor and Human Resources Committee, and the Administration to assure the inclusion of Charitable Choice language in S. 976, the bill to reauthorize the Substance Abuse and Mental Health Services Administration.

Research and Practice

However, changes proposed in Title IV of S. 2779 are in conflict with the research findings of the National Institute on Drug Abuse (NIDA) which classifies drug abuse as a brain disease and recognizes that effective drug and alcohol abuse treatment must have both medical and behavioral therapy components, in addition to a broad array of social support services. Both NIDA and the National Drug Control Strategy, formulated by the Office of National Drug Control Policy, call for science-based principles and program accountability for substance abuse treatment services. Limited governmental resources are best provided to providers and individuals who have the training and education to conduct programs that are consistent with established knowledge, based on scientific principles, and capable of demonstrating outcomes through rigorous evaluation. All providers and programs seeking Federal or State dollars should be expected to embrace these recognized principles and standards.

State Approval Of Practitioners Is Essential

Responsibility for certification of facilities and individuals providing substance abuse services has traditionally and appropriately resided with the States. Every State certifies or licenses substance abuse facilities and counselors in a manner similar to the process used for other health facilities or professionals.

Just as faith-based hospitals and physicians must meet accepted standards so should faith-based substance abuse treatment facilities and professionals. The State licensure/certification system helps to protect consumers from individuals who provide inappropriate or sub-standard care as well as assures effective treatment.

Core Competencies

There is a strong national consensus around core competencies that a substance abuse practitioner must demonstrate in order for them to be effective. These competencies can only be achieved through education, training, and supervised experience. As is the case for other health care professionals, States have evolved a process to ensure that those standards of competency are met. In no other health care profession has Federal legislation been proposed that would force States to abandon established qualifications for practitioners.

The specific individual skill sets and areas of knowledge required to effectively treat alcoholism and drug addiction are broadly accepted and applicable to all treatment settings and philosophies. This includes treatment provided in facilities affiliated with religious organizations. Demonstrated competency in those skill sets and subject areas form the basis for alcohol and other drug counselor certification within specific States and for the reciprocity of professional certification between States. The recognized core competencies are:
bulletPatient Screening 
bulletPatient Assessment
bulletTreatment Planning
bulletContinuing Assessment
bulletIndividual Counseling
bulletGroup Counseling
bulletCounseling Families, Couples, and Significant Others
bulletClient, Family and Community Education
bulletProfessional and Ethical Responsibilities

The core competencies are built upon the acquisition of specific information and supervised experience. The proposed requirement to give equal weight to educational achievements in other subject areas presents very real difficulties.

Multiple Health Needs

The presence of trained competent staff is particularly important today when many clients needing treatment have a variety of complicating conditions including both alcohol and drug addiction, HIV/AIDS, tuberculosis, mental health and other serious health concerns. By preempting State certification and licensing, S. 2779 would allow individuals who do not have the necessary training or skills to provide health services.

Action Needed

We strongly urge you to oppose this and other provisions that would seek to undermine the quality of substance abuse treatment and other health services.


John S. Gustafson

Executive Director


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