Opinion: Allow CADC Interns to Provide Telehealth Services to SUD Patients
Opinion Editorial by Christine Carey, Program Director of a New Jersey Local Substance Use Disorder Program.
There is a need to allow supervised CADC Interns to provide Telehealth services to SUD patients
COVID-19 presents serious complications for those seeking SUD treatment and those in recovery.
Independent clinics are currently struggling to provide critical services to the SUD population in New Jersey. It is well known that there has been a shortage of licensed counselors for SUD in New Jersey even prior to the Covid-19 pandemic. The current situation has now exacerbated the problem with licensed counselors either sick with the Covid-19 virus, acting as a caregiver to someone who has the virus, home schooling children or simply opting to remain on unemployment and not work until the crisis passes. The need for a waiver to allow supervised, CADC interns to provide Telehealth services to SUD patients is critical for the continuity of services to the SUD population to help prevent deaths via overdoses, hospitalizations and relapses.
Independent SUD clinics have always been allowed by regulation to have 50% of its counseling staff be CADC interns working toward their license (N.J.A.C. 10:161B-1.9). Since Telehealth is being restricted to licensed counselors only, this now means that most Independent clinics will have 50% of their SUD counseling staff that have become instantly ineligible to continue servicing their clients! Who is going to now service the 50% of the SUD population that is now being left behind? Furthermore, there are numerous CADC interns across the state who have developed a professional connection to the clients who have been on their caseloads for many months and who are very familiar with their clients and are appreciated by them as the person they trust and confide in. The counseling relationship is a very personal, therapeutic alliance that can take months to build.
During this very uncertain time, the structure and comfort of speaking with a counselor they know and trust is critical. Counselors are literally a life line to clients in early recovery. Even if there were enough licensed people who could be found to carry the other 50% (and there are not) many clients would be reluctant or even refuse outright to start "from scratch" working and confiding in a new counselor.
Some have made the point that there is nothing that can be done to allow the CADC interns to perform Telehealth services as this would violate the law. However as stated in the March 21, 2020 newsletter:
The legislation (signed by Governor Murphy) authorizes certain State agencies to waive requirements in State law or regulation to facilitate the use of Telehealth during the Covid-19 emergency. The Department of Human Services, Division of Medical Assistance and Health Services is directing the Medicaid Managed Care Organizations and for the Medicaid Fee for Service Program that MCOs and Medicaid/NJ Family Care will provide reimbursement to providers for telehealth, including tele-mental health services, in the same manner as for face-to-face services as long as the services are performed to the same standard of care as if the services were rendered in-person.
This would imply that if CADC interns are allowed to provide face-to-face services under normal circumstances (13:34C-6.2), the same should apply to telehealth. There would be no difference in services and no less standard of care. Providers are encouraged to deliver these critical services within their scope of practice. CADC interns are supervised closely by licensed professionals and are operating within regulatory and licensing guidelines.
As per the April 3, 2020 announcement from the Division of Consumer Affairs regarding the Telehealth Services during the COVID-19 Pandemic:
“The availability of telehealth services is critical to allowing as many New Jerseyans as possible to get the medical services they need during the COVID-19 pandemic. The use of telehealth during the pandemic will maintain and increase access to health care services and reduce unnecessary in-person encounters that may spread COVID-19. For these reasons, the New Jersey Division of Consumer Affairs (DCA)—which oversees 51 professional and licensing boards, including the Boards of Medical Examiners, Nursing, and Respiratory Care Therapists, and the boards that license mental health professionals—strongly encourages providers to use telehealth to the greatest extent possible for the duration of the current state of emergency and public health emergency declared by Governor Murphy in response to the COVID-19 pandemic. As part of their response to the pandemic, the New Jersey Legislature and the Murphy Administration have taken steps to ensure New Jerseyans have access to telehealth, including tele-mental health services, to the greatest extent possible. These steps include temporarily relaxing requirements regarding which technologies may be used to provide telehealth services; who may provide telehealth services; how telehealth services are paid for; and where providers and patients/clients may be located when telehealth services are provided.”
We are all aware that these are very trying times. By not allowing CADC interns to provide services that they have already been providing, there could potentially be hundreds or thousands of clients that may not receive crucial care.
A waiver should allow providers to continue to provide quality care to the SUD population which we know were already at high risk with our existing opioid crisis. Limiting providers to not include the waiver with inclusion of CADC Interns, would only leave our clients without necessary critical supports to help manage their needs through this ever so challenging climate. So yes, there are many important laws that have been in place that regulate how services are provided but those laws are being waived so that the needs of vulnerable populations may continue to be served during this crisis. It seems reasonable that the same logic should be applied to this necessary waiver as well, without which, many clients in the SUD population will face horrific, dangerous and potentially life-threatening setbacks.
Cristine M. Carey, MA, LCADC, CCS, ACS is the Program Director of a New Jersey Local Substance Use Disorder Program. Christine is currently a Licensed Clinical Alcohol and Drug Counselor (LCADC) who is also a Certified Clinical Supervisor (CCS), as well as an Approved Clinical Supervisor (ACS). Christine has over 15 years’ experience in the co-occurring field.