A wide range of “qualified providers”* (e.g.,
addiction counselors, social workers, nurses)
who may offer and/or supervise treatment†--
most of whom are not qualified to provide
medical care or are not trained in addiction;
The total proportion of patient care that must
be provided by “qualified providers”; and
The ratio of staff to patients.^180
Although state licensing requirements allow an
array of practitioners to provide addiction
treatment, the licensing requirements for
addiction treatment facilities and programs
typically state that “medical services” must be
provided or supervised by a physician; however,
medical services are defined as detoxification,
opioid replacement therapy or the assessment,
diagnosis and treatment of co-occurring medical
or mental health conditions, not as addiction
treatment itself.^181
According to CASA Columbia’s review, 43
states require non-hospital-based‡ outpatient and
residential addiction treatment programs to
employ (at least part time) a physician to serve
either as medical director or on staff; however,
this requirement applies primarily to programs
that provide opioid maintenance therapy which,
by federal regulation, must be supervised by a
physician.^182 Few states require non-hospital-
based programs that do not provide opioid
maintenance therapy to have a physician serving
as medical director or on staff; 10 states require
residential treatment programs to have a
physician either as a medical director or on staff
and eight states require the same of outpatient
treatment programs. Without a physician as
medical director or on staff, addiction treatment
programs cannot provide a full range of
evidence-based treatment services including
- Qualified providers are those who, under state law,
may provide addiction treatment.
† See section on Licensing and Credentialing
Requirements for Individuals who Provide Addiction
Treatment, above.
‡ Hospital licensing requirements require physician
supervision of patient care; however, the majority of
addiction services offered are not hospital based.
pharmaceutical therapy and treatment of co-
occurring health conditions.Consistent with these requirements, addiction
treatment services typically are not required to
be supervised by a physician, other than for the
provision of narrowly-defined “medical
services.” While states may require that
addiction services be overseen by a clinical or
program director, that position is not required to
be filled by a physician.Approximately two-thirds of states in CASA
Columbia’s review specify that residential
treatment programs (31 states) and outpatient
treatment programs (29 states) must have a
program or clinical director. Among the 21
states that specify the minimum educational/
training requirements for this position, few have
particularly high standards: Eight states require a minimum of a master’s
degree; Six states require the director to be a
licensed or certified addiction counselor; Four states require a minimum number of
years of experience;§ One state requires a bachelor’s degree; One state requires an associate’s degree; and One state simply requires the person to
demonstrate competence to perform certain
services.A national survey of treatment professionals
conducted in 1998 found that 60.6 percent of
individuals who were responsible for
supervising clinical services in addiction
treatment facilities had graduate degrees and
77.5 percent of these supervisors were certified
or licensed as addiction/mental health
professionals. Among facility directors, 64.0
had a graduate degree and 68.9 percent were§ AZ additionally specifies that the individual must
have a high school diploma or GED.