certified or licensed as addiction/mental health
professionals.^183
CASA Columbia’s survey of directors* of
addiction treatment programs in New York State
found that 67.5 percent had a graduate degree,
16.9 percent had a bachelor’s degree, 14.5
percent had some college or an associate’s
degree and 1.2 percent had only a high school or
GED degree.^184
Although state licensing laws sometimes dictate
that clinical supervisors, such as program or
medical directors, have special training
(including certification) or experience in
addiction treatment,^185 they generally allow
facilities more flexibility to determine the
necessary qualifications, including level of
experience, education or training, as well as the
composition of other clinical staff.^186
Federal Staffing Requirements. In states that
provide addiction treatment using Medicaid
funding, hospital and clinic services must be
provided under the direction of a physician,^187
but if states choose to provide services under the
optional benefits category of rehabilitative care,
they are exempt from this requirement.^188 If
services are required to be provided under the
direction of a physician, the facility physician is
not required to be on staff full time, but must be
present for sufficient time to provide medical
direction, care and consultation in accordance
with accepted principles of medical practice.
The facility and the staff providing care also are
required to hold appropriate state licenses,
certifications or registrations.^189
The federal regulations for opioid maintenance
therapy programs specify that each program
must employ a medical director and that all
providers, including addiction counselors,
comply with the credentialing requirements of
their respective profession.^190
- Some of the program directors also may have
served as clinical supervisors, but the survey did not
distinguish between the two roles.
Accreditation Requirements Regarding
Staffing.† CARF standards require that
programs that offer detoxification, inpatient
care, partial hospitalization, residential treatment
serving “persons with medical needs” or opioid
maintenance therapy have a medical director
who is a physician. Organizations that seek
elective accreditation for assertive community
treatment (ACT)‡ services must have a physician
on staff. Other services do not require physician
supervision.^191While CARF requires staff to be licensed or
certified by a credentialing body that uses a
competency-based process,§ it leaves the
determination of which practitioners are
qualified to provide addiction treatment to state
laws and professional associations, thus
allowing for great variation in education and
training requirements.^192The Joint Commission allows programs to
define the qualifications required for staff to
perform their job and requires staff who provide
care to be licensed, certified or registered “in
accordance with the law.” Only opioid
maintenance therapy programs must have a
physician on staff; this person must have
experience in addiction medicine, including
medication-assisted treatment.^193Treatment Service Requirements ...............................................................................
Licensed health care facilities must deliver care
that meets standards of medical practice; state
regulations tend to defer to health care
providers--for whom there are well-delineated
standards of education and training in health
care practice--to determine appropriate medical
practice (e.g., which services to provide and how
to provide them).^194 In contrast, those who
provide addiction treatment often have minimal
† CASA Columbia reviewed the standards of the two
largest accreditors of addiction treatment programs--
CARF and the Joint Commission.
‡ As described in Chapter VI, ACT is a treatment
approach for patients with co-occurring addiction and
mental health conditions.
§ Focused on the ability to demonstrate adequate
skills, knowledge and capacity to perform a specific
set of job functions.