BILL ANALYSIS SENATE HEALTH COMMITTEE ANALYSIS Senator Elaine K. Alquist, Chair BILL NO: SB 707 S AUTHOR: DeSaulnier B AMENDED: April 22, 2009 HEARING DATE: April 29, 2009 7 CONSULTANT: 0 Dunstan/ 7 SUBJECT Alcohol and other drug counselor licensing and certification SUMMARY Institutes a system of certification and licensing for alcohol and other drug counselors by the Department of Drug and Alcohol Programs (DADP). CHANGES TO EXISTING LAW Existing law: Requires all adult alcoholism or drug abuse recovery or treatment facilities to be licensed by the Department of Drug and Alcohol Programs (DADP). Also requires driving-under-the-influence programs and narcotic replacement therapy programs to be licensed by DADP. Grants DADP the sole authority in state government to establish appropriate minimum qualifications, including education, skills, life experience and training for licensees, designated administrators and staff. Requires DADP to operate a certification program for treatment services, such as outpatient treatment services, which are not subject to licensing. Such certification is voluntary on the part of the facility, shall not convey any approval or disapproval by the department, and shall be for Continued--- STAFF ANALYSIS OF SENATE BILL SB 707 (DeSaulnier) Page 2 informational purposes only. DADP is also required to develop standards for assuring minimum levels of quality provided by alcohol and drug programs. Requires all alcohol and drug abuse programs to register with the county drug and alcohol program administrator in order to coordinate efforts in the county. Provides that registration does not constitute approval or endorsement by the county or by DADP. Establishes DADP as the lead state agency for alcohol and drug programs and requires DADP to prepare a master plan to eliminate drug and alcohol abuse in California. Requires DADP to cooperate closely with individuals and organizations concerned with alleviating problems related to inappropriate alcohol and drug use. Requires DADP to develop and maintain a data system that shall gather and obtain information on the status of alcohol and other drug abuse problems in the State of California. Existing state regulations Establish nine counselor organizations that are allowed to certify alcohol and drug counselors who provide counseling services in an alcohol or drug program, which is defined as a program that is subject to state licensing, receives state funding, or is granted voluntary certification. Allow currently employed counselors five years, dating from 2005, to become certified. Require that certification be based on specific addiction counseling competencies, including understanding addiction, knowledge of treatment methods, and professional readiness. Existing state regulations require that, by 2010, at least 30 percent of counselors in licensed facilities shall be in compliance with certification requirements, and all other noncertified counseling staff must be registered with a certifying organization. This bill: General provisions Establishes the Alcohol and Other Drug Counselor Licensing and Certification Act. Creates a three categories of certified counselors beginning with a Certified Alcohol and Other Drug Counselor, and including an advanced and clinical STAFF ANALYSIS OF SENATE BILL SB 707 (DeSaulnier) Page 3 supervisor certification, who would all be certified by DADP to practice alcohol and drug counseling in a program licensed or certified by DADP. Establishes a Licensed Alcohol and Other Drug Counselor (LAODC) who may maintain an independent practice and can also provide clinical supervision and. Defines a registrant as a person registered with DADP and is working towards certification or licensure as a Certified Alcohol and Other Drug Counselor. Certification and licensing Requires DADP to develop standards for certification and licensure of alcohol and other drug counselors, including persons presently certified by DADP and to begin issuing licenses, certificates and registrations beginning January 1, 2011. . Requires DADP, beginning January 1, 2011, to issue Certified Alcohol and Other Drug Counselor certificates to a person who either: 1) completes 350 hours of education and possesses a high school diploma or GED, or 2) possessed an associates or equivalent degree. Provides that the applicant is also required to pass a required test, complete 250 hours of supervised experience, complete 2000 hours of work experience, submit and pass a required criminal offender record information search and pay a fee set by DADP. Requires DADP to issue counseling certificates at an advanced level and a clinical supervisor level to persons who submit and pass a required criminal offender record information search and pays the fee set by DADP, and meets the requirements for of education, supervised experience and work experience, as specified. Directs DADP to issue a license to a person who meets specified requirements and possess a graduate degree in a related field. Requires that education required for the advanced STAFF ANALYSIS OF SENATE BILL SB 707 (DeSaulnier) Page 4 counseling certificate and the licensed counselor meet the requirements of specified publications of the United States Department of Health and Human Services, Substance Abuse and Mental Health Services Administration, Center for Substance Abuse Treatment and any other material specified by DADP. Establishes specified requirements for exams required for certification or licensure by DADP. Specifies the requirements for experience used to meet the supervised experience criteria for certification. Requires supervisors to comply with all requirements for supervision as established by DADP by regulation. Establishes standards for supervised experience as a requirement for certification and licensing. Establishes that nothing in this bill shall be construed to constrict, limit or withdraw the Medical Practice Act, Nursing Practice Act, Psychology Licensing Act, Marriage and Family Therapist Act or Clinical Social Work Practice Act. Provides specific exemptions from the bill's requirements for the California Department of Corrections and Rehabilitation, employees or volunteers of the State of California, employees or volunteers for an agency of the U.S. government and volunteers of peer or self help groups, clerics and live-in alternatives to incarceration. Existing practitioners Requires DADP to certify or license each person who is certified by the department as a counselor on December 31, 2010, and requires this certification or licensing to be in effect for a period of two to four years and shall be renewable. Allows DADP to withdraw or condition a certification or licensure for the same reasons that it could take discipline against new registrations, certificate or licenses. STAFF ANALYSIS OF SENATE BILL SB 707 (DeSaulnier) Page 5 Grants DADP the authority to issue regulations to specify which persons may be eligible to be registered or certified and receive appropriate credit for education supervised experience and work experience. Provides for a person to qualify as an existing practitioner, DADP must receive an application by December 31, 2013. Requires the applicant to have the appropriate advance certification as recognized by DADP before December 31, 2010 or meet the requirements for new applicants, submit and pass a criminal background check, pay the applicable fee set by DADP and complete the certificate application. Establishes that the clinical supervisor level must meet additional work experience and continuing education. Requires that the licensed counselor must meet the requirements for a certificate and must have the appropriate advance certification as recognized by DADP before December 31, 2010. Scope of practice. Establishes and defines the practice of alcohol and drug counseling and makes it unlawful to engage in the practice of alcohol and drug counseling without holding a valid certificate or license. Administration Grants DADP authority to adopt rules and regulations as necessary to administer the licensing act. Provides that licenses or certification shall expire within two year after the issue date and specifies renewal procedures. Requires that a counselor display his or her license or certification in a prominent place. Allows a license to be placed on an inactive status. STAFF ANALYSIS OF SENATE BILL SB 707 (DeSaulnier) Page 6 Requires a person who is licensed, certified or registered to provide written notice to DADP within 30 days of a name change or a change of address. Requires DADP to establish continuing education requirements, procedures for the filing and investigation of complaints, criteria to determine if curriculum meets the licensing act's requirements, parameters of unprofessional conduct, develop examinations, registration and supervision requirements for registrants and a database of certified and licensed counselors and registrants. Requires DADP to establish registration and supervision requirements for registrants, including those persons presently registered. Requires DADP to develop or adopt examination for administering to prospective licensees. Funding Establishes the Alcohol and Other Drug Counselor License Fund in the State Treasury. Requires that all fees collected under this act shall be deposited in the fund and are available for appropriation by the Legislature. Provides the fee for issuing a license or certification shall be $155 for both a new license and renewal. Specifies fees for application, renewals, written and oral examinations, license issuance, rescoring an examination, delinquency for renewal, replacement licenses and others. Enforcement Authorizes DADP to take disciplinary actions, including reprimands or probation or suspending or revoking the license or certification. Allows DADP to issue administrative citations or impose administrative fines not to exceed $5,000. STAFF ANALYSIS OF SENATE BILL SB 707 (DeSaulnier) Page 7 Makes it a misdemeanor to falsely represent that the person has a certification or license from DADP. Authorizes DADP to deny, revoke, suspend or impose conditions upon a license, certification or registration for unprofessional conduct. Establishes that activities that constitutes unprofessional conduct, among them securing a license or certificate by fraud or deceit, administering controlled substances, and gross negligence or incompetence in practicing alcohol or drug counseling. Requires DADP to revoke any license, certification or registration upon a finding of fact that the counselor or registrant engaged in any act of sexual contact with a client or former client, as specified. Authorizes DADP to deny, revoke or suspend a license, certification or registration, because of a disciplinary action by another state or territory on a license or certificate for alcohol and other drug counseling. Allows DADP to temporarily suspend a license, certification or registration when the action is necessary to protect a client from physical or mental abuse, abandonment or other substantial threat to health and safety. Establishes procedures for applicants use to appeal decisions made by DADP. Requires that accusations against people who are licensed, certified or registered shall be filed within three years from the date DADP discover the alleged act or omission that is the basis for disciplinary action, with longer periods for fraud or misrepresentation, sexual misconduct or if a minor is involved. Requires that an applicant for a license, certification or registration consent to a criminal background check and establishes related procedures as specified. STAFF ANALYSIS OF SENATE BILL SB 707 (DeSaulnier) Page 8 Requires DADP to revoke or deny a license, certification or registration if an applicant: a. Has been convicted of five or more criminal offense within a thirty-month period ending two years or less prior to the date of DADP's determination b. Is required to register as a sex offender c. Has been convicted of a violent felony within three years prior to the date of the department's determination. Adds certified and licensed alcohol and drug counselors to the list of mandated reporters for child and elder abuse and neglect. FISCAL IMPACT Unknown. BACKGROUND AND DISCUSSION According to the author, there is no single standard for the educational curriculum, testing, certification or code of conduct for alcohol and other drug counselors providing direct treatment services to clients in state licensed and certified treatment programs. Currently DADP authorizes nine different certifying organizations to certify counselors. Each program develops its own classroom curriculum, training, supervisor and work experience requirements. Background checks are not performed and there is no central repository of counselor information, including disciplinary action taken to suspend or revoke certification for misconduct. DADP can direct a certifying organization to take action against a counselor for misconduct, but there is nothing to prevent a counselor who has had certification suspended or revoked from obtaining certification from another organization. SB 707 authorizes DADP to register, certify and license alcoholism and other drug counselors in California and to charge fees to activities associated with counselor registration, certification and licensure. The bill creates a tiered system for counselor certification and licensure with specific education, supervision, training and experience criteria for each tier. The bill also requires DADP to impose sanctions for counselor misconduct. STAFF ANALYSIS OF SENATE BILL SB 707 (DeSaulnier) Page 9 Background Alcohol and other drug dependency is a treatable condition, but no one treatment modality is successful with all persons who exhibit chemical dependency problems. Due to the fact that individual problems, needs and resources vary greatly, a variety of treatment strategies must be available. Treatments for chemical dependency vary because there are multiple perspectives about the condition, itself. Most treatments focus on helping people discontinue their alcohol or other drug intake, followed by life training and/or social support in order to help them resist a return to substance use. Since chemical dependency involves multiple factors which encourage a person to continue using, they must all be addressed in order to successfully prevent a relapse. An example of this kind of treatment is detoxification, followed by a combination of supportive therapy, attendance at self-help groups, and ongoing development of coping mechanisms. Besides being effective, treatment is widely considered to save money by combating the problems associated with substance abuse. A benefit cost analysis done in conjunction with the evaluation of the Substance Abuse and Crime Prevention Act of 2000, which was Proposition 36 on the ballot, found that, for every $1 invested in substance abuse treatment, state and local governments have saved $2.50 from reduced health care costs and crime. Other studies have found that the per capita cost of treatment is significantly less than the cost of incarceration. According to the Institute of Medicine, the cost of incarceration is about $40,000 per year compared to $12,500 and $3,100 for residential and outpatient treatments, respectively. Despite the cost effectiveness of substance abuse treatment programs, a substantial gap exists between the number of people who need treatment and the number who receive treatment. The number of people seeking treatment who have co-occurring mental health disorders has steadily increased in recent years, although it is not clear if the reason is improved diagnosis of mental disorders or a change in the population. It is estimated that individuals with co-occurring disorders now comprise 20 to 50 percent of STAFF ANALYSIS OF SENATE BILL SB 707 (DeSaulnier) Page 10 those with addiction problems. DADP has noted that, if counselors were better qualified, they would be better prepared to accurately identify these co-occurring disorders earlier, treat the addiction and make appropriate referrals to treat the co-occurring mental health disorder. Alcohol and drug counseling Alcohol and other drug counselors work very closely with program participants, patients and residents, and provide critical services including assessments, counseling, treatment planning and case management. Counselors are not currently required to be certified or to have a minimum amount of education or experience. Most treatment programs use or employ a mixture of counselors, who have some formal education or personal experience with alcoholism, drug addiction, and recovery. DADP adopted counselor certification regulations in April 2005, but they apply only to individuals providing counseling services in an alcohol and other drug program licensed or certified by DADP. To be certified by DADP, individuals must be certified by one of the organizations identified in the DADP regulations. In order for a certifying organization to issue alcohol or other drug program counselor certification, the organization's certification requirements must meet DADP's minimum standards. These standards include completing at least 155 hours of formal classroom education, as defined, at least 160 documented hours of supervised alcohol or other drug program counseling, 2,080 or more documented hours of work experience, and obtaining a score of at least 70 percent on an exam approved by the certifying organization. Many other licensed professionals provide alcoholism and drug abuse counseling either in a medical setting or in private practice. These include MFTs and LCSWs, who are licensed by the Board of Behavior Sciences; psychologists, who are licensed by the Board of Psychology; and, physicians and surgeons, including psychiatrists, who are licensed and regulated by the Medical Board of California. Informational hearing The Assembly Business and Professions Committee reviewed the issue of licensure of alcoholism and drug abuse counselors at an informational hearing held on October 30, 2007. Testimony was provided by stakeholders, including STAFF ANALYSIS OF SENATE BILL SB 707 (DeSaulnier) Page 11 the California Association of Alcoholism & Drug Abuse Counselors, DADP, the Board of Behavioral Sciences, the Justin Foundation, the American Psychological Association, the California Association of Marriage and Family Therapists, and the California Association for Alcohol/Drug Educators. In addition to industry stakeholders and regulatory agencies, a number of community members testified before the committee. Little Hoover Commission Report A March 2008 report by the Little Hoover Commission titled, Addressing Addiction: Improving & Integrating California's Substance Abuse Treatment System, describes the effects of substance abuse on families, neighborhoods and government coffers and recommends ways to reduce the misery and cost of substance abuse by addressing addiction as a distinct problem in many state-funded programs. In the report, the Commission called for a new treatment system model that emphasizes screening for signs of alcohol and drug abuse and early intervention strategies, employs evidence-based strategies to treat addiction, links state funding with improved outcomes, standardizes counselor certification and creates multiple levels of certification, and improves the Substance Abuse and Crime Prevention Act, or Proposition 36, by increasing the use of proven practices such as drug court models. Previous legislation AB 239 (DeSaulnier) of 2008 would have enacted the Alcoholism and Drug Abuse Counselors Licensing Law and would have provided for the licensing and regulation of alcohol and drug counselors by the Board of Behavioral Sciences (BBS). The bill would have created two categories of licensed alcoholism and drug abuse counselors, a "licensed alcoholism and drug abuse counselor I,", who would be a person licensed to practice alcoholism and drug abuse counseling under clinical supervision, and a "licensed alcoholism and drug abuse counselor II," who would be a person licensed to conduct an independent practice of alcoholism and drug abuse counseling, and to provide supervision to other counselors. The bill did not address counselors working in licensed and certified facilities, they would have remained under the jurisdiction of DADP and subject to the existing certification process. STAFF ANALYSIS OF SENATE BILL SB 707 (DeSaulnier) Page 12 This bill was vetoed by Governor Arnold Schwarzenegger. In his veto message, he stated that he was directing DADP to work to craft a uniform standard for all alcohol and drug counselors whether in private practice or in facilities. AB 1367 (DeSaulnier) of 2007 would have provided for the licensing or registration and regulation of Alcoholism and Drug Abuse Counselors, as defined, by the Board of Behavioral Sciences. This bill was held in the Assembly Appropriations Committee on the suspense file in January 2008. AB 2571 (Longville) of 2004 would have created the Board of Alcohol and Other Drugs of Abuse Professionals in the Department of Consumer Affairs and established requirements for licensure of alcohol and other drugs of abuse counselors. This bill failed passage in the Assembly Health Committee. AB 1100 (Longville) of 2003 would have enacted the Alcohol and Drug Abuse Counselors Licensing Law, to be administered by the Board of Behavioral Sciences. This bill died in the Assembly Business and Professions Committee. SB 1716 (Vasconcellos) of 2002 would have enacted the Alcohol and Drug Abuse Counselors Licensing Law requiring the Board of Behavioral Sciences to license and regulate alcohol and drug abuse counselors. This bill was held in the Assembly Business & Professions Committee. SB 537 (Vasconcellos) of 2001 would have required the DCA to initiate a review of the need for licensing substance abuse counselors. This bill was vetoed by Governor Gray Davis who cited as his reason the impact on the general fund. In his veto message, Governor Davis directed DADP to require counselors in drug and alcohol treatment facilities to be certified for quality assurance purposes. AB 79 (Tucker) of 1993 would have required the Department of Consumer Affairs (DCA), to approve private organizations which certify persons working in alcohol or other drug abuse prevention, recovery or treatment programs. This bill was held in the Assembly Health Committee. Arguments in support The bill's sponsor, the Department of Alcohol and Drug STAFF ANALYSIS OF SENATE BILL SB 707 (DeSaulnier) Page 13 Programs, argues that this is a necessary measure to better serve the treatment community and, consequently, the entire state. They state that the bill provides for workforce development and career ladders by establishing uniform qualification and criteria for tiered levels of alcoholism and drug counselors. In addition, they note that the bill would help them protect the public by instituting criminal background checks. The County Alcohol and Drug Program Administrators Association of California supports the bill as an important step toward professionalizing and improving the field of addiction treatment. They argue that the provisions of SB 707 will raise the bar and advance the profession of alcoholism and drug treatment, protect consumers and bring all of the functions under a single state agency. Most important, the bill provides a career path for all alcoholism and drug counselors and address many of the problems in the deeply-flawed system of counselor credentialing that is currently in place. The American Federation of State, County and Municipal Employees, Local 260 argue that this bill will provide higher standards for the valuable work of drug and alcohol counseling. There is a huge need for additional specialists such as drug and alcohol counselors, especially in prisons as well as the community. They would like to see amendments that strengthen the skills for supervising to include education and training on leadership and management. Arguments in opposition Opponents are concerned that the passage of the current version of the bill could lead to dramatic shortages of skilled labor that is necessary for treatment programs. Opponents are concerned about the specifics of the criminal background check. They note that there are many excellent counselors with a criminal background, reflecting a counselor's own history with substance abuse, a history that can be very important for an alcohol and drug counselor. They argue that if treatment leads to rehabilitation and changes lives, the state policy should not be to eliminate qualified people through a background check and they point to how the Board of Behavioral Sciences runs their background checks. STAFF ANALYSIS OF SENATE BILL SB 707 (DeSaulnier) Page 14 Opponents are also concerned that those with a dual diagnosis of mental illness and substance abuse issues will not receive adequate care and won't be referred for assessment, diagnosis and treatment. The California Association of Addiction Recovery Resources questions the need for the bill. They state that the existing counselor certification program, which has been fully operational for a mere 18 months and was 10 years in the making is being set aside. They argue that the current regulations are very comprehensive and that the issues that exist could be resolved easily. They state that they have spent more than $250,000 to develop a curriculum to certify counselors as required by the regulations. They are particularly concerned about the impact on the workforce, in that new counselors will be hard to recruit for the foreseeable future. They point out that it is a field with high turnover and many new counselors are required each year. The high cost to comply with the new requirements will be a significant deterrent to new qualified people choosing this profession. They point out that between all of the fees that DADP will charge plus the cost of the background check, someone entering the field will face a $1,000 bill, in a field with traditionally low wages. They also argue that the process for disciplining counselors will take up to two years, since the bill uses the Board of Behavioral Sciences model, and that is unacceptably long. California Therapeutic Communities argue that many currently in the field have been working for years without meeting the education requirement in the bill as their life experience is an important aspect in their counseling qualifications. They are also concerned that there are too many levels of counselors within the bill, and that the supervising level should be merged with the advanced level. They also argue the treatment facility needs flexibility to determine who meets the qualifications for supervisor. They also argue that additional specific subject matter education be required. The California Psychological Association expresses concerns that a number of issues are not resolved in the legislation but are left to the regulatory process. They are also concerned about making a department the licensing authority for independent practitioners, as compared to the Board of Behavioral Sciences, which oversees clinical psychologists, STAFF ANALYSIS OF SENATE BILL SB 707 (DeSaulnier) Page 15 marriage and family therapists and licensed clinical social workers. They also argue that the scope of practice needs to be tightened to ensure that activities are done in the context of an integrated model, capable of treating dually diagnosed individuals that also have a serious mental illness. They also argue that the requirement that was in AB 239 for the referral for screening for mental illness be included. The California Association of Marriage and Family Therapists opposes the bill because of its ambiguity in numerous sections. They are also concerned that the large number of regulations required for the program to begin by January 1, 2011, may mean that important elements are not enforced or adequately completed. They also argue that the scope of practice is defined by the mere listing of services as opposed to defining principals that clarify the practice of the profession. They are also concerned that the bill may limit the practice of other mental health professionals to treat problems of substance abuse. The California Association of Alcohol/Drug Educators opposes the bill because it should require that more of the education should be in a face-to-face setting rather than through distance education. They point out that many aspiring counselors are in the early stages of recovery and have not yet developed the social skills necessary to become effective, humane and ethical counselors. They also object to the exemption for prisons, which they argue is inappropriate because all people with the disease of addiction deserve quality treatment from certified counselors. They also believe that the education requirements should be altered so that there is a minimum alcohol and drug education component of the overall education requirements. They also argue that the scope of practice language should be amended to reflect a different scope of each of the four levels. The California Psychiatric Association argues that the educational requirements are inadequate and that there needs to be more education on mental illness. They also believe that behavioral disciplines require coherent regulation and that DADP does not have the experience or mission to regulate such a profession and that it belongs in the Department of Consumer Affairs. STAFF ANALYSIS OF SENATE BILL SB 707 (DeSaulnier) Page 16 The San Francisco Women's Rehabilitation Foundation opposes the bill because the bill threatens treatment programs that use the social model. These programs used peer counselors and often on a part time basis whereas the bill contemplates full time counselors serving in a clinical setting or a residential treatment program. The committee received many e-mails from individuals opposing the bill. In general, their concerns were that the bill, as they understood it, put too much emphasis on education and not enough on experience. In addition, many expressed concerns about the background check and the level of the fees to become certified. COMMENTS 1. Many details of the program will be determined administratively through the adoption of regulations. This bill is a structure for a licensing and certification program for drug and alcohol counselors with many of the details to be to established or changed by regulation. Areas needing regulations include the specifics of licensure and certification requirements for those currently certified or practicing, educational requirements for all applicants, the amount of fees, the specific process for registrants to register, the content of continuing education, specifics as to what constitutes supervised work experience, additional detail on the definition of the practice of alcohol and drug counseling, and the processes for appeals and background checks. With the majority of the bill's provisions taking effect January 1, 2011, the timetable seems overly optimistic. The committee should hear from the DADP, the bill's sponsor, as to why they think they can implement this complex bill within the time frame allowed in the bill. 2. The timeframe for implementation could have deleterious effects on the supply of counselors. The majority of the bill's provisions would take effect on January 1, 2011, including significantly new requirements for certification. Those applicants who are not already certified have to meet significantly different new standards, which would take applicants some time to meet. Opponents have characterized the field as having a high turnover. If this is true, it seems unlikely that a new supply of counselors STAFF ANALYSIS OF SENATE BILL SB 707 (DeSaulnier) Page 17 will be available to meet the demand when the bill's provisions take effect. The bill does have grandfathering provisions which could help keep people in the field, but will not help with new entrants. A suggested amendment would be to delay the date of implementation from January 1, 2011 to January 1, 2012, which would also give DADP additional time to complete the necessary regulations. 3. The scope of practice is a list of services. Under this bill, the scope of practice is the same for all levels of certified and licensed counselors. The bill currently establishes four levels of counselors with very different qualifications, but the types of work that each level should be doing is not defined save that licensed counselors can be in private practice and supervisors will supervise. This is an important area that the department will have to develop by regulation. 4. Further significant amendments may occur. This bill may be significantly amended to reflect the results of ongoing negotiations. The committee may wish to ask the author to bring the bill back to be heard again if the bill changes significantly. POSITIONS Support: Department of Alcohol and Drug Programs (sponsor) The American Federation of State, County and Municipal Employees, Local 260 (if amended) California Association of Alcoholism and Drug Abuse Counselors (if amended) California Association of Alcohol and Drug Program Executives County Alcohol and Drug Program Administrators Association of California Drug Policy Alliance Network Oppose: A. K. Bean Foundation California Association of Addiction Recovery Resources California Association for Alcohol/Drug Educators (unless amended) STAFF ANALYSIS OF SENATE BILL SB 707 (DeSaulnier) Page 18 California Association of Marriage and Family Therapists (unless amended) California Psychological Association California Psychiatric Association California Therapeutic Communities Northeast Valley Hospital Association San Francisco Women's Rehabilitation Foundation Numerous individuals -- END --