Editors note: At a time when there is a crisis in both mental health care and behavioral health care, at a time when the state is grappling with its efforts to address the epidemic in overdose deaths and substance use disorders, providing access to clinically trained counselors who had graduated from Rhode Island’s academic institutions would seem to be a critically important part of the equation.

However, a change in wording of regulations, from “subsequent” to “prior,” made recently by the R.I. Department of Health, which is scheduled to become effective on March 7, may have a dramatic impact on dozens of students who are in the midst of their studies, according to Heather Jackson, in a letter shared with ConvergenceRI.

Jackson was accepted and enrolled in the Certificate of Advanced Study Counseling in January of 2017. As the program is described by RIC, “This CGS enables students who already have a Master’s degree, which is fewer than 60 credits, to obtain 60 credits needed for licensure as a mental health counselor in the state of Rhode Island.”

Because of the change in the wording in the regulations, as Jackson explained in her letter, she will now be required to perform all of her 2,000 hours of clinical hours of training again, because they occurred prior to her achieving the 60 credits needed to sit for a licensing exam.

When asked about the changes, Joseph Wendelken, spokesman from the R.I. Department of Health, explained the change as follows: “A student must get 60 credits and get post graduate experience [patient hours] to qualify to sit for the exam. The old language of our regulations read that the post-graduate experience must be accrued ‘subsequent’ to the receipt of a Master’s Degree, Certificate of Advanced Study (CAGS), or Doctorate.”

The updated language, Wendelken continued, “states that 60 semester credits must be received ‘prior’ to beginning the post-graduate experience and supervised case work. There is no actual change in the requirement for students. We simply updated the language [using ‘prior’ instead of ‘subsequent’] because we felt that the new formulation was clearer. The old formulation seemed backwards.”

Translated, Wendelken’s comments appear to confirm Jackson’s premise, that the change in regulation to what seemed to be a “clearer” fomulation may result in students having to redo their 2,000 hours of clinical training with patients, creating a clear barrier of bureaucratic red tape.

PROVIDENCE – I am currently a graduate student at Rhode Island College. I am pursuing my Certificate of Graduate Studies in Advanced Counseling. In 2012, I graduated with my Master’s in Counseling from the University of North Dakota; I graduated with my Master’s in Public Health in 2014 from the University of North Dakota.

At the time of my graduation in 2012, each state had different requirements for masters in counseling program credits. I graduated from my masters in counseling program with 43 credits.

I moved to Rhode Island the end of 2014. I am a single mom, was a former teen mom, and wanted to offer my daughter something more than North Dakota had to offer.

I chose Rhode Island because it is a beautiful state, by the ocean, affordable compared to other parts of the coast, and I had a few job offers. My daughter went to Nathan Bishop for the rest of 7th and 8th grade and luckily got into Classical High School and is currently a 10th-grader.

When I moved to Rhode Island, I decided to become a Licensed Mental Health Counselor, or LMHC. So I applied, got accepted, and enrolled in the Certificate of Graduate Study Advanced Counseling program at RIC.

I am currently taking the second semester of the Advanced Internship class. I will take my final 3 credits this summer and have my 2,000 hours (post Master’s degree, not post 60 credits].

I plan on opening my own practice after becoming licensed and try to fill in the gaps of care related to eating disorders, depression, and anxiety in Rhode Island, as well as working with vulnerable populations such as undocumented people, LGBTQ populations, and low-income. I am also a birth doula and want to integrate that work into my practice.

Currently I am interning at Gateway Healthcare as an in-home clinician. I work on the early childhood team and work with families with children with behavioral issues such as ADHD, PTSD, anxiety, depression, and more.

On Friday of last week [Feb. 16], RIC was informed that the R.I. Department of Health had changed the regulations [for its 2,000 hours of clinical training with patients] from post-masters degree to post 60 credits.

This means all of us in the CGS program [and not only at RIC] will have to start over with our 2,000 hours. This means there is going to be a further lack of qualified, licensed professionals in the state of Rhode Island during a time of opioid crisis, an increase in adolescent females attempting and/or completing suicide, gun violence, and more.

This means Rhode Island could have had many new licensed professionals this year, but now the state has to wait two years for these people to become licensed.

When other states have done this, they grandfathered the people who were attending school and going by the regulations when they were accepted into various CGS programs. But Rhode Island did not offer that. This is unfair. Not only to us, as students, but also to the state of Rhode Island and the people we serve.

Further, some people have well over 2,000 hours, as they may have gotten their degrees years ago and are working later in life to become licensed. This is unfair to all of us who worked so hard to get to where we are.

I am asking that the R.I. Department of Health amend the change in the regulations to allow people to be grandfathered into the change. Not only does this help us as students and professionals but it helps tackle the mental health issues the state is facing [and the nation].

Update: As ConvergenceRI wwnt to press, the R.I. Department of Health said in an email that it was working to resolve concerns around the dhange in wording of the regulations. “Although the actual requirements for students have not changed,” spokesman Joseph Wendelkin claimed, "we recognize that the regulation is now being interpreted differently by Rhode Island College and many students, and that this new interpretation has created some concern. We are going to reach out to graduate faculty, work with them, and see whether accommodations can be made for students nearing graduation."