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DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

BUREAU OF PROFESSIONAL LICENSING

PUBLIC HEARING

October 4, 2019

9:00 a.m. - 5:03 a.m.

Location: G. Mennen Williams Building Auditorium

525 West Ottawa Street

Lansing, Michigan

REPORTED BY: Claudia M. Weekly, CSR-2963

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MS. DITSCHMAN: Hi. My name is Andria

Ditschman. I'm a senior policy analyst for the Bureau of

Professional Licensing in the Department of Licensing and

Regulatory Affairs, and I'll be facilitating the hearing

today. The department staff on the Bureau of

Professional Licensing includes me, Weston MacIntosh,

Tina Marks, Kerry Przybylo, Stephanie Wysick(sp), LeeAnn

Payne and Kimmie Katlyn(sp).

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This is a public hearing on proposed

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administrative rules entitled architects general rules,

counseling general rules, professional engineers general

rules, Board of Occupational Therapists general rules,

and the Board of Pharmacy general rules and continuing

education rules.

The hearing is being conducted under the

authority of the Administrative Procedures Act, Public

Act 306 of 1969 on behalf of the Department of Licensing

and Regulatory Affairs, Bureau of Professional Licensing.

The hearing is being called to order at 9:00 a.m. on

October 4th, 2019 at the G. Mennen Williams Building

auditorium located at 525 Ottawa Street in Lansing,

Michigan.

The notice of public hearing was published in

three newspapers of general circulation, as well as the

Michigan Register Issue Number 17 published on

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October 1st, 2019.

The point of today's hearing is to receive

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comments on the proposed rules. If you wish to speak

please make sure you have signed in. You may use the

cards provided in the lobby for this purpose. Please

hold your card until it is your turn to speak, at which

time you may hand your card to the staff person near the

microphone stand. If you would like to testify and have

not filled out a card please do so now.

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Comments should relate directly to the proposed

rules. If you have questions regarding the rules please

submit your questions as part of your testimony for the

department's review. If you have suggested changes to

the proposed rules please include the specific reasons

why the changes would be in the public interest.

For the record, when you testify please

identify yourself by spelling your name and stating your

organization, if any, that you may be speaking for today.

This will help the department prepare the hearing record

that will go before the joint committee on administrative

rules. Comments will be limited to two minutes per

person to allow everyone an opportunity to speak. If you

submitted a written comment there's no need to orally

repeat that comment on the record. Written and oral

comment count the same.

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Further, a comment received on any issue will

be considered. If you are hearing the same comment

repeated multiple times we ask that you be mindful of the

time and allow others the opportunity to speak on other

issues that have not been raised. Please remain silent

while other comments are being made so that the Court

Reporter can hear them to ensure that the transcript is

accurate. We will also take periodic breaks as needed.

This hearing will close no later than 5:00 p.m.

today. If the hearing is drawing close to 5:00 p.m. you

are encouraged to submit your comments in a written

statement. Written statements can be submitted directly

to me at the table. The department will also accept

written statements e-mailed by 5:00 p.m. today or

postmarked no later than October 4th, 2019.

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We will handle the rule sets in the following

order: Pharmacy general rules, pharmacy CE rules,

professional engineers, architects, occupational therapy,

and counseling. We are going to do our best to group the

comments for each rule set. Please do not get in line to

speak until the rule set you are interested in is

announced.

The first rule set that we'll be taking

comments for is pharmacy general rules. Please get

behind the microphone stand if you wish to speak and hand

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your card to the staff person. That will be me. I'll be

down there. Be mindful of the time cards that announce

how much time you have left to speak. The time cards

will be over on this table over here and we will show you

when you have so much time left and when your time is

done.

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So, we are going to start. One last thing.

Again, because we're doing this a tad bit different than

we usually do, a reminder, please spell your name for the

Court Reporter, speak slowly, and if you have something

that you want to submit in writing and you're going to

read that into the record please just make sure you drop

off a copy of whatever it is that you're saying up here

at the table so we have that as well.

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Okay. So, can you hear me back here? Do we

have anybody from pharmacy general rules that wants to

speak?

SCOTT POPYK: Hi. Good morning. My name is

Scott Popyk, P-O-P-Y-K. And I am here on behalf of my

company, which is Health Dimensions, but also as a member

of MPA, as well as a member of the International Academy

of Compound Pharmacists.

I am here to address Rule 338.533, which

proposes to adopt by reference the compounding standards

of USP Chapter 785, Chapter 787 and 800. And I wanted to

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communicate some issues that have arisen since this rule

was proposed.

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USP has delayed USP 797 and 795. There is some

major technical issues that need to be addressed, and so,

they have delayed the adoption of these or of the

official status of these until further notice, so it

wouldn't make sense for the State to adopt these at this

time.

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Furthermore, USP 800, which is intertwined with

795 and 797 is scheduled to be adopted by the State on

December 1st. Because of the challenge, because of the

issues with USP right now with 795 and 797 800 does not

hold, so it wouldn't make sense for the State of Michigan

to adopt 800 right now, either.

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So, my recommendation is that until the 795,

797 issues are resolved and clarified with USP that they

not be adopted by the State because it's going to change,

and 800 by default should not be adopted until such time

that the foundation of 795 and 797 are resolved. Thank

you.

LARRY WAGENKNECHT: Good morning. My name is

Larry Wagenknecht, W-A-G-E-N-K-N-E-C-H-T. I'm

representing the Michigan Pharmacists Association. I

have a question for Andria. Yesterday I submitted

electronically written comments. I have a couple

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comments that I want to strike from that, and how is the

best way for me to do that? Do you want me to identify

the particular sections that should be changed or submit

a new document? What do you suggest?

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MS. DITSCHMAN: So, there's two ways you can do

that. You can do it on the record, but probably the best

way would be to submit an additional writing today before

5:00 o'clock just saying that you want to modify these

comments. That way I'll have both in writing to submit

to JCAR.

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LARRY WAGENKNECHT: It will just take me one

second. It's relative to Rule 338.534 Sub 1, and Rule

338.534 Sub 4. There's reference to the word shipping a

compound that is sterile. In our document we suggested

changing it to distribute, and that is incorrect, it

should remain ship. So, thank you.

TOM SULLIVAN: I'm Tom Sullivan,

S-U-L-L-I-V-A-N, representing Michigan Surgical Hospital

in Warren, also the Insight Institute for Neurosurgery

and Neurological Sciences, which is our parent company.

We have concerns of Rule 338.501, which defines

compounding. This would be in conflict with the proposed

USP 797, which is essentially -- it is in conflict with

the old version of 797, which is on hold pending appeal,

which as our previous speaker indicated.

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Also, USP 800, which is essentially an

occupational health standard, not enforceable by the FDA,

but USP 797 is enforceable by the FDA. So, the current

version includes the hazardous medication compounding

which will be in conflict with USP 800. So, I would urge

the Board to consider holding the adoption of this until

those discrepancies are resolved.

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I would also urge the Board to consider having

MIOSH consider USP 800 as an occupational health

standard, which is a compounding standard, so it can be

applied equally to all professions and not just pharmacy.

MS. DITSCHMAN: Okay. Is anybody else here to

speak on the pharmacy general rules? No.

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Okay. We're going to move to pharmacy

continuing education rules. If anybody wants to speak on

those rules please come up here at this time. Pharmacy

continuing education?

And also, if someone asks they can always come,

anybody can speak until 5:00 o'clock. So, if somebody

comes in late that still can be fine.

So, I know a lot of you missed the

announcement. I'm just going to quickly kind of go over

some of the highlights. So, what we're doing is we're

taking different professions one at a time. Go ahead and

come up here, make sure you can hand the card to me, and

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then speak in the microphone. And everyone's limited to

two minutes. The time cards are up here. We'll show you

when you have one minute left and when it's time to stop.

And I think that's -- oh. If you have

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something in writing that you're submitting and you're

going to read from that we ask that you put a copy up

here for the Court Reporter so they have that in case

there was issues or questions about that. And I think

that's it.

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We want you to spell your name when you come up

here. Say your name and spell your name and then what

organization you're from at the beginning. So, I'm just

kind of repeating that.

So, once again, pharmacy general rules or

pharmacy CE rules, anybody else?

Professional engineers. Anyone here to speak

for professional engineers? Come on up here.

STEPHEN NICHOLS: Hi. My name is Stephen

Nichols. Steven is spelled S-T-E-P-H-E-N, Nichols,

N-I-C-H-O-L-S. I'm here today representing the American

Council of Engineering Companies of Michigan often

referred to as ACEC/Michigan.

ACEC/Michigan represents more than a hundred

engineering companies in Michigan who employ over 6,000

people. The majority of these are licensed

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professionals. ACEC/Michigan is also registered for

continuing education, a continuing education provider

through the registered continuing education program,

RCEP.net.

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Through ACEC/Michigan programs, conferences,

workshops, seminars there are nearly a hundred hours of

continuing education offered each year to licensed

professionals under the engineering licensure. Many of

the professional engineers have licenses in multiple

states and use the ACEC/Michigan programs to satisfy

these continuing education requirements.

Based on these facts we believe ACEC/Michigan

should be listed under Part 4, Part 339.16041, Rule 41,

Section 1A as a continuing, is an approved continuing

education provider in Michigan, so we would like the

regulations changed to add ACEC/Michigan to that chart.

Thank you.

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MS. DITSCHMAN: Okay. Anybody else here for

professional engineers?

So, we're going to move on to architects.

Anyone here to speak on behalf of the architect rules?

No.

Occupational therapy?

SARA CLARK: Hello. My name is Sara Clark,

S-A-R-A, C-L-A-R-K. I'm a licensed occupational

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therapist in the State of Michigan, and I'm here

representing the Michigan Occupational Therapy

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Association, MIOTA, and the American Occupational Therapy

Association, AOTA. Both organizations try to ensure that

OT services are provided in the best interest of

consumers.

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I'm here today to provide comments on two

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proposed changes to the Board of Occupational Therapists

general rules. The first in regards to Rule 338.1212,

which has been rescinded, we understand this has been

rescinded because it's going to be, it would have been

duplicate language since it's already in the Public

Health Code. MIOTA is requesting that we keep a brief

reference to prohibited conduct being found in the Public

Health Code within our rules. We feel ethical practice

is one of the most important pieces of our profession,

and we want to make sure we our practice is as structured

as much as possible to the definition of prohibited

conduct.

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The other rule we wanted to comment on is

Number, it's Rule 338.1229, Number 4A. The proposed

language states that an occupational therapist who

delegates limited assessments must initiate and direct

the evaluation of the patient or client before delegating

limited assessments to an occupational therapy assistant,

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and we are suggesting to see stronger language that says

that the OT must complete the evaluation before

delegating. We're requesting this because we have

concerns that there's too much room for interpretation in

regards to what the OTA can do in terms of evaluation.

And written comment has been provided by AOTA and MIOTA

on both of these.

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NANCY VANDEWIELE MILLIGAN: I'm Nancy

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Vandewiele Milligan, V-A-N-D-E-W-I-E-L-E, Milligan,

M-I-L-L-I-G-A-N. I am here representing the Michigan

Occupational Therapy Association and the American

Occupational Therapy Association regarding Rule R338.1229

regarding the delegation of limited assessments to the

occupational therapy assistant, OTA.

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Our concerns are while occupational therapy

assistants are trained to assist in the delivery of care

to clients and patients, it is under the supervision of

an occupational therapist as outlined in the standards

established by the American Occupational Therapy

association. The proposed change would allow the OTA to

assess and implement, to assess and implement treatment

prior to the occupational therapist completing the

evaluation. This is a concern because the client and

patient health status and conditions may have changed

since the last treatment or discharge. This could impact

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the client's patient or safety, and it is the ethical

duty of both the OT and OTA to provide the best care for

all clients. It is in the best practice of the OT to

conduct that treatment being rendered, and it is both

client-centered and evidence-based on the patient's

current status.

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In addition, the Medicare Benefit Policy Manual

states that OTAs may not provide evaluative or assessment

services. This rule will be grounds of denial of

coverage for services. I propose that the wording be

changed to initiate and direct the evaluative of the

patient or client before delegating the assessment.

Thank you.

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MS. DITSCHMAN: Okay. Anyone else here to

speak on behalf of occupational therapy?

Okay. We're going to start counseling. So,

what we want you to do is we're going to start lining up

and then speaking. We don't need to have everybody in

line here, but let's line up on this side over here.

Start right here in front of me. Everybody doesn't have

to get up at once because you're just all going to be in

line. So, let's put 30 maybe in line. The rest of you

can kind of fill in then as that line shortens. You're

going to go to that side. So, come around here in front

and go around in back and get in line.

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Everybody does not need to get in line right

now. Just have a seat. What we'll do is then as you

speak then you can go out the door on that side and then

other people can get in line and we'll just keep it

moving.

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So, I'm going to go over just a few things

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again to make sure I touch on -- I know everybody wasn't

in here at the opening. So, everyone is limited to two

minutes to try to get as many people's comments in as we

can. There is time cards up here, one for one minute,

one for stop. I'd like you to please try when the stop

comes up to stop so we get as many people speaking as

possible. When you come up to speak you want to say your

name, spell your name and state the organization that

you're representing. If you're just representing

yourself you just don't have to state the organization.

That's fine. When you're done you can exit at the back

on that side.

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If you're going to read something verbatim from

a sheet of paper you want to submit the paper up here,

the written comment after that so we can have a copy and

make sure it's exactly as you stated.

If you hear the same comment over and over,

it's up to you, but you may want to not repeat that

again, the same comment. Somebody else may have

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something that's different than that that we want to make

sure we address in the rules.

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It does end at 5:00 o'clock today, so if we get

close to 5:00 o'clock and you haven't spoken, which I

think we'll get to everybody here, then put that in

writing and submit that. And I think that's it.

Anything else I missed the first time? Oh.

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The comments should pertain to the rules that are before

you, something in the rules. Otherwise, we can't address

it and take it into consideration. So, you're wasting

your time saying it because we can't do anything with it.

KERRY PRZYBYLO: One last thing. If you are

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reading a comment please be mindful that there is a Court

Reporter here that is trying to take down every word that

you say, and the faster you talk the harder it is for her

to take it down. So, she may reach out to you and tell

you to slow down, so just be mindful. She's sitting

right over to my left, so please be mindful of her as

well. Thank you.

MS. DITSCHMAN: You can hand your card to me,

take the microphone, go for it.

ROBYN EMDE: My name is Robyn Emde, first name

is spelled R-O-B-Y-N, middle initial J, last name is

E-M-D-E. And I am the chair of the Michigan Board of

Counseling. However, I am not standing here as in that

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capacity.

As a private practitioner I was made aware that

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at the June meeting of the Michigan Board of Counseling a

fair compromise to LARA's proposed rules changes was

submitted by the rules subcommittee. This can be clearly

found in the minutes of the June meeting as an attachment

and also attached to this testimony. The endless hours

spent by the rules subcommittee is outlined in distinct

areas of disagreement to the proposal.

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A major inconsistency is the placement of the

terminology of counseling techniques. The placement of

counseling techniques only in the educational section is

completely illegal. I do not state this lightly. Let me

explain the rationale behind this great opposition.

Within the law 333.18101 counseling techniques is listed.

With counseling techniques being a part of the law it

should be within the provisions, not only the education

section of the rules.

It is the law that defines the scope of

practice. In the Public Health Code that counseling

techniques is a developmental approach that systemically

assists an individual through the application of any of

the following procedures, and counseling techniques is

listed.

This results in a grave inconsistency within

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the counseling profession. Per the law, counselors are

required to administer counseling techniques, but per the

provisions it is not listed. The proposed rule changes

suggest that counseling techniques be removed from the

provisions and placed solely in the educational section.

The proposed change of the provisions within

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the counseling profession is not logical. For almost 30

years every Attorney General, board analyst and JCAR

approved the counseling rules. The proposal of the

changes suggests that each one of these individuals were

wrong in their approval. Every one of these trusted

appointed officials were wrong, but now an attorney is

correct? An attorney can testify to the validity of the

counseling profession? An attorney determines the

training and implementation of what makes a counselor?

This is provided to you by the expert witness of the

Michigan Board of Counseling rules committee and approved

by the entire Board of Counseling as seen on their

website.

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HAROLD LOVE: Harold Love. I'm a vice-chair of

the Michigan Board of Counseling sitting here as an LPC.

My name is spelled Harold, H-A-R-O-L-D, Love, L-O-V-E.

Another point of difference between the LARA

advisory staff draft of the rules change and the rules

committee recommendations appears to be LARA's position

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that the majority of definitions currently in the rules

be moved to a new section of the rules that will pertain

to education only. Moving the definitions and thereby

implying they are only applicable to the educational

preparation of counselors loses the important

understanding that some of the definitions apply to

counseling practice and are not solely applicable to

educational preparation; i.e., counseling techniques and

diagnoses.

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The loss of perspective has the potential to

create significant confusion, lack of clarity, and

substantial negative consequences for services provided

to the public by over 10,000 licensed professional

counselors. These 10,000 counselors have provided

counseling services to the public consistent with these

definitions as currently written and approved. The

section of the definition has been in place for over 25

years.

This revision and update to the rules has been

vetted through our prior rules revisions and updating

processes. This included vetting by LARA prior to

meetings of the Board of Counseling, former full Boards

of Counseling, the legislature, and the public. The

current rules committee and the full Board of Counseling

strongly recommends that these definitions remain in

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place in the definition section of the rules applicable

to the counseling section of the Public Health Code.

Another point of difference pertains is the

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training of supervisors, higher educational institutions

throughout Michigan, training individuals that will be

highly effective supervisors and counselors. The

training process includes a thorough supervision

experience for each potentially fully licensed counselor.

The supervision training for LPCs who will be supervising

limited LPCs have recently been required by the rules to

have three years of counseling experience and training

and supervision, serve as an LLP supervisor.

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Prior to January 1st, 2013 the rules specified

that supervisors were required to have training in the

function -- the rest is written down.

MS. DITSCHMAN: I just want to make sure, also,

when you are, if you're reading from something and it's

verbatim and you submit it make sure your name is on

there because we'll also be using that as written

comments. Correct? So, yeah, we'll need copies of all

those. But please make sure your name is on there. And

you may not get the entire thing in the transcript. We

want to make sure you have your name on there and your

organization, if there is one. Thank you.

DIANE PARFITT: Am I coming through? I'm Diane

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Parfitt, D-I-A-N-E, P-A-R-F-I-T-T. I've spent two terms

on the board of counseling. I just finished in June.

I'm also a professor emeritus from Eastern Michigan

University, the counselor of education. I'm also a

private practitioner that does both counseling and

supervision, and I also do supervision training. So, I

speak from a number of hats.

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The training that most counselors within the

State of Michigan receive is in national compliance. The

educational component of the training of counselors in

Michigan includes courses that train counselors within

counselor techniques, counselor techniques and diagnosis.

Licensed professional counselors in Michigan have the

educational background to implement counseling techniques

and diagnosis.

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If the proposed rules go into effect an

estimated 10,000 professional counselors will be affected

and over 10, 100,000 Michigan residents will be without

service from licensed professional counselors. And I

know this well, speaking personally. My life's work is

to serve others. This is an unspoken oath. Every

licensed professional counselor accepts as part of his or

her journey.

If these rules are implemented our clients will

be without a licensed professional counselor. The work

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we have been trained to perform will be null and void.

The citizens of Michigan will suffer greatly without the

expertise of licensed professional counselors. Michigan

has an increasing mental health need.

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These have been recently recognized by the

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educational systems that are to implement funds directed

towards directing the mental health needs within the

schools. Suicide is tragically on the rise and the

second highest death rate among teens in Michigan.

Michigan needs licensed professional

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counselors. The residents of Michigan need the

confidence that this proposal will not go into effect.

For almost 30 years every Attorney General, board

analyst, and JCAR approved the counseling rules. The

proposal of the changes --

MR. MacINTOSH: Time.

DIANE PARFITT: -- suggest that each one --

JIM BLUNDO: My name is James Blundo. I'm the

executive director for the Michigan Mental Health

Counselors Association. Wes and I know each other

because we've had several different meetings in which

we've dealt with things in a different way.

Thank you for this opportunity to provide

comment in the 2019-063 LARA proposed counseling general

rules. As the director of this organization we represent

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licensed professional counselors and the state chapter of

the American Mental Health Counselors. And joining me

today are Napoleon Harrington, MMHCA president, and Irene

Ametrano and Sue Schaeffer, co-chairs of our public

health, our public policy licensure committee.

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MMHCA would like to start by first questioning

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the legal authority of the Department of Licensing and

Regulatory Affairs to promulgate these rules. Through

LARA -- though LARA's staff identify in their draft rules

their assumed authority under ERO Number 1991-9, this

only provides the transfer of statutory authority,

powers, duties, functions and responsibilities from the

previous Department of Commerce to the current Department

of Licensing and Regulatory Affairs, and it specifically

provides that the boards shall retain all of their

statutory authority, powers, duties, functions and

responsibilities.

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Part 161 of the Public Health Code explicitly

states that the department shall not promulgate rules

that constitute the licensure, registration or

examination of health professionals, and that only a

board shall promulgate these rules. Furthermore, the

rule-making authority granted under Part 181 of the

Public Health Code is to the Board Of counseling, itself.

Both Board of Counseling rules committee and the full

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board unanimously opposed these proposed rules. Their

proposed alternative rules were ignored by the LARA

staff.

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With regard to the proposed rule changes,

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themselves, MMHCA recognizes that some do make necessary

and appropriate updates. Thank you very much.

NAPOLEON HARRINGTON: Napoleon Harrington,

current president of the Michigan Health Counselor's

Association. Napoleon, N-A-P-O-L-E-O-N, Harrington,

H-A-R-R-I-N-G-T-O-N.

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With regard to the proposed rule changes,

themselves, MMHCA recognizes that some do make necessary

and appropriate updates. However, we strongly oppose the

proposed rescission of definitions under Rule 338.1751

and the rescission of Rule 338.1757. The unjustified

impact of these rule recessions would significantly limit

a licensed professional counselor's scope of practice and

would directly violate the counseling profession's

ethical standards rendering Michigan's 10,000 licensed

mental health counselors from being able to legally

practice and do so at a time when the need for

professional mental health services in our state could

not be greater.

Additionally, insurance companies will likely

stop reimbursing for the services of LPCs due to the

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significant limits on scope of these rules, these rule

changes would impose.

Sure, counselors could still do case management

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or other such types of work, but they would not be able

to provide any counseling services. This inability for

LPCs to practice in Michigan will not only cause

significant harm to tens of thousands of people across

the state who will immediately lose their counseling

services when the rule changes take effect, it will also

force all Michigan counselors to be in violation of other

professional ethical standards regarding neglect and

abandonment.

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MMHCA objects to the general rationale for

these proposed rule changes. As stated in the regulatory

impact statement, LARA staff claims that these proposed,

these rule changes is to address confusion and

misinterpretation about the scope of practice of the

counseling profession, especially around a counselor's

ability to diagnose.

MMHCA argues there is no confusion or

misinterpretation here. The right of counselors to

practice their profession and employ counseling

techniques, which include diagnosis, consistent with his

or her training and code of ethics, has been guaranteed

in the Public Health Code for ten years before the

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passage of the counselor licensure law.

IRENE AMETRANO: I'm Dr. Irene Ametrano. I'm

representing MMHCA, and I'm also the chair of the

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counseling program at Eastern Michigan University. I'm

continuing on that same document.

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As LARA should be aware, the American

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Counseling Association's code of ethics, which counselors

are legally mandated to adhere to, requires the proper

diagnosis of a client's mental disorder before treatment.

Additionally, under the counselor licensing

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statute, which states that the practice of counseling or

counseling means the rendering to individuals, groups,

families, organizations, or the general public a service

involving the application of clinical counseling

principles, methods or procedures.

Section 18101A clarifies that counseling

principles, methods, or procedures means a developmental

approach that systematically assists an individual

through the application of a variety of specific

procedures, including counseling techniques. The term

counseling techniques, which is explicitly used in the

statute for both the scope of practice provisions and

educational requirements, is a widely understood

professional term that includes a variety of specific

procedures, including diagnosis. Because the term

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counseling techniques is used in the scope of practice,

as well as in the training requirements, it must not be

removed from the definition of scope. There simply is no

rationale, legal rationale for doing so.

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Furthermore, Section 18101 goes on to state

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that the practice of counseling does not include the

practice of psychology, except for those preventive

techniques, counseling techniques, or behavior

modification techniques for which the licensed

professional counselor or limited licensed counselor has

been specifically trained. This language was included in

the statute because these terms were already part of the

psychology licensing statute which permitted counselors

to do these activities in that law's exemption section

for counselors.

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SARA SUE SCHAEFFER: I'm Dr. Sara, S-A-R-A,

Sue, S-U-E, Schaeffer, S-C-H-A-E-F-F-E-R, representing

MMHCA.

In Section 18105-1 of the counseling statute

states that a licensee shall not perform any acts, tasks,

or functions within the practice of counseling unless he

or she is trained to perform such acts, tasks, or

functions. So, the scope of practice for counselors

explicitly includes those acts, tasks, or functions that

a counselor is trained to perform. Under

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Section 18107-1B the program training requirements for

counselors are clarified to include counseling techniques

and other statutory standards for which the board was

required to promulgate rules.

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The rule defining counseling techniques and the

subsequent training and scope of counselors has been in

effect for 30 years. It explicitly states that, quote,

counseling techniques is the application of counseling

and psychotherapy skills and theories in the counseling

process in order to, amongst other things, diagnose and

identify the problem.

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MMHCA also objects to LARA's proposed

rescission of Rule 389.1757, which identifies the

requirements for providing counseling supervision and

specific training in supervision. This training

requirement is a national standard for professional

counseling, which again counselors are legally mandated

to adhere to. If this rule is rescinded counselors who

provide counseling without training would be practicing

in violation of the ACA's code of ethics.

Without the availability of qualified, trained

supervisors Michigan's limited license professional

counselors would also be challenged to meet the ethical

and, therefore, legal licensing requirements to practice

as a fully licensed professional counselor. And LPCs who

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receive their supervision in Michigan would also likely

be ineligible for licensure in other states because their

supervisor would not meet the qualifications in the state

to which the counselor is moving.

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On behalf of MMHCA I would also like to provide

comment on the regulatory impact statement that has been

submitted for the record. We have numerous provisions of

this statement woefully lacking in proper disclosure.

DONALD AMIDON: I'm Dr. Donald Amidon,

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A-M-I-D-O-N, and I'm speaking on behalf of MMHCA.

The Question Number 2 was compare the proposed

rule standards in similarity situated states based on

geographic location, topography, natural resources,

commonalities, or economic similarities. LARA's staff

claims that Michigan's proposed rule standards for

counselors are like other Great Lake states; in essence,

Illinois, Indiana, Minnesota, New York, Ohio,

Pennsylvania, and Wisconsin. However, Indiana,

Minnesota, and Ohio explicitly include the ability to

diagnose in their scope of practice for counselors, along

with 30 other states in the country, while Illinois,

New York, Pennsylvania, and Wisconsin use such terms such

as identify, evaluate, that clearly implies diagnosis.

Number 3 states identify any laws, rules, and

other legal requirements that may duplicate, overlap, or

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conflict with the proposed rules. LARA's staff claim

that there are no laws, rules, or other legal

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requirements that duplicate, overlap, or conflict with

the proposed rules. This is not accurate. As previously

stated, Michigan's Public Health Code requires counselors

to practice their profession, which includes diagnosis as

a component of counseling techniques, consistent with his

or her training and code of ethics. The American

Counseling Association's code of ethics requires the

proper diagnosis of a client's mental disorder before

treatment and requires counselors to be trained in

supervision methods and techniques.

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JESSIKA MARIANO: Jessika, J-E-S-S-I-K-A,

Mariano, M-A-R-I-A-N-O, and I'm speaking on behalf of

MMHCA.

Number 6, identify the behavior and frequency

of behavior that the proposed rules are designed to

alter. LARA staff claim, but fail to document, that the

current location in the rule set causes confusion and

misinterpretation about the scope of practice of the

counseling profession. Again, MMHCA argues there there

is no confusion or misinterpretation here. The right of

counselors to practice their profession, including the

ability to use counseling techniques which encompass

diagnosis, was first established in the Public Health

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Code in 1978 and was maintained with the passage of the

counselor licensing law in 1988.

As previously stated, under Part 181 of the

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Public Health Code, PA421 of 1988, the statute

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specifically defines the practice of counseling to mean a

service involving the application of clinical counseling

principles, methods, or procedures, and the statute also

defines counseling principles, methods, or procedures to

mean, amongst other things, counseling techniques. How

then can LARA staff possibly claim that the definition

for counseling techniques should not be included in the

general rule provisions applying to the scope of

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practice? We are especially curious about this legal

justification, given LARA staff have determined that the

reference to counseling techniques in the education

requirements for LPCs, MCL 333.18107, and then 1B, does

warrant inclusion in the rules related to education.

Finally, these rules have been reviewed and

upheld by the Attorney General, the Legislative Service

Bureau, and the Michigan legislature repeatedly over the

years, including in 1995, 2003 and 2012. Furthermore, in

the more 30 years since the passing of PA421 in 1988

there have been no successful legal challenges to the

counselors' scope of practice under the law and no

successful related complaints filed with the Board of

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Counseling.

ANDREA CASCARILLA: Andrea Cascarilla,

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A-N-D-R-E-A, C-A-S-C-A-R-I-L-L-A, on behalf of MMHCA.

6C, what is the desired outcome? LARA staff

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state the desired outcome of the rules rescission is to

result in fewer questions, fewer regulatory problems, and

greater safety and protection of the public. However,

LARA staff have failed to identify any document any

questions, regulatory problems, or greater public safety

and protection concerns that would warrant these

detrimental rule changes.

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Number 7, identify the harm resulting from the

behavior that the proposed rules are designed to alter

and the likelihood that harm will occur in the absence of

the rule. LARA staff simply fail to identify any harm

that is resulting from Rule 338.1751 or any likelihood

that any harm will occur in the absence of the rule's

rescission other than avoiding confusion, which is

completely unsubstantiated. Further, they identify no

harm that is resulting from Rule 338.177 or would occur

in the absence of the rule rescission. MMHCA again

argues these current rules actually protect against harm

by ensuring counselors are practicing to their ethical

standards and receiving the appropriate supervisions

before practicing independently.

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What is the rationale for changing the rules

instead of leaving them as currently written? While LARA

staff completely claim the rationale is to update

outdated standards, correct typographical errors, supply

clarity to all rules on licensure and reorganize the

rules into a format that is more are user friendly, none

of this rationale applies to the recession of Rule

338.1751 and Rule 338.17757, for they contain no outdated

standards, typographical errors, lack of clarity, or user

unfriendliness.

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I know I'm running out of time. I do just want

to submit for the record, too, a petition, the results of

a petition, over 37,000 signatures opposing these rules.

BRIAN BANKS: Good morning. Before you start

my time I just want to make a point that I did submit a

written comment, so I'm going to stay on a few points

here.

Good morning again. My name is Brian Banks,

and I'm a representative from the American Counseling

Association. I'm here today in opposition of the

proposed rule changes to R338.1751 and R338.1757.

The proposed changes will seriously impede the

ability of at least 10,000 of Michigan's LPCs to provide

services to the state's families, couples, adults,

seniors, veterans, adolescents, and children at crucial

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times in their lives. Rather than improve critical and

much needed mental health services the proposed

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regulatory changes will provide obstacles to the delivery

of quality mental health counseling by LPCs who are

educated, trained, and practice at the highest

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professional standards. Michigan LPCs help at least

150,000 citizens each year who face life's challenges.

Since the promulgation and adoption of Act 368

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of the Public Health Code, creating that LPC credential

in 1988, which includes the diagnosis and identification

of the problem, has been one of the counseling

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profession's core principles. The authorization to

diagnose is essential to providing necessary and

appropriate treatment for clients. Moreover, in Section

E5A, proper diagnosis, of the American Counseling

Association's code of ethics, which governs and defines

ethical behavior and best practices in the profession of

counseling in Michigan, requires the proper diagnosis.

It takes us down a dangerous path. With the

board's mandate to protect the public it is imperative to

have well-trained, experienced, and ethically practicing

LPCs. Eliminating the ability to diagnose will adversely

affect LPCs' professional ethical duties, which are

directly related to the practice of counseling. The

proposed counseling supervision provisions will create

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insurmountable barriers that bar LPCs from providing

needed services to both urban and rural populations in

Michigan.

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I would be remiss if I did not mention the

nation's opioid crisis and the vital role LPCs play in

providing treatment to those affected in Michigan. In

August Governor Whitmer issued executive order 2019-18,

creating the Michigan Opioids Task Force.

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STEPHEN CRAIG: Good morning. I'm Dr. Stephen

Craig, professor and unit director of the counselor

education program in the department of counselor

education and counseling psychology at Western Michigan

University. The name is spelled S-T-E-P-H-E-N,

C-R-A-I-G.

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Thank you for the opportunity to address this

committee. I oppose the proposed rules changes. While

some of the changes are seemingly innocuous and perhaps

necessary to maintain relevance with evolving

accreditation standards, others, including the proposed

change and moving the definitions into the educational

section, only are particularly troubling and will likely

lead to increase confusion and potentially could lead to

substantial costs and overall harm to the public and to

the small business community where many counselors are

employed.

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In a report titled The American State of Mental

Health in America 2018, Nguyen and colleagues estimated

that more than 1.3 million Michigan residents have some

form of mental illness. In the same report it was

estimated that more than 55 percent of Americans with

mental illness never received treatment. More than 20

percent of adults with a mental illness reported they

were not able to obtain the care that they needed. The

four systemic barriers to assessing care that were cited

in the report, it's a lack of insurance, lack of

available treatment levels, lack of financial resources,

and lastly, I quote, a lack of available treatment

providers, end quote.

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The report further cites that although the

Affordable Care Act may have increased the number of

individuals with mental illness who are now able to seek

treatment, those same people are faced with limited

numbers of available providers. The problem, they say,

is that with increasing demand for mental health services

coupled with a high turnover rate of providers due, in

part, to low compensation, it has created a substantial

shortage of mental health professionals. At a time when

1.3 million Michigan residents have some form of mental

illness, at a time when 55 percent of Americans with

mental illness are not receiving treatment, and at a time

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when one of the principle barriers is a lack of available

providers, the Department of Licensing and Regulatory

Affairs is proposing a measure that could effectively

eliminate 10,000 available providers.

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Throughout the regulatory impact statement and

cost-benefit analysis LARA has indicated that the

proposed rules remove confusion about the scope of

practice of the counseling profession. The Bureau of

Professional Licensing has a mission statement that

includes a goal.

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GLINDA RAWLS: Good morning. My name is

Dr. Glinda Rawls, G-L-I-N-D-A, R-A-W-L-S. I'm an

associate professor at Western Michigan University in the

department of counselor education and counseling

psychology. I'm here to complete my colleague's

statement, particularly talking about the role of LARA

and the protection of the public.

In the health professional disciplinary reform

fiscal year 2018 report to the legislature the Board of

Professional Licensure director Pezon in his 2019 report

reported that for the period between 2017 and 2018

identified that there were 5,000 allegations against

licensed health professionals in general received by

LARA, and the grand total of that was 102 allegations

related to licensed professional counselors. And of the

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more than 1500 allegations against the licensed health

professionals that were authorized only 47 were

authorized against LPCs. That means that for the same

reporting period for the 10,000 LPCs who practice in

Michigan the LPCs that were only subject to 3 percent of

those allegations.

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I think that LARA is trying to tell us that

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their role is designed to help the public, but really it

seems to me that the vast majority of counselors are

doing good work and are competent, and including their

roles in diagnosis and to inform the treatment, which

informed the treatment that they provide.

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Many of the proposed rule changes will neither

promote efficiency, nor will it protect the public, and

they will likely create substantial confusion and

potentially cut off Michigan residents to over 10,000

competent mental health professionals.

MS. DITSCHMAN: We're going to take a break in

about three minutes. I'm sorry if you've been standing

in line for 20 minutes. We thought this was the best way

to coordinate it, but we've just been told that everybody

has to get out of the aisle.

So, one last speaker and we'll take about a

ten-minute break. And so, then we'll start back in at

ten after. But the last speaker right now.

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CHRISTINA COLLINS: Hi. My same Christina

Collins, C-O-L-L-I-N-S. And I am an alumni of Western

Michigan University and am here to complete the statement

of two of my biggest advocates and best professors in the

counselor education department at Western Michigan

University.

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I am deeply concerned that a government agency

is actively lobbying against one of the licensed health

professions, ignoring the input of counselors, rejecting

decades-long precedent, and seemingly responding to

pressure from another licensed health profession who

actively seeks to suppress the number of available mental

health providers to serve the needs of Michigan

residents. Rather than showing deference to statutory

language and administrative rules, the latter of which

have been in place for nearly three decades, this

department is attempting to rush through a change that

could have a devastating impact on the mental health

needs of Michigan residents.

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As for the language in the rules associated

with supervision training, we are not, quote, imposing

requirements on a licensee without statutory authority,

end quote. In fact, all licensed professional counselors

have the freedom to decide whether or not they wish to

provide supervision to limited licensed professional

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counselors. We are merely suggesting that for those

individuals who voluntary decide to become a supervisor

of limited licensed professionals they should have the

requisite training to do so.

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Suddenly, after years of scrutiny, review,

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approval, and acceptance, even by this body who seeks to

change it, LARA wishes to unilaterally change the rules

and reject years of precedent.

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For these reasons I stand in opposition to the

proposed rules changes. I respectfully request that LARA

listens to the legitimate concerns raised by LPCs and the

Michigan Board of Counseling and reconsiders their

position on the proposed rules. We are not asking for

what LARA describes as, quote, expanding the scope of

practice, end quote. We're asking for LARA to accept the

nearly 30-year precedent of our licensure law and

administrative rules and allow us to do the important

work that the people of Michigan need us to do. Thank

for the opportunity to express my concerns.

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MS. DITSCHMAN: We are goings to take a break.

This is what needs to happen. If you want to keep your

place as far as speaking you shouldn't leave the room.

It's for the Court Reporter basically so her hands can

rest for a minute. And then when we come back there's

two board members that we're going to let speak. And

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then, as I said, we're not going to use the lines. If

you have already spoken we would ask that you leave the

room because there's many, many counselors outside

waiting to come in and we're limited in numbers. Okay?

(Short recess had from 10:00 AM to 10:09 AM.)

MS. DITSCHMAN: So, we're going to start. We

have a couple board members that are going to go here,

and then we're going by row. So, let's go ahead. We'll

start and we'll go from there.

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CHARLES HUGHES: Hello. All right. My name is

Charles Hughes, C-H-A-R-L-E-S, Hughes, H-U-G-H-E-S. I'm

a board member and also a member of the Star behavior

health providers who are civilians who are trained to

treat veterans. I'm a recently appointed member of the

Michigan Board of Counseling. I'm not speaking as a

board member today but as a representative of my

behavioral health clinic, Munson Grayling Behavioral

Health, and the people that I work with. I work in

Crawford County.

I want to start by telling you of the community

needs assessment and county health rankings in Michigan.

I work in county 83 of 83. Crawford County has the worst

health outcomes in the state. It's a multifaceted

problem, but a large reason why it is ranked so low is

the ratio of mental health providers to patients.

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Crawford County has a ratio of 730 patients to 1 mental

health provider. The state average is 400 to 1 and the

national average is 310 to one. This ratio is with the

current 8 LPCs working in this county. Without LPCs this

county will no longer have any capacity to help the

mentally ill as there are only one MSW currently working

in the county.

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I also work for Oscoda County, who is ranked

81st of 83, and their ratio is 2,070 people to 1 mental

health provider. Many of our patients from Oscoda County

drive to see us, which is a drive of 30 miles, to come

see us at my hospital and my practice.

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My practice has a caseload of over 200

patients. We provide for both Oscoda and for Crawford

County. And we also provide crisis services for the

Grayling emergency room, and without our LPCs there is no

crisis services for private insurance in our counties.

Our small practice took six to nine months to

hire a single LMSW, and without the change or with the

changes we will be unable to serve the people of our

counties.

MS. DITSCHMAN: We have somebody from the

occupational therapy. We're going to have her speak.

The other thing I would like you to do, before she speaks

is if you are in the back row, if you want to move

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forward so you're not waiting you may do that at this

time because we will be filling in with a few more people

in a minute and we're going to be doing this by rows.

So, if you want to move so that you're not waiting longer

feel free to do that right now.

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Okay. Go ahead and have a seat. Just move

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towards the middle. Come on. Move towards the middle

and make space. So, if there is a seat next to you

towards the middle please fill it because we are going to

have more people come in and they are going to be walking

over you in just a minute. So, if you don't want them

walking over you move towards the middle.

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MS. DITSCHMAN: Okay. OT, go for it.

ELIZABETH BENNANI: I'm Elizabeth Bennani. I'm

an occupational therapist. I have submitted my comments

through e-mail, so you should have them.

I basically have some questions. The first

question is how do the proposed rules and changes

coordinate with the existing definitions and functions,

including those defined in the State Operations Manual,

including Paragraph 484.115, condition of participation,

personal qualifications, specialized rehabilitative

services, and medical provider manual. I have attached

in there the various definitions of these.

I also would like to know, and I'm sure

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everybody else, what is the reasoning for rescinding

R3338.1212, which is the prohibited conduct. We also

expect -- okay. Thank you.

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Question 3, will there be a new scope of

practice for occupational therapists, certified

occupation therapy assistants, and the new limited

licensed therapist? How will this new scope of practice

coordinate with AOTA, the American Occupational Therapy

Association.

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And Question 4, with reference to the limited

license what will be the scope of practice of the limited

license therapist?

I have a lot of other comments, but I guess

I'm -- the other concerns that we have is with respect to

the certified occupational therapy assistant. I have

worked with a lot of very knowledgeable and competent

COTAs, but there are no definitions within here as to

what evaluations can be performed and what part of the

evaluation and the training is required.

COURT REPORTER: Could you spell your last

name, please?

ELIZABETH BENNANI: B-E-N-N-A-N-I.

JANET GLAES: Good morning. My name is

Dr. Janet Glaes, and that's spelled G-L-A-E-S, first name

is J-A-N-E-T. I am a member of the Michigan Board of

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Counseling, and today I'm here to speak as a counselor

educator and private practice counselor.

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I'm strongly opposed to the proposed LARA rule

changes. I'd like to point out that the educational

training that counselors in Michigan receive really more

than qualifies them to diagnose and treat their clients.

To give you some understanding of that I'd like to talk

just a little bit about the program I'm most familiar

with, which is Spring Arbor University.

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Some examples of classes my students take are

counseling techniques, clinical psychopathology,

conceptualization and treatment, advanced clinical

psychotherapy and abnormal behavior, and evaluation of

psychopathology, just to name a few of the 60 credit

hours that they take. They go on to complete a 600-hour

internship under the supervision of fully licensed and

trained practitioners, and this is standard practice.

So, a licensed professional counselor within Michigan do

have the experience and the background they need. Our

students go on to work in mental health agencies and

hospitals, family service programs, medical service,

hospice, foster care, and private practice, just to name

a few.

This morning on my way in I heard on the radio

that counselors and counselor educators should have been

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aware of these impending changes. I couldn't disagree

more vehemently. I've been an LPC for almost 30 years

and been a counselor educator for 10. In those 10 years

our students have applied for and been approved for

licensure in the state. I've renewed my license every

three years and paid fees, as we all have.

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All of us have submitted professional

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disclosure statements where we clearly list diagnosis and

treatment as part of our scope of practice and we've been

approved by LARA. I urge you to reconsider these

proposed changes.

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MS. DITSCHMAN: Okay. Anybody in the first

row, start here, would you give me your card and we'll

just kind of move down the rows like this.

JOSEPH GUAJARDO: My name is Joseph,

J-O-S-E-P-H, Guajardo, G-U-A-J-A-R-D-O. I'm here on

behalf of the Michigan Mental Health Providers

Association. I received a Master's of Arts in Counseling

degree from Spring Arbor University. I've been

practicing since 2014. Additionally, I'm a certified

alcohol and drug counselor and certified clinical

supervisor through Michigan Certification Board for

Addiction Professionals. I have worked at two separate

inpatient substance abuse treatment facilities for the

last nine and-a-half years. I've been a clinical

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director and supervisor for the last three.

It is important to me to let you all know that

I've never diagnosed an individual outside my scope of

practice. I've never treated outside of my scope of

practice. If I was treating someone for presenting

problems that I was not specifically trained to provide

treatment or therapy to I would always refer the

individual to a more appropriate helping professional.

This is my DSM-V, and the binding is broken. And I just

wanted to make that very clear.

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As you know, Michigan is experiencing an opioid

epidemic and other significant mental health crises.

Licensed professional counselors are crucial to combat

these issues. The proposed rule changes by LARA to

restrict the scope of practice for LPCs to eliminate the

counselor's ability to diagnose and use counseling

techniques will serve as an injustice to the need to

provide the public substance use disorder and other

mental health treatment populations.

Restricting the LPCs' ability to diagnose

within their scope of practice and counsel will leave

many clients without a treatment provider. These rule

changes will lead to thousands of Michigan residents with

less resources for treatment and therapy that at this

time is very much needed. The families of the clients

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and counselors who work together every day will be

impacted negatively. There's a whole lot of treatment to

be provided and plenty of work to be done. Now is not

the time to limit treatment resources in the State of

Michigan.

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I stand with many, many people, families, and

helping professionals who oppose the rule changes. I ask

the governor to ask LARA not to implement the changes.

MS. DITSCHMAN: I just want a little reminder,

because we just had a few people come in in the back, so

when you are going line by line, when you get up here

what we're doing is make sure you state your name and

then spell it, and organization if you're representing an

organization.

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Once you have spoken we ask that you exit so

somebody else, if you want to, so somebody else can come

in. Because I understand there's lots of people waiting

outside still. If you're hearing the same comment over

and over be mindful that goes into the record here, it

will be reviewed through the process, so you don't need

to, you don't have to make the same comment, just so you

know that.

We're having many more of them. We'll already

know that they were sent in writing. Anything else that

we -- oh. If you are going to read something verbatim

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please leave it up here so that we can give it to the

Court Reporter. Make sure your name's on there. And if

you want to submit written comments but you're not

actually reading the whole thing, if you want to submit

something in writing you can submit it over here to this

table. And I think that's it. Okay. Keep going.

DAYNA WEBER: I study at Wayne State, so I

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intend to be not verbally nervous, but I will try to

avoid negative language.

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I'm very frustrated with a couple of the

statements that I've heard. My name is Dayna Weber,

D-A-Y-N-A, W-E-B-E-R. One of the statements I'm

frustrated with is things that have been going around

that we're underqualified. I'm not going to be rude and

turn this in, but I have a transcript which consists of

78 credits done in my Master's degree, including abnormal

psychology, treatment planning and principles,

psychological assessment, differential diagnosis,

substance abuse, three series of group dynamic courses,

developmental psychology. And I mean I could go on about

how qualified we are. After our 600 internship hours I

did 3,000 clinical hours under supervision. We are not

sitting down watching television during 3,000 clinical

hours, we're doing counseling. We're doing the work that

LARA's trying to basically say we're not qualified to do

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and they're trying to repeal that right. It's

ridiculous.

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I'm also frustrated by the statement that has

gone on in the news that we are not going to be

negatively affected. The bottom line is that 10,000 of

us will find ourselves out of work. 10,000 of us are

terrified. And there are going to be more suicides.

Michigan is already high in suicides. And I'm not going

to filtrate it, but if this happens people will die.

That's it.

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PHILIP HIMEBAUGH: Hello. My name is Philip

Himebaugh, P-H-I-L-I-P, Himebaugh, H-I-M-E-B-A-U-G-H.

It's pretty appropriate that an opera singer went before

me. Before I was a counselor I was an actor, and I still

haven't been offered a modeling contract. I'm not sure

why.

But one thing I am pretty good at is my DSM.

Pretty good at diagnosing my clients, pretty good at

being a counselor. I opened a business about a month

ago, Northwest Counseling and Wellness in Big Rapids,

Michigan. A professional mentor of mine said Philip,

don't be surprised if after your first month you've only

got one or two clients. Okay. I won't be. I have 18

clients. I'm grateful for that, I'm really grateful for

that. I have an opportunity to be a positive force in

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the lives of those in my community. Not a lot of people

get that chance.

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In this past week I had to watch as one by one

my clients came in in tears and said what am I going to

do, if you can't see me what am I going to do? If you

can find a psychologist or psychiatrist in Mecosta County

that's accepting clients and wants to spend more than

three minutes and throw a bottle of pills at them I'd

love to meet that person. I'd love to have the

referrals.

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I agree with my colleague before me. People

will die. Suicides will happen. People will lose their

care. I don't want that. Do you want that? We hear

that we won't be negatively affected. Well, tell you

what, you can come to work tomorrow, you won't be paid,

but don't worry, you can still do your job. Right?

That's what we're being asked to do. You know what? As

it stands right now I think I'm willing to do that.

Because unlike everybody else, the State of Michigan and

at LARA, I care about people. I care about people's

well-being, and I will not let a rule stand in my way.

NANCY CARBONELL: Hello. My name is Dr. Nancy

Carbonell, N-A-N-C-Y, C-A-R-B-O-N-E-L-L. I'm fully

licensed psychologist in Michigan and I have been since

1991. That's close to 30 years. I'm speaking on behalf

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of Andrews University where I'm a full professor and also

coordinate the CACREP, accredited MA in clinical mental

health counseling.

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I also maintain a private practice in a town

where I work with other great counselors who have LPCs

and we refer back and forth with each other. I'm

involved in all aspects of the MA level of training for

those students who are pursuing a licensure as licensed

professional counselors. It's a 60 credit program. It's

rigorous. It addresses all areas of professional

development, including diagnosing and interventions. Our

students are trained to provide supervised treatment for

clients who are adults, couples, family, group, children

and adolescents.

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I'm here to support the HB4325 bill and oppose

LARA's redefinition of the LPCs' scope of practice. I'm

also here to validate the training of these counselors

all over Michigan. They are placed in so many

communities and are valuable. To suddenly strip these

well-trained counselors and supervisors would not only

leave thousands of professional counselors without a job,

but would also be a travesty to the thousands of clients

suddenly abandoned.

It must be noted that many LPCs are actually

servicing many clinics and programs where licensed

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psychologists aren't available to work in. It's a

win-win situation for all of us. Thank you.

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BRAD HINMAN: Good morning. I'm Dr. Brad

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Hinman. I'm a licensed professional counselor. I'm also

a licensed marriage and family therapist. I'm also an

AASECT certified sex therapist. I'm here today on behalf

of Andrews University where I serve as a professor in

graduate psychology and counseling. I am here to speak

for my students and my clients and my university.

If LARA changes the rules as proposed the

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Federal Government will immediately disallow Master's and

doctoral level students to enroll in counseling programs

from receiving Federal financial aid because they will no

longer be pursuing a degree but will resolve in being

gainfully employed. If LARA's intention is to have

Michigan universities lose millions of dollars in

financial aid then you're well on your way.

I also want to go on record to notify you of

the absolute agony and despair of my students when I

inform them of your intention to make a rule change that

would prevent them from practicing the job that they gave

us years of their life to pursue. Ten of them are here

today with me, including my daughter-in-law who is

currently enrolled in our program.

Speaking of losing money, LARA, itself, stands

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to move $1.2 million in renewal fees by licensed

professional counselors who will likely not renew a

license that will be useless in facilitating them to do

the job that they spent thousands of dollars pursuing,

hundreds of hours of training and devoted their life to

serve. Why would LARA want to lose $1.2 million?

Finally, I own a private practice where I

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employ another licensed professional counselor and a

Master's level intern. We serve men with out of control

sexual behavior in extreme southwestern Michigan, and to

my knowledge there is not another therapist specializing

in treating out of control sexual behavior within a

hundred miles of our location. Where are our clients

supposed to go? We have over 80 active clients right

now. Thank you for your time.

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AKASH KUMAR: I'm Akash Kumar. I'm a

psychiatrist and medical doctor. I have no vested

personal interest in the outcome of all of this. I

really only came out of concern for my caseload of 100

patients. Like every other psychiatrist, I spend eight

years training in the diagnosis and treatment of mental

illness. Like every other psychiatrist, I share hundreds

of cases with psychologists, counselors and social

workers. Like every other psychiatrist that I've spoken

with about this matter, I'm baffled by the idea that

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counselors aren't fully qualified to diagnose and treat

mental illness. They're already doing it. They are

already doing it consistently very, very well.

LPCs have no reputation of functioning outside

the scope of their practice. LPCs have no reputation as

functioning inadequately. Many of the therapists I trust

most with my patients are counselors. I literally share

hundreds of patients with counselors. Many of these

patients have spent years building a therapeutic

alliance. Some of these patients are suicidal. There's

already a very severe shortage of therapists in many

areas of Michigan. I don't want to imagine what will

happen to these patients without our army of counselors.

Thank you.

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JODI BARNES: Yes. I thank you for letting me

speak. My name is Jodi Barnes, J-O-D-I, B-A-R-N-E-S.

I'm here to represent MMHCA. I'm a board member. I'm a

licensed special counselor and a national certified

counselor. I've been practicing for ten years. I'm an

LLPC supervisor as well. I went to Central Michigan

University and in the agency counseling track, and I can

tell you we have been trained to diagnose and treat

clients. It's in our transcript. It's everywhere.

And some reasons why, regarding your rules

changes, I oppose them, some reasons why I feel that this

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is the wrong choice is because, first and foremost, our

clients, number one, they will be affected. The suicide

rate will go up. The opioid crisis is a problem. They

count on us to counsel them. It's very important.

Another issue is a counselor's livelihood will

be affected. I have a passion for counseling. I love

this. I wouldn't do anything else. And, you know, I

love my job, so I'd like to keep it.

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Other things that would be affected, other

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mental health professionals will be bombarded and burned

out and chaotic. Restricting the practice of LPCs and

LLPCs in the State of Michigan, there's also a mental

health crisis, so there's going to be more of that. And

we need our counselors.

Also, supervision will be affected. Insurance

companies would stop reimbursing us. And also, lastly,

this is going to affect a lot of us, and I really oppose

these changes, so I hope that you reconsider and let us

practice, let us do our job, let us help people. Okay.

And I ask that you wait on implementing your proposed

rules changes. The solution is House Bill 4325. Thank

you for your time.

MS. DITSCHMAN: The Court Reporter just asked

that we not applaud until somebody's done. I would ask

you if you want to get as many people in here as possible

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please hold your applause to the end because two minutes,

this is taking a long time, it's going to take a long

time to get you up here.

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HEATHER MICHELLE: My name is Heather Michelle.

I'm speaking on behalf of clients, preferably suicidal

clients and suicidal parents, parents who deal with

suicidal ideations. I am a suicide attempt survivor.

I'm a survivor because an LPC was willing to take on my

case when larger mental health institutions were

overloaded.

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On the outside you see a well-composed

professional working mom, but on the inside you don't see

over 20 years of abuse that I have experienced, which

manifested in my adulthood as PTSD, depression and

anxiety took over me. I suicide as my only choice, but I

was determined to see alternative choices. I had all my

life, so I started to seek for help.

Larger mental health institutions denied me or

either treated me bad. Becoming a client for an

institution did take forever, and I had to spend six

months suppressing whatever I was feeling just to stay

alive. By the time I got in I was in such bad condition

the mental health clinicians dealing with me were notably

very overwhelmed. I was just another number on their

list. I felt like I had no choices in my life, but

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despite my experiences I persevered.

When I began seeing an LPC I got my choices

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back because when you are checked into a mental health

institution everything is taken away from you and

everything is decided for you from the moment you wake up

until the moment you go to bed. Choosing life over

suicide involved choosing things that make life worth

living, and I learned how to bring brilliance and

gratification into my life through seeing an LPC. I got

a hold of my choices back.

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If this LARA rule change goes into effect my

personal story reflects that the quality of care becomes

damaged. I want to know today who's go to be held

accountable if someone ends their life when care could

have been provided. What if the suicidal parent, someone

like me, kills themself and more kids end up in the

overcrowded foster care system? LPCs don't need to be

restricted, they need to be empowered.

At the end of the day people who want to kill

themselves don't want to die, they want the pain to stop.

And LPCs -- sorry. And LPCs right alongside for a

healthier life.

I have one more sentence. I have one more

sentence. I'm sorry. I'm the only client that's spoken

today. Because of my LPC I now live a better life than

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the hell I existed in. I'm not out of the woods. I'm

not out of the woods with my mental health recovery yet,

but I'm on the right path. Please don't take that away

from me. My son and every child in west Michigan,

Michigan in general deserves a healthy parent.

MARIN HANN: My name is Marin Hann. First name

is M-A-R-I-N, last name is H-A-N-N. And it's N, as in

Nancy.

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I would like to speak to the harmful impact

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these proposed rule changes would cause. On a personal

note, I use a power wheelchair and serving as a counselor

is one of the few vocational things I'm physically able

to do with the academic training that I have. I went to

graduate school for four years so I can do this. I

studied psychology in my undergrad program because I knew

I wanted to be a counselor and I wanted the psychological

background. I knew that I wanted to practice

psychotherapy by the time I was in junior high. In high

school I took every single advanced placement psychology

and counseling class that was available to me.

Due to needing to be on income restriction for

Medicaid to provide for my personal home care needs I am

forever unable to afford going back to school. All my

limited resources for building a profession went into

this. I will no longer be able to have a career if I

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cannot practice as a licensed professional counselor. I

would survive this, but you cannot begin to understand

the negative impact that this will make on my life.

But what is more important to me than that is

the welfare of the people that I serve. The emotional

damages that this will cause my clients are severe. The

majority of my clients are long-term who have

dissociative identity disorder, PTSD, and borderline

personality disorder. Many of my clients also have very

low income and transportation challenges, and I provide

video access counseling to them and sliding scale fee

options.

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I have spent years building the therapeutic

alliance with my some of my clients so that we could

begin to make progress, and for that therapeutic alliance

to be abruptly severed it will take years of repair work

before they can even start to building an alliance with

someone new.

My clients are incredible people and they don't

deserve to have this happen. They deserve so much more

than this. They need a strong support network that they

can trust that is consistent and dependable. They

need -- coming to therapy with me has been in integral

part of that support. With these rule changes LARA would

be responsible for ripping that support away.

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These people I'm describing to you right now

are absolutely your concern. I don't even dare to

imagine the emotional damage that this might cause some

of them, and I hope it does not come to that. I pray it

does not come to that.

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ELIZABETH REECE: Good morning. My name is

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Elizabeth Reece, R-E-E-C-E. I'm a Master's level

clinician counselor, also a CAADC. To graduate from

Oakland University I was required to complete a course on

using the Diagnostic and Statistical Manual of Mental

Disorders and be able to correctly diagnose mental health

symptoms to pass the course. I also completed classes on

counseling theory, clinical counseling skills, and

supervised counseling practicum.

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The first job of my career was as a therapist

at a drug and alcohol inpatient rehabilitation center in

Michigan where I was employed for ten years. I currently

work as an outpatient therapist.

My biggest fear about the proposed changes by

LARA is the detrimental effect this new rule will have on

the people I serve. If passed, this rule would

immediately disallow 10,000 LPCs from seeing 300,000 or

more persons, essentially abandoning them in the middle

of their treatment. This is incredibly unethical and

damaging.

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Let me share a worse case scenario with you. A

depressed and suicidal person would no longer have the

support they need to have to fight against the urge to

end their lives. I would like to share a statistic with

you. According to the MDHHS four persons a day commit

suicide, complete suicide in Michigan. I know this

sounds dramatic, but it's the nature of our work.

I'm sure you've had heard of the opioid crisis

our state is currently experiencing. LPCs that work in

the field of substance abuse are like soldiers on the

front line of a battle. We are standing next to the

people that are literally fighting for their lives,

desperate to overcome their addiction and get back to

living their lives and being members of this society.

I serve a person who came to the realization

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recently that she was sexually assaulted. This was

devastating for her. Do you really expect me to abandon

her during this time considering it was our work together

that facilitated this realization?

I'm professionally, ethically and morally

obligated to continue serving my people until their goals

of treatment are reached. Science and research have

proven that to overcome mental illness and addiction

counseling is the best chance to reach that goal.

Thank for this opportunity.

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MS. DITSCHMAN: I just want to make sure we're

on the second row. If you just came in you should wait

until we go through and come back. If you've been

sitting here -- who's next? I need a card.

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LISA ROBINSON: My name is Lisa Robinson,

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L-I-S-A. I have a pretty easy last name, but I'll still

spell it. R-O-B-I-N-S-O-N. I am a proud licensed

professional counselor of ten years.

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You've heard a lot of things challenging the

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LARA proposed rules. I want to share something very

personal. Not only have I saved lives, but many of these

people in this room and ones that aren't here have saved

lives. An LPC saved my life two and-a-half years ago

when I became a widow, single mother because my husband

died of cancer. And so, I want you to know that, yes,

this will impact every person's livelihood, but I don't

want to leave this room without you knowing personal

stories of what you do to people, including LPCs. We

save lives. I'm going to echo what somebody else has

said many times in this room. People will die and that

won't be our fault.

MS. DITSCHMAN: Who's next in the row that has

not spoken that has been sitting, didn't just come in?

CHRISTOPHER YOO: Hi. My name is Christopher

Yoo, spelled C-H-R-I-S-T-O-P-H-E-R, last name Y-O-O. I'm

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a Master's level graduate from Northwestern University's

master of counseling program with a limited license in

counseling, and I'm allowed to practice in the State of

Michigan. I would also note that given the comments made

by the MPA representative on the second that my program

is and was CACREP accredited.

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I was made to pass coursework in diagnosis,

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theory and treatment, as many others. I continue to ask

myself what the purpose could be to move those things

into a education section if we're not allowed to practice

them. The belief that Master's and counselors are less

qualified than our fellow mental health practitioners is

unfounded and combated by one of my professors during my

time at Northwestern, Dr. Eric Beeson, who also an LPC

and a Ph.D. level practitioner as well as the

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president-elect of the American Mental Health Counselors

Association. When interviewed about our ability to

practice, and the article I will submit to you, he

succinctly says that Master's level of mental health

practitioners are not therapy-like.

I have roughly 30 clients. I've only been

actively working for about ten months. I can only

imagine what that will grow to. And I can only imagine

where my clients will go or what they might do should we

suddenly not be allowed to continue to work with them.

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Thank you.

MS. DITSCHMAN: A reminder that if for some

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reason you have to leave and you want to leave comments

you can use a card, write it on the back, or if you're

submitting something, another document in writing just

make sure your name is on it. You can bring it up here

and submit it to us.

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CHERYL KALLIO: May name is Cheryl Kallio,

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C-H-E-R-Y-L, last name is K-A-L-L-I-O. I am here today

to express my opposition to the proposed general rule

change for counselors.

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Specifically I have concerns about repealing

our ability to use counseling techniques that we are

trained and the ability to diagnose and identify a

problem. Of great concern is that these limitations

would largely exclude us from reimbursements from

insurance companies, which in large part would end our

careers. The proposed changes also puts counselors in

direct conflict with the American Counseling

Association's code of ethics, which requires a proper

diagnosis. This could subject us to permanent expulsion

from our profession.

For example, without the ability to bill

insurance I would no longer be able to see approximately

80 to 90 percent of my clients. Many of my clients live

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in poverty and they cannot afford out-of-pocket to pay

for a therapist as they're struggling to keep groceries

in the house. I can describe many such scenarios, but

there's not enough time. What you are proposing to do is

not only heartless, but it is unethical to take away the

mental health support for tens of thousands in Michigan.

In addition to my concern for my clients, this

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is about me and my family, too. In 2012 I was divorced

with two young kids to care for. At that time I alone

could not support us securely. I went back to school to

rebuild myself and did everything the State of Michigan

said I had to do to become a licensed counselor.

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I finally built my own practice and have what I

was going for, a stable career to support me and my kids.

And now you are saying nevermind, we're changing the

rules and you're about to potentially lose most of your

career. To say that I am angry after everything I have

done to meet the State's requirements is an

understatement. I am furious at how careless you are

with my livelihood. Your proposed rule change would all

but end my career. This is reckless and unethical.

I am asking you to identify if, how and why

specifically LPCs are failing to meet the needs of those

that seek our help. And if and where there are failures

work with us to create proposed solutions as opposed to

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abruptly ending our careers and mental health support for

tens of thousands of Michiganders.

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MIA REID: Hello. My name is Mia Reid, M-I-A,

R-E-I-D, and I am here to speak on behalf of all the

LPCs, all the LLPCs in Michigan.

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About eight years ago I lost my child to

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murder. By the grace of God I have been able to cope

because I saw an LPC. Okay? When I walked in that

office he said the three words you are -- well, four --

you are not alone. Those are the words that helped me be

able to talk, be able to eat, be able to sleep, be able

to cope.

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Because of that it inspired me to go back to

school because I already had a degree in psychology, but

I wanted to be a clinical mental health counselor because

I wanted to do what that counselor did for me. So, now I

have a practice and it is called Change Happens Today,

and I have clients and I am helping them and I want to

continue to help them. I want for them what was done for

me, help.

MELISSA ESTERLING: Good morning. My name is

Melissa Esterling, that's M-E-L-I-S-S-A,

E-S-T-E-R-L-I-N-G. And I am here today representing

Compassionate Christian Counseling. We have offices in

Spring Lake, Jenison, and Fremont. I am here today to

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express my opposition to the proposed general rule change

for counselors. Specifically, I have concerns with

limiting their ability to practice their therapies in

addition to prohibiting them from billing insurance

companies. This would, in large part, end the careers

and shut down my agency, leaving the thousands of people

we help without the therapists they depend on.

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At Compassionate Christian Counseling we help

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people in Muskegon, Ottawa, and Newaygo, and beyond.

According to a 2019 community health needs assessment for

Muskegon, Oceana and Newaygo Counties there is not enough

access to mental health providers. This should be

considered a crisis as in Muskegon County men and women

are almost twice as likely to be sexually abused when

compared to the national average in addition to 25

percent higher rates of physical abuse. The county rate

for suicide also exceeds that of the state rate by nearly

25 percent.

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Now is not the time to reduce access to mental

health therapists. At Compassionate Christian Counseling

we have 28 therapists, 14 of which are either LLPCs or

LPCs. These LPCs and LLPCs see over 200 new clients per

year, which includes over 5,000 sessions per year with

them. Of those seen, approximately 85 percent bill

insurance. Our agency and those seeking our help depend,

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for the most part, on their ability to bill their health

insurance companies.

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I am asking you to identify how and why

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specifically LPCs are failing to meet the needs of those

that seek our help. If there are failures work with us

to create proposed solutions as opposed to abruptly, for

the most part, ending the careers of many of our

therapists. Thank you very much.

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MS. DITSCHMAN: I ask -- we are going to try to

speed this up a little bit, so if are planning on

speaking and you're in the next row come down here and

like two or three of you so we can keep going really

quickly. I want to get as many people as we can.

BARRY BRIGHAM: Thank you for the opportunity

to allow me to speak to you today. My name is Barry

Brigham, B-A-R-R-Y, B-R-I-G-H-A-M. I am a licensed

professional counselor, have been in practice for 29

years, much of that in private practice with a group of

folks in the Kalamazoo, Michigan area. I've been sworn

into the Family Court as an expert witness, a mental

health witness, in five different counties in Michigan.

I have my Master's degree from Western Michigan

University. As I said, I'm a licensed professional

counselor.

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My primary concern with the amendments that

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LARA's proposing is that it would definitely, it would

definitely hobble my colleagues', and mine, ability to

provide services to our clientele. These are individuals

who need counseling so severely, they need ongoing

compassionate care and treatment, would be forced to

accept alternative services such as the services that

would be much more infrequent in their visits, or some of

the clients would stop altogether the services, and that

would be a tragic thing for them and their families.

So, we already have a mental health crisis, as

was stated. The Mental Health in America report states

that over 70 percent of youth with major depression are

still in need of treatment. More than 10 million adults

have an unmet need for mental health treatment. That

number has not declined since 2011.

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So, the proposed rule changes would further the

mental health crisis, and that's not a crisis that we

need in Michigan at all for our residents. We've just

come through a Flint water crisis not that long ago. We

don't need another one.

My colleagues and I provide quality

professional counseling. And we want to ask, implore

that LARA would hold off on these proposed changes and

implementation of the changes. Thank you for the

opportunity to speak to you today.

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MS. DITSCHMAN: After the break if you want to

speak keep a seat and we'll come back to you.

TEAH DOYLE: My name is Teah Doyle, T-E-A-H,

D-O-Y-L-E. I've been a counselor for 17 years, 8 of

which has been under my LPC here, and I work in

Kalamazoo, Michigan. I have a Master's in counseling at

a CACREP accredited school in Texas. My training

included diagnosis and treatment, treating mental

disorders.

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I work in a group practice where we treat

things such as depression, suicide prevention, trauma

recovery. I'm here to advocate for myself, all of the

other LPCs, the 150,000 clients, and the family members,

co-workers and employers of all of those clients across

the state.

I'm highly concerned about the welfare of all

of the current clients and those on the waiting list

waiting to get in for counseling services even before

this change. Even if they can find someone with

openings, the whole therapeutic relationship will be

severed and have to be re-established, which interrupts

and often ends treatment. Many clients will not be able

to find services or will refuse to take another chance on

another provider.

Myself, personally, this would send my family

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into financial crisis. We would most likely have to

relocate outside of the state. It occurs it me that all

the other LPCs would be in the same position. In

addition, I have a 13-year-old daughter who I adopted who

has services with an LPC. And, as we all know, teenagers

are very finicky, can be at least. It took two years and

three therapists to find the right fit for her. She now

has someone that she works with that she trusts and opens

up to in a way that she doesn't with anyone else. Please

don't take that away from her and please don't -- well,

actually, I'll just end with please let us continue

caring for the forgotten and the outcast of our

community. Thank you.

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LAURA KELLICUT: My name is Laura Kellicut,

L-A-U-R-A, K-E-L-L-I-C-U-T. I'm a licensed professional

counselor. I've been practicing for over ten years. I

was first licensed in the State of Tennessee. Part of

the licensing process was a test known as the national

clinical mental health counselor examination. This

specifically tested my ability to accurately diagnose and

make treatment plans for my clients. So, I was trained

and then tested at the state level with a

nationally-recognized exam to diagnose and treat my

clients. My training and special scope of practice

included these things, and I transferred that same

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license to Michigan.

I have now been practicing in Michigan for over

five years. I'm currently finishing my Ph.D. in

counselor education. I'm trained to and have supervised

others for full licensure, and I teach both undergraduate

and graduate level counseling classes at multiple

institutions.

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I see clients three days a week as well. My

entire livelihood depends on my LPC. My family has

sacrificed so much for me to pursue my degrees and we

cannot make ends meet without me working.

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My clients come to me because they are seeking

a safe place to unburden themselves and receive treatment

for their various struggles. Making the changes that

LARA has proposed will take away my ability to provide

for my family, as well as causing unnecessary anxiety and

stress for my many clients who already struggle with

anxiety, depression, trauma, and various other things.

This will be detrimental to the progress that these

clients have made with many who would struggle if they

had to start with someone new. That concept is

terrifying to many of my clients.

I ask that LARA not follow through the proposed

changes and allow time for HB4325 to pass. Thank for

your time.

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TRAVIS ERICKSEN: Hello. My name is Travis

Ericksen, T-R-A-V-I-S, E-R-I-C-K-S-E-N. I'm a licensed

professional counselor. I have three kids, two of them

are adopted, one sees an LPC therapist. I earned my

Master's degree in counseling from Spring Arbor

University. I've been providing diagnostic and

counseling services for over ten years to older adults in

nursing homes as a program coordinator.

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I'm extremely concerned that LARA does not

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grasp the full scope of the crisis it would create if the

rules were adopted. Being an over-assessor, Federal law

requires that I diagnose serious mental illness in

nursing home settings and ensure that appropriate

specialized mental health services are being provided.

One out of every eight mental health assessors in

Michigan are LPCs. If you take away our current ability

to diagnose we can't do our jobs or continue to assure

the well-being and the safety of nursing home residents

or insure that access to needed mental health services.

There's already a shortage of mental health

professionals serving the older adult population.

Previously I worked at a rural CMH agency and was

literally the only person in the entire county providing

in-home counseling services to older adults.

For the sake of our most vulnerable residents

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of our state I urge LARA to not swap out a reduced LPC

scope of practice for an exponentially expanded scope of

crisis for mental health services in our state. Thank

you.

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KATHRYN ZUVERINK: My name is Kathryn Zuverink,

K-A-T-H-R-Y-N, and then last name is Z-U-V-E-R-I-N-K. I

hold a Master's degree in counseling from one of the top

counseling programs in the nation. I am an LPC. I am an

LLPC supervisor. I'm a small business owner. And I am

on faculty in the counseling program at Aquinas College.

First, I want to thank you for the opportunity

to speak. I will be very brief. My small office that I

own I supervise very several limited licensed counselors.

55 percent of our staff are LPCs or are LLPCs. They all

have full caseloads.

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We can all talk about tens thousands of

Michigan citizens who will be impacted, but I'm here

specifically on behalf of the 27 adults and adolescents

my small office serves who are actively fighting suicidal

thoughts or significant self-harm. For the 17

adolescents we see who are bullied mercilessly every day

we are in the trenches with them every week, sometimes

multiple times per week, trying to keep them safe and

healthy. Please do not get in the way of their

treatment. I strongly urge you to hold off on the rule

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change and allow time for House Bill 4325 to pass the

House and Senate and become law, which will clarify any

question regarding scope of practice. Thank you.

CHRIS PATTERSON: Chris Patterson. I'm a

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licensed attorney and I work for Fahey, Schultz, Burzych,

Rhodes, PLC in Lansing, Michigan. I'm here to actually

address the proposed rules as well. As I reviewed the

action and events that led up to today it appears that

these rules are actually being promulgated in violation

of both the Public Health Code and the Administrative

Procedures Act.

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Before this morning it was actually unclear to

me who was potentially promulgating these rules because

under the Public Health Code it is the Board of

Counseling who is provided with the authority to actually

promulgate rules relating to the licensure

re-examination, renewal and passing of examination

scores. And we already heard before I testified five

board members, themselves, who objected to the rules and

also unanimously rejected the proposed rules at their

June 12th, 2019 meeting.

Section 16145 of the Public Health Code

specifically vests the authority for the promulgation of

these rules in the board. Section 16141, likewise,

prohibits this department from promulgating these rules.

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The proposed rules, and this is conceded in the

regulatory impact statement, that it is actually a change

in the scope of licensure. And specifically Rules 72

through 78 all relate to licensure, relicensure and

renewals. Proposed changes to Rule 74 relate to

licensing examination and passing scores.

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All of these are areas that are within the

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realm of what the board promulgates, not the department.

In fact, there's significant policy reason for this

because the board is vested with this authority because

they're the licensed individuals with the expertise and

experience to actually determine the appropriate

counseling therapies and the principles that provide to

their scope of practice.

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With respect to the statements that the

statutes that underpin the rules do not authorize

diagnosis purposes there are multiple terms that can be

read broad enough to basically underpin and allow the

rules that currently exist. Thank you.

CASSANDRA PATTERSON: Hi. Okay. So, my name

is Cassandra Patterson, C-A-S-S-A-N-D-R-A, Patterson,

P-A-T-T-E-R-S-O-N. I'm just one of the many LPCs here

today that could be negatively impacted by the rules

changes. We're licensed professional counselors, so

obviously I'm here to express my objection.

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So, according to the Centers for Medicaid and

Medicare Services counselors comprise the largest

percentage of the U.S. behavioral health care workforce.

So, LARA's decision to possibly move forward with the

proposed rules and deny the largest sector of the

behavioral health care workers the ability to diagnose is

senseless.

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Licensed professional counselors should not be

expected to treat a disorder of which they cannot

properly diagnose first. This practice is similar to

expecting a physician to diagnose and treat a broken bone

without allowing the physician to first review an x-ray.

This implies that LPCs are qualified to treat mental

disorders but not to diagnose them. Laws in 31 states

explicitly authorize LPCs to diagnose mental illness.

CACREP standards have aspects of diagnosing

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process that are all included in all of our coursework.

The ACA, the largest organization, states in its 2014

code of ethics that counselors not only have the ability

to diagnose but we can refrain from making a diagnosis if

it causes harm to the client.

The National Board for Certified Counselors

includes test items on diagnostic and assessment

services, which appear on the NCE, national counselor

exam, an exam which the board has adopted as an exam in

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Michigan.

Clarity, safety, accuracy are some of the words

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I heard from LARA this week. An LPC's clinical training,

educational requirements, and supervised experiences

clearly, safely and accurately provide counselors the

ability to diagnose. The proposed rules changes should

be denied. Thanks for your time.

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LISA KLEIN: Good morning, afternoon. I'm not

exactly sure what it is right now. It's been quite an

amazing time. All of my people.

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My name is Lisa Cline, L-I-S-A, K-L-E-I-N, and

I'm proud to be a licensed professional counselor. I

opened my private practice in Awakenings Christian

Counseling nearly two years ago after spending an amazing

time at a Christian counseling center, Cornerstone

Christian Counseling, in Kalamazoo under the supervision

of Barry Brigham. I have also one of the heads of the

program that I was in at Western Michigan University

here, so I better do a good job with this.

Just to give you a brief background on my

education, I have a Bachelor's degree in psychology from

Central Michigan University, a Post Baccalaureate in

education from Western Michigan University, and in 2006 I

earned a Master's degree in counseling from Western

Michigan University, which is a CACREP accredited

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institution. I am so proud of what I have done there and

everything that I do. I have 600 hours of training under

the supervision of a Ph.D. psychologist in Munson. But I

see I don't have much time, so I want to get to my

personal information, why I did this.

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The reason why I got into becoming an LPC was

because I have three children, six children together, but

three angel babies and three children surviving. I was

diagnosed 27 years ago with multiple sclerosis, and by

the grace of God I am standing before you and I am

healed. I also was actually given less than a year to

live due to a skin cancer dynamic in which it was

misdiagnosed, and I am still here today.

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I'm fighting with you. You are not entry level

practitioners. You are licensed professional counselors

and you deserve to be there for the people who need you

the most. I want you to walk with my MS clients and my

medical clients, and I will continue to be on that walk

and stand beside you. This is Jericho and I feel like

Joshua and we need to move forward.

LYNN BOZA: Hello. My name is Dr. Lynn Boza,

L-Y-N-N, B-O-Z-A, and I'm representing LPCs as well as

the counselors I work with at Henry Ford College in

Dearborn.

LARA is recommending repeal of rules that

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define the LPC scope of practice under R338.1751,

particularly the practice of counseling techniques and

relatability to diagnose and identify the problem.

Repeal of these rules is another example of the

devolution of professionalism in our society and in our

state. Professionally trained counselors have been

fighting for recognition of their practice for over 40

years. Professional training includes a minimum of 45

credits beyond a Bachelor's degree, a supervised

practicum or internship, and 2,000 hours of supervised

work.

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When the counselor licensure law was passed in

1988 it defined who was considered a licensed

professional counselor. It restricted use of the term

counselor and recognized the professional skills that

LPCs bring to their practice, including the practice of

counseling techniques and ability to diagnose and

identify the problem. We finally were recognized for our

professional ability to practice. Without these and

other definitions the counseling scope of practice is

severely limited. Many individuals will lose their

ability to work in professional settings, and people,

students, who expect to move into the field will face

restricted employment opportunities.

I'm opposed to the repeal of the rules that

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define an LPC scope of practice under R338.1751. Thank

you.

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speaker person to make comments and then we're going to

take a five-minute break. We ask that you not leave. If

you do leave you wouldn't be let back in. Is that my

understanding? People that are in the room. So, you're

going to want to stay in the place that you're at.

Again, if you want to put something in writing

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and not wait to speak you can do that, use the back of

your card, submit it up here and then you don't need to

wait. When we take the break don't move around. Okay?

Everybody's coming in at a certain time and we're trying

to get you based on when you did come in as much as we

can, so if you move around we're hoping you'll just not

take someone else's seat. I think that's it.

ROSANNE RENAUER: Hello. I'm Rosanne Renauer,

R-O-S-A-N-N-E, R-E-N-A-U-E-R. I'm a 36-year career

professional with Michigan Rehabilitation Services, the

State of Michigan's vocational rehabilitation counseling

agency, and I'm currently a doctoral candidate with

Michigan State University in the rehabilitation

counseling education program.

Today I am speaking as an authorized

representative and as a board member of the Michigan

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Rehabilitation Association. These comments are also

supported by Michigan State University's rehabilitation

counseling program. The Michigan Rehabilitation

Association and Michigan State University respectfully

oppose a number of the proposed rules for counseling

licensure published by the department recently,

specifically those at Rule 338.1751, definitions.

The Michigan Rehabilitation Association

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consists of rehabilitation counselors and other

rehabilitation professionals who specialize in the

habilitation and rehabilitation of individuals with

disabilities, including those with mental health

disabilities. There are approximately 1100

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rehabilitation counselors in Michigan, many of whom are

licensed professional counselors or limited licensed

counselors. The professional training and standards for

rehabilitation counselors are very similar to those of

other professional counselors in Michigan. They work in

public and private settings, in special education, in

post secondary education, in mental health agencies, and

in rehabilitation organizations throughout the state.

They work with well over 10,000 individuals who have

mental health conditions. Many of these individuals will

be negatively opposed by the, would be negatively

affected by the proposed rule changes. Thank you.

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(Short recess had from 11:16 AM to 11:26 AM.)

CAROL BERGER: Hi. My name is Carol burger,

C-A-R-O-L, B-E-R-G-E-R. I got my license, I became a

professional counselor in 1999, went to work on a Native

American reservation, and then went back to school to get

my school counseling license, which takes extra classes.

I then was required to take six graduate level credits

every five years or the equivalent. So, I have 70

credits. I also have extensive postgraduate training in

trauma recovery.

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But I want to tell you about two stories from

the alternative high school that I worked at, the school

that served our most vulnerable children in Michigan who

have been bullied their whole life, moved 15 times by the

time they got to us. So, the first one is I'm a calm

person usually, and I'm trained in handling other

people's strong emotions, but one day, early morning, a

boy came straight in my office and he said Carol, I need

you to get me out here or I'm going to kill people. And

I knew he was telling the truth because I had never had

this reaction before. My whole body was trembling. And

I asked myself do I feel safe? Am I safe to take him

home? And I knew that I was, but I knew that I had to

get him out of there.

He had a big knife on him and he handed it over

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to me because I had a therapeutic relationship with every

kid in that school and most of their parents. I called

his mom and I told him I was bringing him home. I went

home with him. I took him home. I de-escalated the

situation, debriefed, safety plan, and discussed next

steps. That boy never came back to school. He was

petrified. What had happened to him, he had got cornered

and threatened by the two kids, students that had never

gone to that school. It was a tragic situation.

The other situation was an 18-year-old girl who

was living in a shelter because neither of her parents

could house her or wanted to house her.

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PAULA DENYES: My name is Paula incident yous,

P-A-U-L-A, D-E-N-Y-E-S. I live in Troy and I have been

an LPC for nearly 20 years. I practice as a licensed

professional counselor at a clinic in Bloomfield Hills,

and I am also an LLPC supervisor. I received my degree

from Oakland University, a CACREP accredited program.

My education included diagnosis, treatment

planning, and counseling techniques. I know how to

diagnose. I know how to plan treatment based upon my

diagnosis and how to appropriately use counseling

techniques. It was part of my professional training. It

is part of what I do every day. It is something I've

done successfully hundreds and hundreds of times.

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My education did not end when I received my

Master's degree and my license. I have sought out and

paid for countless classes and seminars over the course

of my career in an effort to provide the very best care

for my clients, including specialized training in EMDR,

which is used in the treatment of those who suffer from

the effects of trauma.

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In the clinic where I practice my schedule is

completely full and I have a waiting list. The clients I

see are people with whom I've developed a trusting

relationship. They're human beings who are hurting.

They are people with challenges such as anxiety,

depression, grief, loss, trauma, and PTSD. Some come

with suicidal ideation.

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These are people who depend on me, who trust

and want me to help them. What am I supposed to tell

them if I'm no longer able to practice? How am I going

to explain these are rule changes. How do I rip the rug

from underneath these people? How do you think people

who are depressed and full of anxiety will respond to the

news that I can no longer see them? What are the

ramifications for them? What will they do and where will

they go?

ALEJANDRA MEDINA: Good morning. My name is

Alejandra Medina, A-L-E-J-A-N-D-R-A, M-E-D-I-N-A. I am a

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bilingual counselor in Oakland County and I am an owner

of a small counseling business. I speak English and

Spanish. I see anybody who wants to come and seek

therapy from me in either language. I treat women and

men to help them overcome depression and anxiety. I

treat families and their children to learn ways to

regulate and to connect so aggressive behaviors or

unhealthy patterns decrease or disappear.

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I treat adoptive families and their children to

adjust and to develop new and healthier ways to interact

among them so the developmental trauma does not take

over. I treat men and women with bipolar disorder and

clients with obsessive compulsive disorder who are

learning they are more than an illness and who are

finding ways to thrive and to be happier.

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I treat underserved families and individuals

who are falling in the cracks of the system that would

not take them because their mental illness is not too

severe and whose mental crisis are not a priority to get

service at a public health facility.

Diagnosing and applying counseling, which is

what allows me and every counselor to help these

population. The changes of the proposal will affect all

of this and the services we can provide; 40 clients of

mine, their 40 families, their environment will be

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affected once this takes effect.

And I want to finish with a question to LARA

because I don't know if they have spoken to the

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Department of Education about all 10,000 or so counselors

that will not be able to repay their student loans as

myself because of a lack of charge.

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SUZANNE MEINKE: Good morning. Thank you for

the opportunity to speak. My name is Suzanne Meinke,

S-U-Z-A-N-N-E, M-E-I-N-K-E. I'm here representing myself

and my private practice, Meaningful Connections

Counseling from Kalamazoo, Michigan.

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As an LPC, a licensed marriage family

therapist, a certified advanced alcohol and drug

counselor, and a nationally certified counselor I've

treated hundreds of individuals, perhaps more. Just

thinking about how many of these folks have canceled

their day today so that they could be here and stand up

for ourselves and our clients, probably hundreds, maybe

thousands of sessions canceled just today, sessions that

wooer rescheduling for tonight into the late hours, for

this weekend, into next week, and taxing ourselves to be

there for our client.

We are well-trained. We are well-educated. I

personally train many LLPCs, I have many on staff,

students as well at the end of their Master's degree. I

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know that these individuals are prepared and they are

doing amazing work. We single-handily at times keep

people out of the hospital. We save lives every minute

of every day. The risk of us not being able to do what

we do by these proposed changes is detrimental to the

health and safety of Michigan without question.

Some of the populations that we serve that are

most at risk are first responders, police, fire, EMS. We

help folks with bipolar, people struggling with the pain

and despair of infertility, severe trauma survivors, and

at least one-third of our practice is adolescents and

children. The students that we train go into the

schools, and some of our LPCs as well, and meet children

at the school because their parents would be unable to

provide them transportation to services. We help, we

make a huge difference, and we need to be able to do what

we do to continue to do this work. Thank you for your

time.

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MS. DITSCHMAN: Just a reminder, if you came in

at 10:10 do not come up here yet. I'm moving all way to

the back. We'll come back and pick you up if your line

is called. But if you came in after the first break do

not get up to speak yet, please.

MONICA MICHAEL: Hello. I am Monica Michael.

My name is spelled M-O-N-I-C-A, M-I-C-H-A-E-L. I'm a

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professional counselor for ten years in private practice

and a sole wage earner for my family. But I want to talk

about something different. I want to say this is already

been a e-mail submitted, so just a couple excerpts.

It's incomprehensible to me why my state's

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licensing body would entertain a policy change that would

leave so many in the dual-sided relationship of

counselor-counselee stranded. I see LARA's proposed

changes as an aggressive act against a whole category of

mental health provider. Neither research nor practice

supports this kind of sweeping change that are being

proposed. The residents of Michigan have been receiving

quality care by LPCs for over 30 years under the current

regulations.

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One second. When LPCs were granted their

license to practice they legally crossed over from the

category of layperson to professional. As such, they

will spend the rest of their lives liable to the

professional standards and responsibilities of their

ethics boards. To strip them of the ability to earn a

professional wage is a onerous thing. I urge you to

postpone the proposed LARA rules changes and let HB4325

take care of the needed updating of language.

ANTHONY MULLER: My name is Anthony Muller,

A-N-T-H-O-N-Y, M-U-L-L-E-R, and I have worked in the

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behavioral health field for 23 years. I'm the director

of clinical and business development for a large

nonprofit organization called Wedgwood Christian

Services. I also have a document here.

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I'm a well-respected member of the behavioral

health field. I sit on State subcommittees with the

Office of Recovery Oriented Systems of Care. Within the

past five years I have lead the creation and development

of substance abuse treatment programs in ten different

counties; Kent, Allegan, Muskegon, Ottawa, Newaygo,

Osceola, Mecosta, Montcalm, Ionia, and soon to be

starting Eaton.

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In the last year, in response to the public

health crisis of the opioid epidemic I have created and

opened Suboxone clinics, one in Ottawa and one in Ionia.

There's five other programs I've started up in the last

five years and I'll skip those.

Programs I designed have won awards. In 2002

the program I designed won innovative of the year for

intensive outpatient program for adolescent substance

abuse. In 2019 in February we were also recognized as a

national program of the year at a conference in Colorado.

In the past, I'm a state-wide and national and

international trainer. In the past year I've led

trainings for Detroit Wayne Mental Health Authority, CMH

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Partnership for Southeast Michigan, for Southwest

Michigan Behavior Health and the Lakeshore Regional

Entity, also for Michigan State University, I keynoted

the juvenile justice 2020 conference and many others.

At those trainings I trained LPCs, MSWs, LLPs

and LPs. People do not attend because of book knowledge

because the knowledge is learned through my ability to

assess and diagnose clients and implement counseling

techniques.

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At Wedgwood I lead a team of 60; 16 of them are

LPCs and I am an LPC. My competency and value to the

field is not questioned by my peers. It is not

questioned by the Office of Recovery Oriented Systems of

Care, by directors of PHIPs, by directors of insurance

companies or CMHs, Judges or Court administration. This

is the only place in my state where my competence is

questioned.

I am one of 10,000 LPCs. I represent a

fraction of 1 percent of the valuable work being done.

LPCs matter. I humbly ask LARA to hold on the

implementation of its proposed new rules that would

impact these greatly needed services.

MICHAEL DALEY: My name is Michael Daley,

M-I-C-H-A-E-L, D-A-L-E-Y. I'm a licensed professional

counselor. I'm here today about great concerns about the

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proposed rule changes which will impact the profession of

counseling in Michigan. I appeal to the LARA board not

to move forward with the rule changes without the current

House Bill 4325 in effect. Without careful consideration

an entire profession will literally be destroyed.

The Michigan Board of Counseling has voted

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against the proposed LARA changes. The LARA changes will

repeal virtually all the rules that define the

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counselor's scope of work under 338.1751. These rules

are, have been recognized as part of my scope of practice

since the passage of the licensed professional counselor

statute in 1989. Over 10,000 LPCs will be without a

profession if these rules will be adopted. And as a

conservative estimate, 150,000 current clients of

licensed professions will be abandoned.

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I am in private practice with my wife for over

28 years in Rochester, Michigan who -- she's not able to

be here today because she is seeing clients in our

office. I'm also credentialed with Military One Source

as a mental health provider who can diagnose, treat,

plan, and crisis planning for service personnel and their

families, and I'm honored and privileged to serve not

only those members of the Armed Forces, but the Michigan

National Guard active and reservists, and the U.S. Border

Patrol officers and their families.

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I am closing with this comment from my wife in

quotation. The proposed rule changes without the House

Bill 4325 signed into law will place the population at

risk and prevent counselors from doing their work. Thank

you.

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MATTHEW PIERSON: Thank you, LARA, for giving

me the opportunity to speak in front of you on behalf of

licensed professional counselors. My name is Matthew

Pierson, first name M-A-T-T-H-E-W, last name

P-I-E-R-S-O-N.

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I would like to start off with the basics. I

oppose LARA's regulations that limit our scope of

practice to take away our rights to diagnose and perform

psychotherapy, and I strongly support House Bill 4325.

It is my wish that LARA rescinds these proposals that

affect our careers and the livelihoods of our clients and

wait for House Bill 4325 to be law of the land.

I am a proud LPC, a proud graduate from Wayne

State University, as well as a certified alcohol,

certified advanced alcohol and drug counselor. As you

know, with that being said, I passed numerous exams that

cover diagnostics and psychotherapy.

It is my request that I ask LARA to do their

job to protect us and to protect our clients. There's

nothing redundant that can be said about the opioid

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crisis and the suicide rates around here. The proposed

changes are unethical and will just put us at risk of a

mental health crisis. There's probably no point of

return if these proposed changes pass through.

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So, I do ask LARA to please do the right thing,

do the ethical thing. Please do not affect our scope of

practice, and please do not affect the livelihoods of our

clients because I am here for them. Thank you again.

MARK PHELPS: My name is Mark Phelps, M-A-R-K,

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P-H-E-L-P-S. My life was saved by an LPC. I won't get

into the details. His name was David Thomas, God rest

his soul. And I can feel his spirit here today.

I am not an LPC. I'm a marriage and family

therapist. And I stand with these colleagues, these

allies, these brothers and sisters of mine as we face the

challenges of addressing mental health in Michigan

because there is no health without mental health. There

is no health without mental health.

I wish that the board members were here because

what they'd be seeing is not just people commenting on a

rule, they would be seeing a bunch of people standing up

and saying wait a minute, if this goes into effect you're

going to have not just a mental health problem, not just

an employment problem, not just a financial problem.

You're looking at a cascading mental health, no, excuse

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me, a cascading health crisis if this happens because

there is no health without mental health.

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which I am the executive director, 27 percent of our

clients are seen by LPCs. Imagine if 27 percent of, I

don't know, say the fresh water in Michigan were suddenly

unavailable because of some rule would that cascade into

the rest of life? It would. We are going to cut off --

and if 27 percent is any indication of what would happen

outside of my practice then we're talking about a lot of

people who would be cut off from something they

desperately need.

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This is a tremendous mistake. There is no

health without mental health. And I would implore the

LARA board to pause this, to hit the pause button until

HB4325 is passed. Thank you.

KAYLA THRUSHMAN: Hi. Thank you for allowing

me to speak. My name is Kayla Thrushman, K-A-Y-L-A,

T-H-R-U-S-H-M-A-N. I'm an LPC and work at a private

practice called Willows Edge. I wanted to offer a

different perspective and tell you why I received my

degree in counseling in the first place.

I'm from Lake Orion, a small Metro Detroit

town, I've always had a passion for helping others in my

community. Beginning in 2006 in the span of a less than

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10 years I lost 13 friends and classmates to suicide with

little to no warning. These were people I grew up with,

went to school with, worked with, even participated in

Girl Scouts with. I've been to more funerals than I can

count, and I witnessed firsthand what devastation, loss,

mental illness and tragedy look like.

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This horrible loss is really what motivated and

inspired me to want to become a counselor, to help young

people like my friends, who were obviously struggling but

probably thought that they had nowhere to turn to. I

wanted to positively impact my community and be a person

young people with anxiety and depression could turn to

for support, which is why I went to college for eight

years in a row, never taking a break, and graduated with

my Master's degree at Wayne State at the age of 25 so

that I could get right to work helping people and

hopefully saving lives.

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For the last five years I've been working at a

private practice called Willows Edge consisting of eight

LLPCs and LPCs. They are expected to have 5,000 sessions

this year and have over 300 active clients spread over

two locations. Our outreach covers approximately six

other townships. And I personally treat 48 active

clients. And I have counseled 74 clients and their

families in the past five years. Many of my clients are

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adolescents who showed up with symptoms of depression and

anxiety, including trauma, suicidal ideation, and the

history of self-harm behavior and suicide attempts, and

they rely on me for support.

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I ask that you reconsider allowing LARA's

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proposed rules changes to take place that affect LPCs'

practice, or at least take more time to offer alternative

options for LPCs. I'm asking that you look at the

situation from our perspective. It is our job as

counselors to see and understand the perspective of

others, and we are damn good at what we do. It would be

irresponsible, careless and dangerous if the new scope of

practice were to go into effect, rendering our degrees

and licenses worthless if --

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MR. MacINTOSH: Time.

THE WITNESS: Someone must be held accountable

for the damage to hundreds of thousands of people.

SYDNEY TREMONT: Hi. My name is Sydney,

S-Y-D-N-E-Y, Tremont, T-R-E-M-O-N-T. I am here today to

advocate for the passing of HB4325 and to immediately

reject the proposed rule change by LARA R338.1751. I am

a graduate of the Master's program at Wayne State

University in counseling and art therapy, and currently

I'm a licensed professional counselor and registered art

therapist in the State of Michigan.

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It is upsetting and appalling that such a gross

violation of mental health needs is being proposed by

LARA. The number of lives, both as clients as

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professionals, that would be devastated to this proposed

rule change is incomprehensible. How does the community

plan to handle the displacement of 150,000 clients seen

by 10,000 LPCs?

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Part of my job is to sit with a person and

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listen, to quietly observe their movements, dress manners

of speaking, thought processes, emotional responses, and

affect. I build a safe, non-biased atmosphere so that

when a child tells me that physical or sexual harm is

occurring I can report it and provide care. How will

LARA's proposed change impact the number of children who

will go without care? The number of people seeking

rehabilitation for drugs and alcohol who will go without

care? People struggling with psychosis, grief, anxiety

and depression can go without care? Who will provide

these spaces for people? And how will the lack of these

spaces impact our communities?

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Not only will this proposed rule change impact

my clients, it will impact me. I have spent upwards of

$100,000 on my graduate education, NCE testing, LLPC and

LPC licensing. I spent hours away from my children, my

husband and friends in pursuant of an education and

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career to provide for people that I love. I made these

sacrifices intentionally to secure a future for myself

and family. If my profession is exterminated how will I

pay for housing and food for my family? How will I

continue to contribute fiscally to my community? What

will this proposed rule change do to our economic

climate?

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JACQUELINE PARADISE: My name is Jacqueline,

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J-A-C-Q-U-E-L-I-N-E, C. Paradise, P-A-R-A-D-I-S-E. At

the age of nine my son was diagnosed with anxiety and

panic disorder. He was immediately given drugs, which

only created more issues and did nothing to help him cope

with everyday life. For the next ten years of his short

life it was prescription after prescription and diagnosis

after diagnosis in an effort to hide the problems with

the right drugs.

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We need more counselors who have the time and

ability to diagnose and identify the problem and help the

individual create coping skills to deal with their

issues. Prescription drugs are fine as a last resort,

not as the first course of action.

At a time we need mental health professionals

the most please don't jeopardize the careers of thousands

of counselors and leave thousands more without the help

they desperately need. I urge you to support House Bill

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4325, which would strengthen the mental health counseling

profession and negate the need for LARA's rule changes

under R338.1751. Thank you.

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LINDI JOHNSTON: Hi. My name is Lyndi

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Johnston, L-Y-N-D-I, J-O-H-N-S-T-O-N. I'm a licensed

professional counselor living and working in the City of

Detroit. I have a private practice where I specialize in

working in the field of sexual health. I work with

individuals and couples. Many of my clients identify as

lesbian, gay, bisexual, trans or queer, and most live in

the City of Detroit, which, like the rest of the state,

suffers from a shortage of mental health professionals.

I currently have a waiting list of clients who want to

see me for therapy.

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I graduated with my Master's degree in

counseling psychology from Lewis & Clark College in

Portland, Oregon in 2005. I was trained extensively in

diagnosis and treatment of mental health disorders. I

did an internship where I trained as a mental health

clinician. My entire education was focused on diagnosis

and treatment of mental health concerns. I've worked in

the field since then in different settings; in healthy

violent shelters, hospitals, hospital ERs, and most

recently in my private practice.

I've been a licensed professional counselor

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since 2011, first in Oregon and now in Michigan. I have

additional training in sexual health through a year-long

sexual health certificate program at the University of

Michigan.

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Overwhelmingly, the feedback I get from clients

is we are so glad we found you. While there are other

LGBTQ-affirming therapists who specialize in sexual

health in Detroit, they are also full and have waiting

lists themselves. This rule change that LARA is

considering will only make the shortage of therapists a

larger problem, and it's especially troubling for my

clients who are part of a very large population.

While I am very concerned about my clients'

with-being I'm also concerned about myself as a small

business owner. I'm the main income producer in my

family and I'm not sure how I will sustain my career and

business without the ability to diagnose and treat mental

health conditions. Again, this is what I'm trained to

do.

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I'm here to encourage the LARA board to wait on

implementing the proposed rule changes. The solution

that meets both LARA's need and LPCs' need is the House

Bill 4325. Thank you.

HOLLY RHODE: Hello. My name is Holly Rhode,

H-O-L-L-Y, R-H-O-D-E. I'm here representing the National

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Alliance of Mental Illness, NAMI Michigan. I'm the

president of the Board of Directors. NAMI happens to be

an organization that's the nation's largest grassroots

organization working to improve the lives of those living

with mental illness. And I'm here today representing a

large footprint in Michigan that opposes LARA's changes

in the scope of practice for licensed professional

counselors. It's our belief that we want to see access

to care widened and care improved for those living with

mental illness, and that this bill does quite the

opposite, so we oppose the changes.

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My brother has schizophrenia, and my family

would gladly tell you that we've been through some very

dark times. NAMI understands and is made up of many

people that have experienced the same thing. And we

understand this gentle delicate balance that takes,

focuses mental illness to a place of recovery. We

respect that. And we do not want to see relationships

with therapists terminated over regulation.

Additionally, our pulse of the mental health

network here in Michigan tells us this would be

detrimental to a lot of agencies, and so, we urge LARA to

pump the brakes on their regulatory changes. Thank you.

KODA HAYNES: Hello. My name is Koda Haynes,

K-O-D-A, H-A-Y-N-E-S. And I'm here to talk to you today

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because I'm not talking as an LPC. I'm talking as a

parent of a 13-year-old autistic son who just spent

almost three hours yesterday crying and having a complete

meltdown, finding out he might lose his therapist of six

years, the therapist who has helped him not only be able

to take all general ed classes for the first time and be

prepared for high school, who I can go out in public now

and he's not having a meltdown because there's too many

people.

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He understands his triggers. He is learning

how to communicate. And you're wanting to take away

something that ultimately will not only destroy him, it

will destroy the relationship I have with him. It will

destroy his school education because he will not be able

to learn how to continue to function. And he will

regress.

So, I am hoping that you will think about this

and remember that it's not just a staffing. There are

people that will be detrimental to their health, their

lives. Thank you.

JENNIFER BLOUGH: Hi. My name is Jennifer

Blough, J-E-N-N-I-F-E-R, B, as in boy, L-O-U-G-H. I am

the owner of Deep Water Counseling and I am an LPC. I

employ nine counselors. We have a waiting list of at

least 30 people. I cannot bring on counselors fast

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enough. And I think I speak for every person in this

room, every person outside, what an honor it is to sit

across from a client who's about to graduate and hear

them say to you you saved my life.

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And I want to tell you really briefly why I am

qualified, why all these people are qualified to save

lives. I went to school in California. I got my

Master's degree, with distinction I might add. I have a

specialization in marriage and family therapy, as well as

professional clinical counseling. Besides my graduate

program I had a thousand hours of practicum in

internships, seeing clients. Then I came back to

Michigan and had 3,000 additional hours seeing clients.

I have postgraduate certifications in supervision, grief

and loss, compassion fatigue, and trauma.

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I can't fathom what I will say to my clients if

I can no longer see them. When my client says I'm

currently suicidal, I'm depressed, you are the one thing

that's keeping me going I don't know how I'm to tell them

that I will no longer be able to see them.

So, like look my colleagues, I just ask you to

please, please support HB4325. Thank you.

ROBIN PADILLA: Hi. My name is Robin Padilla.

R-O-B-I-N, P-A-D-I-L-L-A. And I am a licensed

professional counselor.

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I'd like to add to my comments in support of

the colleagues that have spoke today in the form of our

ethical duty. Based on the ACA code of ethics I'd like

to speak to a few specific ACA codes. A.4A, avoiding

harm. Counselors act to avoid harming their clients.

LARA's proposed changes will, in fact, cause us to

violate this code, as it is evidently clear that by, in

effect, prohibiting ourselves from being able to continue

to counsel our clients would affect counselors into a

position of causing harm to our clients, in some cases

creating such harm as to create the further trauma in a

client's live.

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Which leads to Code A11C, appropriate

termination. Due to the speed and narrow time constraint

that LARA's proposed changes are to be made, appropriate

termination is not something that we will be able to

ethically do without most clients feeling abandoned.

This then also leads to Code A12, abandonment

and neglect. Counselors do not abandon or neglect

clients in counseling. Not only will we be violating

this code by forced to abandon clients, but as a result

of the shortage that already exists in the State of

Michigan our clients will truly have nowhere to go.

Finally, Code C2E, consultations on ethical

obligations. Counselors take reasonable steps to consult

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with other counselors, the ACA ethics and professional

standard departments, or related provisions when they

have questions regarding their ethical obligations or

professional practice.

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Following my code of ethics, as I have been

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thoroughly trained to do, I am here today and I have

questions. How is it possible then that the very code of

ethics that, if we were in any way to violate, would mean

the loss of our professional license, that is now the

proposed changes by LARA would, in fact, cause us to

violate these same code of ethics.

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How is conscionable that neither 150,000

patients be suddenly left without treatment and no clear

way of receiving or affording treatment elsewhere? And

how is it that the State of Michigan claims that it's

trying to attract and build more jobs is in a position to

actually wipe out tens of thousands of jobs in one field

that has already got a shortage?

AMY SZARAZ: Good morning. Thank you for

allowing me to speak. My name is Amy Szaraz,

S-Z-A-R-A-Z. I graduated in 1995 with my professional

counselor degree from Central Michigan University.

It was the regulatory impact statement that

allowed LARA to advance on this path of changing the

scope of practice for 10,000 plus licensed professional

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counselors in Michigan, LARA's proposed rules change of

LPC's scope of practice so severely that immediately upon

implementation of the proposed rules any LPC whose job

depends on the ability to diagnose and provide

psychotherapy services will be immediately unable legally

to do their job. This includes any LPC working in a

prison, an emergency room, or substance abuse recovery

center.

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The regulatory impact statement states at least

nine times that small businesses will not be affected by

the rules changes economically or otherwise, and that

it's only licensees that be affected by the proposed rule

changes, there is no expected significant impact on job

elimination because of the rules, Mr. MacIntosh wrote.

I would like to inform you that hundreds, if

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not thousands, of small businesses will be severely

damaged or forced to close entirely if LARA's rules

changes are implemented before House Bill 4325 is signed

by the governor.

LARA also states that the department has no way

of knowing how many small businesses will be affected

because they do not have access to that kind of data.

How can that possibly be true when LARA has an e-mail

address and professional disclosure statement for every

licensee. And if LARA had even e-mailed a thousand

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licensees and asked how the licensees' place of

employment would be affected by LARA's proposed rules you

would have access to the kind of data that nearly

100 percent of business where LPCs are employed would be

debilitated or have to close. Hospitals, prisons,

Community Mental Health, and more would be severely

debilitated. Lastly --

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MR. MacINTOSH: Time.

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MS. DITSCHMAN: We're going to -- thank you.

You want to submit your --

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AMY SZARAZ: Yes, I will submit it with the

report and I would like to request that you --

MS. DITSCHMAN: We're going to take a break.

The good news is that you can leave the room. You can go

use the restroom. We're going to take a quick 20-minute

break for lunch, and you can't leave the building,

though, because if you do there are other people waiting

to get in, you won't be allowed back in, so you're at the

end of the line.

Just a second. When you do come back in please

take the same seat so you're not getting in front of

someone else to speak. And you had a question about

taking cards? No, you don't need the card as proof. Is

that correct, Kerry?

MS. PRZYBYLO: Right.

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MS. DITSCHMAN: And if you want to submit the

card of comments again you can do that. Let's do it

right up here. But if you leave your card I can't say it

will be there when come back, so you may just want to

keep it on you. Any other questions, any other comment,

Kerry? Okay. Twenty minutes.

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(Short recess had from 12:06 PM to 12:32 PM.)

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ANGIE LANDRUM: I am Angie Landrum. I am

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representing myself and my business, a Brighter Tomorrow

Counseling. I am an LPC. I am also a Board certified

telemental health and I'm also clinical military

counselor certified. I have my own practice in

Coldwater, and I've had it for about seven years.

I work with -- I am contracted with Child

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Protective Services and foster care. I work with

children, children and adults. I work with kids who have

been traumatized. I work with kids who have been removed

from their parents. Some of them have been in multiple

foster homes and residential homes. They suffer from

abandonment, rejection, trust. They have behavioral

problems, PTSD, low self-esteem.

I am recognized by the Branch County Court as

an expert for neglect and abuse. I also extensively work

with child sexual abuse. Children, the child sexual

abuse stats is one in three girls and one in six boys

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will be abused by their 18th birthday.

I also work with the general public. I work

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with suicide. I work with depression, anxiety. I'm

concerned for these children. I'm concerned for my

clientele. These kids, you have to build a trusting

relationship with them. And if you -- they don't want

somebody else. It takes a while to even build that

relationship to where they'll even talk to you. And now

we're going to abandon them, which is against our code of

ethics.

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So, I'm asking that you put this on hold and

that you wait for Bill 4325 to pass. There are like

13,000 children in foster care, and I don't even think

that's counting the ones in the CPS system. I do not

work outside of my scope. I don't do testing.

ERIKA ALEXANDER: Hello. My name is Erika

Alexander, E-R-I-K-A, A-L-E-X-A-N-D-E-R. And I'm a

licensed professional counselor, having earned my

Master's degree from Oakland University 20 years ago. In

addition to my Master's degree I hold postgraduate

certification in advanced alcohol and drug counseling and

I'm a certified clinical supervisor.

The proposed LARA rules changes specific to

techniques and diagnosis seek to eliminate my ability to

practice what I have been trained to do. Moving

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diagnosis and counseling techniques to the education

section alone will prevent Michigan LPCs and LLPCs from

operating a business. I am terrified for the individuals

and families currently being seen by LPCs and LLPCs who

will find themselves suddenly without counselors should

the LARA rules go in effect.

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I have worked for the past 19 years at a

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private nonprofit agency which provided counseling

services to more than 2,000 children and adults in the

last year alone. If the proposed rules are adopted more

than 1,000 individuals will go without treatment as LPCs

make up half of our clinical staff.

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Our agency, like many across the state, treats

vulnerable individuals, trauma survivors, foster

children, parolees and probationers, veterans, domestic

violence victims, people suffering from addiction and

mental health disorders. We do so in a state-wide market

that is void of an adequate workforce to begin with,

including LPCs and LLPs. But my agency is only one

organization.

All clients being seen by an LPC or LLPC across

the state will be impacted greatly by the loss of their

therapist should these rules be adopted. There is no

reason to prohibit the working men and women in the

counseling profession from doing the work they've been

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trained to do. Thank you.

THOMAS KLEIN: Hello, and thank you for

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allowing me the opportunity to speak today. My name is

Thomas Klein, T-H-O-M-A-S, K-L-E-I-N. And I'm a licensed

professional counselor and a nationally certified

counselor.

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In my time as a counselor I've worked with

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people suffering in the grip of the opioid crisis, people

who have wanted to complete suicide, couples on the brink

of divorce, and children who have been bullied so badly

they are thinking about bringing a gun to school. I have

also worked with parolees and probationers integrating

into society who have been convicted of domestic violence

and criminal sexual conduct. In many of these cases I

see myself as one of a select few people who is qualified

and willing to do this work. The schooling I received at

Oakland University gave me the skills I need to be able

to accurately diagnose these clients and to take steps I

need to build rapport.

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I'd like to focus on the treatment of sexual

abusers. The Department of Corrections made sure that I

am qualified to do this work with additional training in

diagnosis and assessment. At one point there were only

88 of us working in this program, and I was solely

responsible for St. Clair, Huron, Sanilac, Tuscola,

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Saginaw, Genesee, Shiawassee, and Livingston Counties.

This work has given me purpose I have not known in

previous jobs. And I know there are less victims of gun

violence, domestic violence and sexual assault because

I'm able to do what to do.

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I'm here today to ask you to help me work to

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make Michigan safe for all of us. I'm not here to ask

for an expansion or even a change to our scope of

practice. I have no interest in that at all. I'm here

asking for preservation of the scope of practice that has

been implied and implemented precedent for 30 years.

I'm asking that I be able to continue to

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provide for my family and to continue allowing me to help

the 62 clients I currently serve and, thereby, their

families, friends and countless others. Please consider,

reconsider your changes and allow House Bill 4325 the

opportunity to pass. Thank you.

ANNA KLEIN: Hello. Am I loud enough? Thanks.

My name is Anna Klein. Thomas is my husband. My name is

spelled A-N-N-A, K-L-E-I-N. I am a registered nurse here

in support of LPCs. I'm a labor and delivery nurse. I

work with women and mothers in some of the happiest and

saddest times of their life. One in seven women

experience perinatal mood disorders during the pregnance

and postpartum period.

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If this bill change passes, if LARA's proposed

changes take effect mother and infant morbidity and

mortality will see a huge increase in the State of

Michigan. Please reconsider. Thank you.

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SCOTT ADAMS: Hello. My name is Scott Adams,

S-C-O-T-T, A-D-A-M-S. I'm an LPC and I'm also an Air

Force veteran. I have a Master's in counseling from

Eastern Michigan University, which is a CACREP accredited

program. I am also a nationally Board certified

counselor.

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As a veteran I have an insight into what

veterans experience that differs from many in the

population. I am well-aware of the amount of men and

women who have served our country in these counseling

services. When the response to a veteran is they can go

to the VA there's a part of them that don't understand

the shame dealing with the need veterans. I have had

many veterans that I've worked with tell me that because

I am a veteran and that I work outside of the VA they

feel more comfortable talking with me.

We are all aware of the high number of veteran

suicides and how crucial not just access to mental health

therapy is but therapeutic rapport. Therapeutic rapport

is something that would be greatly damaged if LARA's

proposals go through. As we have heard, we have many

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mental health crises in the state, from suicide, opioid

addiction, to veteran suicide.

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Along with veterans I work with refugees from

around the world, along with clients from many different

backgrounds. My goal and hope is to continue to provide

my brothers and sisters who have served our country the

counseling services that they need and require, along

with all my other clients.

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I want to end asking one simple question.

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Where is LARA? Where are other people who are intent on

destroying our ability to practice, and are they willing

to accept the responsibility for the mental health,

trauma and abandonment that their decision will cause?

I'd like them to speak up if they'd like to talk. Thank

you very much.

ADAM HAMILTON: Hello. My name is Adam

Hamilton, A-D-A-M, H-A-M-I-L-T-O-N. I'm here

representing Oakland Community Health Network, which is

the prepaid inpatient health plan, and CMH in Oakland

County, Michigan. Oakland Community Health Network and

its staff provide a network, touches the lives of

approximately 27,000 people annually. It's estimated

that 25 to 30 percent of the public mental health system

workforce is comprised of LPCs. LPCs working across our

system work in harmony every day with practitioners of

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other disciplines. OCHN opposes the implementation of

this rule, supports the passage of House Bill 4352.

Thank you.

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LAURIE RUDOLPH: Hi. Thanks for letting me

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speak. My name is Laurie Rudolph, L-A-U-R-I-E,

R-U-D-O-L-P-H. I am a licensed professional counselor, a

certified advanced alcohol and drug counselor, and a

national certified counselor, and a certified trauma

specialist.

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I'm a veteran, I'm a private practice owner,

and I'm a widow of a 100 percent disabled veteran who had

100 percent PTSD. I've worked for 14 years as a

therapist. I started in a victory clinic, a Methadone

facility, and then I started my private practice, which

I've had since 2013.

I now work six days per week from 9:00 a.m. to

9:00 p.m. to handle my caseload. I see veterans. I see

people who have addiction, people in Drug Court, Sobriety

Court, trauma victims, including children, people with

suicide ideation and PTSD. I want to know who, what

licensed psychologist, psychiatrist, who is going to work

the way that I do to provide for my clients. I am there

when they need to call me. I'm there when they need to

meet with me. I don't know who. Maybe 10:00 a.m. to

4:00 p.m. isn't going to work. Irregardless, my clients

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will be abandoned if you implement these LARA

regulations. Thank you.

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MR. MacINTOSH: We're going to pause the

counseling rules for a second. We have two folks who are

going to speak to the engineer's rules.

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JAMES McLAUGHLIN: Thank you, Madam Chairman.

I'm thoroughly chilled, but my voice is still working. I

do have some written comments.

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I'm James McLaughlin. I am associate counsel

for Kettering University. I'm also a PE. I'm also a

patent attorney. And I'm speaking about the, as we see

it, deficiency in the continuing education requirements

for people who are particularly in academia who did

research and are not civil engineers necessarily. I have

submitted to the good lady here some written suggestions

on augmenting the rules, particularly in continuing

education.

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What we do is research. What we do is high end

things. And the rules as proposed and is as existing

make it very difficult for us to appear to satisfy the

rules. But, of course, we're continually doing that kind

of thing. Again, I warmly encourage the passing of the

written materials on down the chain.

And I note that we had no inkling that we

should be here at 9:00 o'clock, no inkling at all. And

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I'm sorry to have interrupted the flow of things. These

good people out here have been so civil. This is the way

the constitution intended petitioning the government.

There's no flattery in that. Thank you kindly.

And next is our dean of engineering who wants

to tell you some more of the things that are not covered

by the present rules.

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CRAIG HOFF: Hi. I'm Dr. Craig Hoff, the Dean

of engineering at Kettering University, and I'm

representing 12 faculty members who are mechanical and

electrical engineers, and the issue is the requirements

for continuing education.

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While this is a really important thing and that

we need to have this done, the rules as they are written

right now doesn't really cover our particular

circumstance. So, as an automotive engineer I would want

to take classes through the Society of Automotive

Engineers. As the rule is written I couldn't do that for

continuing education credit. Instead, the offerings are

through professional engineering organizations which are

geared toward civil engineers. And I would just like to

broaden what those options are.

The other thought is as an engineering

researcher we are actually developing the knowledge

that's going to be passed down through future continuing

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education courses. Right now I'm working in the area of

connected and autonomous vehicles. So, cars are going to

be different. And you can't go take a class on this

stuff. But I'm working on writing the rules and writing

the education. And there ought to be a way to better get

recognized for that as staying current in the discipline.

So, with that, that's my comments. Thank you very much.

MS. DITSCHMAN: So, we're going back to

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counseling rules.

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KEITH MATTHEWS: My name is Keith Matthews.

K-E-I-T-H, M-A-T-T-H-E-W-S. I'm a licensed professional

counselor in Michigan. I have my own practice. I work

primarily with single parents and their families. And

with any war those in the military know you have to have

BOG, boots on ground, and that's what LPCs are. We're

the front line. Without intelligence you can't win a

war.

I have a student/client that I was informed

that threatened to kill a teacher. When I went to the

school and asked about it the teacher told me she was

told not to make waves. Now, I'm obligated to report it.

Once I reported it we had a school hearing. At that

school hearing seven different teachers had statements

that this young man threatened to shoot and kill them.

It was not reported. I had to report it to the board. I

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had to report it to the office. Without front line

soldiers, LPCs, the mental health war is lost.

ANTOINETTE MALLETT: Hello. My name is

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Antoinette Mallett, A-N-T-O-I-N-E-T-T-E, Mallett,

M-A-L-L-E-T-T.

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In looking at the regulatory impact statement

and cost benefit analysis form that was approved for us

to even get to this proposition hearing today there are a

few discrepancies that shouldn't have passed, that should

have been more closely reviewed. These include Question

Number 8, describe how the proposed rules protect the

health, safety and welfare of Michigan citizens while

promoting a regulatory environment in Michigan that is

the least burdensome alternative for those required to

comply. LARA's answer that the proposed rules supply a

regulatory mechanism for the practice of counseling. So,

to protect the health, safety and welfare of Michigan

citizens.

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And they also said that this is important to

the members of the profession to adhere to the education

and professional standards. However, all counselors in

the State of Michigan programs have a requirement of

classes that are already now listed and clarified in the

educational section of the new LARA changes. Therefore,

counselors are practicing within our scope of practice,

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including diagnosis, which is in all counseling programs

in the State of Michigan, as well as psychotherapy

techniques in which LARA is saying has been misread.

Also, the changes will negatively affect over

150,000, if not more, citizens who are directly receiving

these services through LPCs and which is within our scope

of practice, verbatim, our education. Our scope of

practice is based on what we are trained to do based on

our education.

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There has been already small business being

addressed, but I also want to address mainly Question 32

and 33, which is how the proposed rule will impact

business growth and job creation in Michigan, as well as

disproportionately affect the rules of the industrial

sector, segment of the public, business size, or

geographic location.

MS. DITSCHMAN: Time. Thank you.

JAMES HANSEN: Hi. My name is Dr. James

Hansen, H-A-N-S-E-N. I have a specialized perspective on

this issue that is informed by my relatively unique

professional. I'm a counselor and a psychologist.

Specifically, I'm a licensed professional counselor, a

fully licensed psychologist, have a Ph.D. in clinical

psychology, and have been working as a professor in the

department of counseling for nearly 25 years.

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My consistent observation throughout my career

has been that there is no difference between the ability

of counselors and psychologists to diagnose and implement

counseling techniques. In fact, in many cases I have

observed that counselors have superior abilities in these

areas. My observation should not be surprising given

that counselors receive extensive training in counseling

techniques and diagnosis.

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Furthermore, research has consistently

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demonstrated that there are no significant differences in

client outcomes as a function of professional discipline.

Therefore, there's no rational basis to change the

longstanding scope of practice for counselors.

Counselors diagnose and implement counseling techniques

at least as well as their colleagues in related fields

who have these privileges.

Like many others, I'm also concerned about the

devastating impact these changes would have on consumers

of mental health services. Counselors serve a large

portion of mental health clients in the State of

Michigan. Suicide rates are on the rise. Gun violence,

depression, anxiety, the opioid crisis, and substance

abuse are just a beginning list of the problems that

professional counselors work to alleviate on a daily

basis.

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Furthermore, counselors tend to help people

from lower socioeconomic groups who may not have the

means to access help from other professionals. If the

proposed changes were implemented counselors would be

forced to stop providing the services and abandon their

existing clients. It is difficult to overstate the harm

this would cause the consumers of mental health services

and the State of Michigan as a whole. Thank you.

SEBI FISHTA: Hello. My name is Sebi Fishta.

I am a licensed provisional counselor and a national

certified counselor. I work as a counselor in a

community mental health setting assisting people with

severe and persistent mental illness. Additionally, I

work in private practice. I supervise LPCs. I am a

special lecturer at Oakland University as well as Ph.D.

candidate.

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I thank you for this opportunity to speak here

with you in regard to the misguided new proposal to

change the rules for LPCs. The disappointing proposal

takes away the LPCs' and ultimately my abilities to

diagnose and provide psychotherapy techniques necessary

to serve the clients, essentially disabling me from

practice.

I work daily shoulder to shoulder with

psychiatrists, psychologists and social workers. At the

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community mental health where I work 38.5 percent of

clients are served by LPCs and LLPCs. This agency

actively serves about 6,000 clients.

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My clients suffer from schizophrenia, major

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depressive disorder, bipolar disorders, anxiety, eating

disorders, et cetera. A good portion of clients on my

caseload started services due to thoughts of suicide.

I will go to the end. Dear honorable members

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of this important licensing board, finally, I would like

to share with you my biggest dilemma. I don't even know

where and how to discharge all of my current clients. I

do not know how to explain to them what has happened.

And I can promise you this will be a total devastation to

their emotional and mental health recovery.

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My recommendation to you is that we can keep

what is successfully in place. This is definitely --

there is definitely no room for all of us mental health

professionals to co-exist because the demand of such

services is so great.

MS. DITSCHMAN: So, I just want to remind

everybody. Sorry. I have a new job here. I'm working

the timer. I just wanted to remind everybody that just

came in that when come up you need to state your name and

then spell it for her so that she can get it right in the

record. We are keeping a record of today.

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If you have written comments that you've

already submitted you don't need to submit them again.

If you want to submit written comments today and you

don't want to sit and wait to speak you can do that. You

can either do it on the card by putting your information

on the front and writing it on the back and dropping that

off up here, or you can just submit a letter with your

name on it, or you can wait to speak.

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How we're -- once the comment goes into the

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record we have that comment. If someone doesn't want to

wait to make the same comment again you don't have to do

that because once one comment is seen on that that

comment brings up that issue.

Just so that you know, we do work for LARA.

I've been asked multiple times. The director is not here

today. We are basically putting this into the record.

That's what we're here for today. So, if you see us busy

doing something else or doing the timer or not looking up

it's not that we're not paying attention. We don't have

to -- this is all going into the record. That's what we

review later. So, if you see us looking away it's not

that we're ignoring you for a few minutes. We're keeping

track of all the other stuff we need to do here.

You've been brought in, so that if you have

been in here since, before 10:10 you should be going

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first. After that we're going to direct you as to how we

go through the, how you get to get up and make a comment.

If you have a card you'll be able to give the card over

there to staff and then you can come over to make a

statement. Make sure you have all the details.

If you try to leave the room I believe that you

won't get back in. I think they're still doing that.

Stephanie? They can't leave the room, right, at this

point?

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STEPHANIE: I think it's fine. I think it's

fine. Keep track of your seat because we don't have more

people out there that we're letting in.

MS. DITSCHMAN: Okay. So, I can only answer

about logistics, not about the subject matter.

UNIDENTIFIED SPEAKER: So, when do the two

minutes start, when we say our names or after you type

that?

MS. DITSCHMAN: When you say your name is when

it begins. Yeah. And I'll let you know one minute and

I'll let you know please stop. So, we're trying to get

as many people. This does end at 5:00 o'clock today.

UNIDENTIFIED SPEAKER: So, this information

gets put on the record by you, and how is that

distributed? Do you get portions of it or do the rest of

the LARA read through all of these things?

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MS. DITSCHMAN: So, there's a procedure,

there's a rule-making procedure. I'm not going to go

through all that right now, but the record does include

everything that is spoken here today and all of the

written comments are a part of our records.

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UNIDENTIFIED SPEAKER: Who sees it?

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MS. DITSCHMAN: I'm not going to go through

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that today because you want to be able to speak. I don't

want to waste any more time. Some people have been here

since 8:00 o'clock. So, I'm going to keep going.

UNIDENTIFIED SPEAKER: Thank you.

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MS. DITSCHMAN: So, on with the information.

CHELSEA RUMOHR: Okay. Good afternoon. My

name is Chelsea Rumohr. It's C-H-E-L-S-E-A, R-U-M-O-H-R.

I want to thank you for the opportunity to speak today.

I am currently pursuing a Master's in mental

health counseling at a CACREP accredited institution. My

journey into the field of counseling started in 2015 when

I was diagnosed with postpartum depression after the

birth of my daughter and diagnosed with postpartum

anxiety after the birth of my son in 2016. I struggled

with fear, isolation and suicidal thoughts because I

didn't believe I was good enough for my husband or my

three children. My counselor saw through the fog of my

postpartum depression and anxiety and helped save my

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life. I was the one in five moms who suffer from

postpartum depression, and I was one of the 90 percent of

moms that suffer from postpartum anxiety.

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Suicide is the number one cause of death for

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moms in the first year after their baby is born, and I

almost joined that statistic. Because of my counselor my

husband has a happy and healthy wife, and my three

beautiful children, Gavin, Emory and Clair, have a happy

healthy mom. Because of my counselor I'm able to stand

in front of you today.

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Because of the impact my counselor had on me

I'm dedicating my life to help other moms struggling with

perinatal mood and anxiety disorder. We need our

licensed professional counselors.

These changes will not only have devastating

consequences for every licensed professional counselor,

but it will be catastrophic for every single individual

who is currently receiving support from a counselor.

These changes will have a horrific impact on our state in

ways I don't want to imagine. We need our licensed

professional counselors. Counselors save lives and I'm

living proof of that. Thank you.

CHERYL MERCHANT: Good afternoon. My name is

Dr. Cheryl Merchant, C-H-E-R-Y-L, M-E-R-C-H-A-N-T. I've

been practicing as an LPC approaching 20 years in the

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Southfield Lathrup communities in Oakland County, and I

am the originator of the wildly spread and signed

petition titled protect licensed mental, I'm sorry,

licensed professional counselors licensure, where as of

9:13 a.m. today, 45,700 supporters.

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I'm also a member of the Michigan Mental Health

Counselors Association. I have a Master's in counseling

and a Ph.D. in psychology. I supervise LPCs and I am a

full-time psychology professor at one of our Michigan

colleges.

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I'm speaking on behalf, first, of our clients,

of LLPCs and LPCs and all Michigan families. One of the

first ethical principles of health care in general and

mental health specifically is do no harm. So, my first

question for LARA's record is how do the clients of our

Michigan communities benefit from the expulsion and

unemployment of nearly 10,000 LPC mental health

providers? There is currently a deficit in mental health

providers and client waiting periods as long as three

months in many cases.

My second question for LARA's record is is

there a realization that the current unemployment rate in

Michigan as of August, 2019, BLS.gov, of 4.3 percent will

increase due to unemployment of LPCs. My final comment,

do no harm, LARA, to our clients.

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MS. DITSCHMAN: Your time is up.

CHERYL MERCHANT: Thank you.

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MICHELLE ZUKOWSKI-SERLIN: Okay. Good morning.

My name is Michelle Zukowski-Serlin, M-I-C-H-E-L-L-E,

z-U-K-O-W-S-K-I, S-E-R-L-I-N. And I am your first LMSW

to speak today. I'm the owner and co-founder of Choices

for Change Counseling Agency, which is 28 years old. And

I have ten therapists that work for my agency of all

levels, all professions, five being LPCs, and I train

LPCs. I'm also the president of the Psychotherapy

Consortium of Southwest Michigan.

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And I am here as a social worker, and I have

been one of the lead organizers in this because I am here

for my brothers and my sisters who are out there every

day working hard to help clients with trauma, to help

people have better and healthier lives. It is for 30

years the scope of practice has included diagnosis and

psychoanalytic techniques that, in fact, the scope is, of

practice for LPCs, is to do diagnosis.

More importantly, as LARA administrators you

have been charged with protecting our community. It is

never in the best interest of the community to force

10,000 people out of work. It is never in the best

interest of the community to have 150,000 plus clients be

left without their therapist.

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For my agency we specialize in trauma. The

sexual assault survivor who has entrusted her therapist

will wake up one day to know she's abandoned. The foster

care child who's been beaten and is alone reaches out to

their therapist who is no longer there.

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To go forward and change the LPC scope of

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practice is to do harm. There is a solution. House Bill

4325 addresses everyone's concerns with CEUs,

accreditation, and continues the status quo scope of

practice. Why not wait? Why not reach into your hearts

and do the right thing? This is just plain wrong. Thank

you.

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TROY ZUKOWSKI-SERLIN: It's always tough to

follow her. She's my wife. My name is Troy

Zukowski-Serlin, T-R-O-Y, Z-U-K-O-W-S-K-I, hyphen,

Serlin, S-E-R-L-I-N. I'm also an LMSW with over 30 years

of post Master's experience. And I work with a variety

of professionals, psychiatrists, psychologists, social

workers, paraprofessionals, parents, school teachers.

We're all in the same boat together here. We

all play crucial roles in the delivery of mental health.

Take them out of the equation and we'll have a huge

behavioral health crisis which will snowball into major

problems for individuals, families, communities, law

enforcement, and other first responders.

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Public safety would be at risk if an unelected

regulatory body decides to make such sweeping changes on

its own in a very short period of time. I'm telling you

that's not what you want. All the stakeholders here have

legitimate concerns. But we don't want a situation where

we end up with winners and losers and the legacy of

bitterness among professionals, because that could very

well be the result of this.

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Therefore, I highly recommend allowing House

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and Senate to complete legislation that incorporates all

these concerns. And I think the House bill has. The

State legislature is the branch of government closest to

the people and best able to see the big picture in

Michigan. The House has a very strong bill which

clarifies explicitly the language spelling out what the

different branches of the behavior health community can

do and cannot do. I highly recommend House Bill 4325 be

passed, sent to the Senate, reconciled, and then sent to

the governor for signature. And then LARA will assume

its roll as an enforcement body. Thank you.

CAROL TILLOTSON: I'm Carol Tillotson and I'm

an LPC. Tillotson, T-I-L-L-O-T-S-O-N, Carol, C-A-R-O-L.

I graduated at 61 years old with a Master's in counseling

degree, a 72-hour credit program. I've been educated

level and trained for the scope of practice. The

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equivalent level of coursework as a Master's degree

psychologist. And for 30 years you licensed us under the

current scope of practice.

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Currently I provide for a nonprofit

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organization, substance abuse counseling, for

approximately 300 male and female parolees annually in a

18-session, closed session program in a residential

re-entry program, and too many of them are opioid users.

The proposed changes will limit my ability as

an LPC to gain work, to bill government and private

insurance providers, affect my ability to obtain

liability insurance, and the risk of violating APA codes.

It will also cause me hardship to pay back my student

loan, 28,000, doubled because of the 6.9 percent FAFSA

interest rate, and $250 LARA licensure fees, 3,650

supervision costs, 1,040 professional liability

insurance. That's a total of 60,000, 61,000 financial

investment, with 10,000, 11,000 hours of time investment,

supervision, practicum internships.

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And so, what I'm asking you today is to

reconsider restricting our scope of practice and wait for

the House Bill 4325 to pass, at minimum have a

grandfather clause.

TAMERA LAGALO: Good afternoon. My name is

Tamera Lagalo, T-A-M-E-R-A, L-A-G-A-L-O. I'm pleading

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with you as a resident of Michigan, a small business

owner, a survivor of domestic and sexual assault, and a

mental health advocate for the State of Michigan.

I'm the founder of The Support Group, a mental

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health billing company that serves providers locally and

nationally, along with being the owner of Spring Forest

Counseling in Okemos. My private practice is comprised

of both LPCs, LMSWs, and a Ph.D. In just two years we've

grown from a one-room suite to a brand new 12-room space

and a satellite office in Holt, Michigan.

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This growth was fueled by the dedication of all

our clinicians. However, our licensed professional

counselors treat approximately 51.9 percent of the

clients served and contribute over 56.9 percent of the

practice operating income. We currently serve 493

clients in our practice.

Without the financial contribution of the LPCs

at our practice I would be forced to default on a

seven-year lease, putting myself $279,000 in debt

overnight. The impact would not only be destructive to

10,000 LPCs whose careers would end, leaving 200,000 plus

clients without a provider. Many of these LPCs are small

businesses. The small businesses pay taxes. The State

of Michigan stands to lose $38 million in revenue from

LPCs. LARA, you stand to lose $1.2 million a year if

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LPCs don't renew their licenses. Billing agencies like

mine will lose thousands of dollars a year if LPCs are no

longer able to bill insurance.

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If we lose our licensed professional counselors

ability to treat and diagnose, their ability to bill

insurance, where will you turn in a time of need? How

easily will you find care for your spouse, your child, or

your loved one. If we take 10,000 clinicians out of a

game that is already in triple overtime there's no chance

our state or future will win.

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SARAH BRABBS: Hi. My maim is Sarah Brabbs,

S-A-R-A-H, B-R-A-B-B-S. I'm not a mental health worker,

but I am a professional speaker and I'm an author, and I

am directly connected all the time to mental health

workers in what I do. I wrote a book about assholes.

So, I didn't know if I swear, but that's okay. Anyway, I

don't think anybody here blames any of you specifically

for this, so we appreciate you listening to all of our

concerns.

I mostly am concerned -- I live in a rural

community in southeast Michigan. I see a lot of people

that are impacted all the time by LPCs. When I first

heard about this I thought that it couldn't be true. I

also teach at a college, and I have always told my

students if something this early makes you angry, raging

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or scared it's likely not true. But that was not the

case with this. And I think it's extremely

short-sighted. I.

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Think LARA will end up with egg on their face

at the least, and a huge amount of money and potentially

lawsuits at the most, including the deaths of many

people, as many people have said. So, I think you've

heard lots of stories. You would probably not disagree

with that at this point, if I had to guess. But it would

be really, really appreciated if you would slow things

down and give this a lot more thought, have a lot more

communication around it. It's not a simple issue.

I think, LARA, you are part of the problem, and

so, you fixing it in this way to me is like putting a

criminal in charge of a crime scene. I know that's not

what you mean to do, but that's how it comes across. And

your legacy is going to change if you do this. Thank

you.

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COTRENA CHAMBLISS: Hi. My name is Cootrana

Chambliss. I'll spell it. C-O-T-R-E-N-A, and the last

name is Chambliss, C-H-A-M-B-L-I-S-S. And I am here

today to speak on behalf of counselors like myself. I

support the HB4325 bill passing.

As counselors we serve the clients of the

community and we need to continue practicing and

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providing mental health therapy to clients. Counselors

in mental health have been providing services to women,

men, children and families for many years. Clients are

in treatment right now as we speak and will be affected

with treatment and many clients are at critical, critical

stages of change in their lives. Counselors are in the

middle of diagnosing and providing treatment with

clients, and they need the support, the clients need the

support of the therapist. This change would put

counselors in a situation of not being able to provide

clinical and ethical services to the mental health field.

Thank you.

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HENRY D. WILLIAMS, JR.: My name is -- well,

first of all, I want to thank you for the invitation to

be here. Can you hear me? Now you can. It's an honor

to be here today. And I want to thank this audience and

you, too, for being here and allowing us to have our

voices.

COURT REPORTER: Name?

HENRY D. WILLIAMS, JR.: I'm sorry. Some call

me Rev, but you can call me anything you like, but don't

call me late for dinner.

Henry D. Williams, Jr. is my name. But I also

want to thank two individuals, Napolean Harrington and

Dr. Katherine James for always being in the forefront to

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face the challenges that can impact the livelihood of

counselors past and present.

There's three points I wanted to share with

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you. First, included in this repeal is a practice of

counseling techniques and the related ability to diagnose

and identify the problem. Without these and numerous

other definitions the counseling scope of practice is

several limited.

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Secondly, these changes in scope will put

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Michigan's LPCs and LLPCs and our supervisors in

violation of the American Counselor Association Code of

Ethics; E5, a proper diagnosis. Additionally, insurance

companies will likely stop reimbursing for the services

of LPCs due to the significant limits, the scopes those

rule changes would impose.

Thirdly, the deeper impact is the clients who

have entrusted in me over time as a counselor. I have

been prepared for this journey to walk with them. I

earned two similar degrees, a Master's degree in pastoral

counseling, a Master in theological seminary, and a

Master's of divinity from Garrett Evangelical Theological

Seminary in theology and ethics.

Finally, my colleagues are clinically trained

and spiritually adept --

MS. DITSCHMAN: Your time's up.

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HENRY D. WILLIAMS, JR.: -- which them as LPCs

and LLPCs to give diagnoses for treatment in a

spiritual --

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JON RITZ: Good afternoon. My name is Dr. Jon

Ritz, J-O-N, R-I-T-Z. I am currently a student in the

Master's of Arts in counseling program at Spring Arbor

University. I am also on the faculty at Michigan State

in a different field and serve as an advisor to

undergraduate students.

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I've been teaching at the college level for 20

years, and in that time I worked closely with college

students and have seen firsthand the impacts of mental

health issues on this population. A few years ago I

decided to pursue training as a therapist so I might have

some positive impact outside of the classroom.

I researched both the MSW and MAC degrees

thoroughly and came to the conclusion that earning a

Master's of Arts in mental health counseling en route to

become an LPC was the best fit for me primarily due to

the number of courses on counseling theory,

psychopathology, diagnosis, case conceptualization and

treatment I would have an opportunity to take.

This is actually my third graduate degree,

including a Ph.D., and many ways it has been the most

rigorous. I'm now doing my clinical intern year at

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Michigan State's counseling center. There I'm working

with real clients doing diagnosis and treatment under the

supervision of experienced clinicians from our full-time

staff, which includes five LPCs and LLPCs. At the end of

our internships my classmates and I will have 700 hours

of clinical experience. We will complete another 3,000

hours and pass a national exam to earn full licensure as

LPCs.

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If LARA's proposed changes go through my

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classmates and I will not be able to practice or use our

degrees in Michigan for all intents and purposes. I

respectfully ask LARA to delay their proposed changes

until a legislative remedy has been achieved, an outcome

I truly believe is in the best interest of everyone in

our state. Thank you.

BRAD PRZYSTAS: Hi. Thank you for allowing me

to speak today. My name is Brad Przystas, B-R-A-D,

P-R-Z-Y-S-T-A-S. I am not here today as a LPC but has a

husband and father. I'm here to advocate for my wife

Christine Zouaoui who is an LPC, our family, and the

tens, the 10,000 other LPCs, their families and their

clients whose careers, way of life and mental health

well-being are in jeopardy. I'm here to express my

strong opposition to LARA's rule changes for their scope

of practice and that you give House Bill 4325 a chance to

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pass.

The proposed changes from LARA would repeal

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nearly the entire scope of practice for LPCs in the State

of Michigan which has been operating under the current

scope of practice for the last 30 years. If these

changes go through it will completely eliminate my wife's

career here in the State of Michigan. My wife has worked

in private practice as a LPC and as a mental health

specialist with Lansing School District for over 17 years

and is specialized in trauma.

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I am a stay-at-home dad who takes care of the

kids in the house and dealing with a child who has an

autoimmune disorder. If these proposed changes are

adopted my wife and other LPCs will not be able to

diagnose or administer therapy to help other people, such

as myself, who use LPCs for their own mental health.

These changes will also make it so LPCs will

not be reimbursed by insurance companies, which is how my

wife provides for our family. If these proposed rule

changes are enacted thousands of LPCs in the state,

including my wife, will be at risk of losing their jobs.

By allowing these changes you are essentially evicting

10,000 residents from the State of Michigan so they can

go do their jobs that they have been doing, been trained

to do, have been educated to do, are licensed to do, and

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have a code of ethics they follow to provide essential

mental health to residents of the State of Michigan but

will now have to practice in different states. Thank

you. Please support House Bill 4325.

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MICHELE FIGUEREO: Hi. My name is Michele

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Figuereo. M-I-C-H-E-L-E, F-I-G-U-E-R-E-O. I'm an LPC

from Grand Rapids, Michigan. I have clients who have

histories of trauma, and I'm trained in EMDR, eye

movement desensitization and reprocessing therapy. Over

one-third of EMDR therapists in Grand Rapids hold LPC

licensure. I work with veterans, first responders, and

women with past sexual abuse as they attempt to heal.

These are individuals who have experienced traumatic

events through service to our country, the general

public, or as a child, and are struggling to function and

live normal lives. Several individuals travel over

40 miles to see me as they either do not have a provider

who specializes in trauma in their area or because other

practitioners are unable to accept new clients. This

population as an elevated risk for self-harm and suicide

attempts due to the horrific traumas they have endured.

I shutter to think what will happen to my

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clients and hundreds of thousands of others should their

counselors be forced to abandon them. For many this will

be a continuation of longstanding pattern of abandonment

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and will compound their trauma. I can say with

completely honesty that I will fear for the safety of

several of my clients' lives. We know that

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discontinuation of mental health services on this

astronomical scale will lead to increased suicides

throughout the state. The statistics speak for

themselves. And yet, these are just figures.

You don't know the faces, the stories and the

true picture of what this will look like the same way we

do. To briefly illustrate with a true story, a small

school district in Kent County reduced the number of

counselors to address students' mental health needs.

Within a couple years of this removal their district saw

a increase in suicide attempts and completed suicides

amongst the middle and high school students. It was not

until a seventh-grader, Kyle, hung himself from a tree

behind the middle school that they admit that their

decision had led to the devastating effects for their

community due to lack of access to mental health care.

I use this to illustrate on a very small scale

the reality of what removing these life-saving services

will look like. But the good news is you can prevent

these needless tragedies. You can allow House Bill 4325

to pass.

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MS. DITSCHMAN: Your time is up.

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ALEX BALENGER: Hello. My name is Alex

Balenger. That's A-L-E-X, B-E-L-A-N-G-E-R. And I'm a

counseling student at the University of Detroit Mercy,

and I have received extensive training in assessment,

diagnosis and treatment as part of my coursework.

These rule changes would render counselors

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unable to do the very things they're trained to do, and

it would make me unable to legally utilize my thorough,

lengthy and expensive education. Coursework in my

program include mental health diagnosis and treatment,

testing and evaluation, advanced issues and assessment,

and treatment, as well as counseling skills.

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So, I am urging you not to pass the proposed

rule changes on counselors, instead HB4325 as it

addresses the scope of practice without the negative

ramifications.

Additionally, I question why the Michigan

Psychological Association is opposed to HB4325. Are they

not ostensibly dedicated to helping others? Ostensibly

dedicated to helping why would they want something, why

would they support something that's going to hurt people

by decreasing the availability of mental health services.

So, actually, the most famous psychologist in

history probably best describes this as Narcissism of

small differences, and that is the tendency for

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communities with adjoining territories to engage in feuds

and ridicule because of hypersensitivity to details of

differentiation.

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So, you know, the negative impact of these rule

changes has already been eloquently expressed by many

people, so I'm not going to rehash that. I'm just going

to end it there and I'll say thank you for your time.

SHELLY WIGGINS: Good afternoon. My name is

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Shelly Wiggins. Thank you to LARA for allowing us to

share the facts of our stories for this is at the heart

of our work. The skill of reflective listening is

happening here today in this room. This is allowing all

the LPCs here to decompress from the fear of being deemed

incompetent to diagnose and treat in our specialty areas.

Many of us here today have diagnosed and

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implemented mental health treatment throughout the State

of Michigan for 25 years. Myself and other LPCs have had

the pleasure of serving children's residential treatment

programs, counseling agencies, private practices, all in

the capacity of a licensed professional counselor.

I currently serve in the educational system and

have had a private practice for ten years. There is a

huge gap between education and mental health, but that

gap is being bridged by LPCs that work within the

schools. The suicide stats have already been stated. If

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LARA makes changes in the rules and the House Bill 4325

bill does not pass I ask who will reach the children and

the teenagers who are either suicidal or have lost a

loved one in this manner? I implore the governor please

sign Bill 4325. And I stand to celebrate all the lives

that have been saved because of the professional caring

hearts of those who are LPCs.

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I also pause reverently remembering those who

are no longer with us because they had no one to talk to

at the critical moment. Semicolon. An old proverb says

there is wisdom and a multitude of counselors. And the

turnout today speaks for itself.

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My name is Shelly Wiggins, S-H-E-L-L-Y,

W-I-G-G-I-N-S.

AMBER JAMES: My name is Amber James,

A-M-B-E-R, J-A-M-E-S. I'm the president-elect and

legislative chair for Michigan Association of Art

Therapy. We have opposed the proposed rule changes from

LARA and we support House Bill 4325.

I'm not an LPC. I hold a Master of Science

degree in art therapy and am a Board certified art

therapist. I'm here today to urge you to reconsider the

regulatory impact statement before making a decision on

the proposed rule changes affecting the scope of practice

for LPCs. The RAS does not reflect the impact, the true

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impact that these rule changes will have. It doesn't

reflect the impact the rules change will have on the art

therapists and the services we provide.

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Art therapy is a unique mental health

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profession that uses the processes in art-making to reach

individuals who do not have yet have the words to express

what they are feeling. Our therapists work with kids in

the foster care system, those battling substance abuse,

veterans experiencing PTSD, and those who are mentally

ill, just to name a few.

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Art therapy is not yet a licensed profession in

Michigan. For this reason many art therapists have taken

on the significant in burden of completing a second

Master's degree to become an LPC, despite a significant

overlap in coursework and requirements and a ridiculous

amount of student loans.

It is worth noting that I literally sat next to

both clinical psychology students and mental health

counseling students in my classes for my art therapy

degree, specifically on the classes for diagnosis,

psychopathology and assessments. We are all in the exact

same classes.

Many of my colleagues chose to repeat classes

in counseling theories and techniques to meet CACREP

standards in order to obtain a license. And now you're

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proposing to take the credibility of that license away.

The art therapists who are not licensed in

another field are already in the position you are

proposing to put 10,000 more professionals in. Many of

us work multiple jobs, are in a grant-funded positions,

or take positions for which we are overqualified while we

watch in agony as clients who would benefit from our

services go without.

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NANCY CURTIS: Good afternoon. Thanks for this

will opportunity to speak today. My name is Nancy

Curtis, and I'm a licensed professional counselor, a

licensed marriage and family therapist, and a certified

advanced alcohol and drug counselor. I live in Hastings,

Michigan, which is the county seat of Barry County. We

have 7500 residents in Hastings.

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And I work for Pinerest Christian Mental Health

Services as a marriage and family therapist. I also

provide substance use disorder treatment in my clinic.

Hastings is one of Pinerest's several outpatient clinics,

and we currently have six therapists in our clinic. It's

a small clinic. We've grown from three therapists three

years ago, when I started working at Hastings, to six

therapists, and that's due to the increasing demand for

mental health and substance use services in our area.

This is a small rural community and we serve

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people who are Court ordered. Many of my clients are

Court ordered to do substance abuse treatment. And if

this bill, if these proposed changes are passed we're

going to have a huge impact in our community. Three of

the therapists in my office are LPCs, so our staff will

be cut in half immediately, which will reduce the amount

of services that we can provide in our community.

Our community has recently seen an increase in

methamphetamine and opioid use, so they need substance

use services. I'm the only person in my office who can

provide those services. And those services will be

greatly minimized if we're eliminated from the

profession.

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MS. DITSCHMAN: You're time's up.

NANCY CURTIS: Thank you.

MICHAEL JOY: Good afternoon to members of

LARA. Thank for having us speak today. My name is

Michael Joy, M-I-C-H-A-E-L, last name is spelled J-O-Y.

I am the president of the Michigan Counseling

Association, but more importantly, I'm a licensed

professional counselor. And we are here today basically

to not have a fight, but just to have a discussion how

much common ground we all really have in this room.

Because the common ground that we all have is that we

know that licensed professional counselors do great work.

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And why we do great work is in the proof. It's in the

proof because we all know that we take rigorous courses

accredited, ultimately, by CACREP, that we get trained in

the various areas of the scope of practice that you guys

are potentially going to eliminate such as diagnosing and

counseling techniques.

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I'm not going to bore you with the details that

have already been discussed today, but just to highlight

a few facts. Up to 10,000 professional counselors may

loose their jobs and also harm 50,000, and millions and

millions of economic impact will be filled. And it all

comes at a time when suicide rates are going up.

And I just want to let you guys know that it's

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been great to work for the last 30 years as licensed

professional counselors. It's been quite a journey. I

mean think of all the things we've been able to do

because of this rule being in place. We've been able to

save millions of lives. We've been able to help a bunch

of people who have come to treatment that maybe

considered it for years but never took that step.

We all play for the same team, we all care

about the care of our clients, and we want to keep this

going moving forward. We respect the need for you guys

to update the rules and do your jobs. We just ask that

you respect the ability to do our jobs as well.

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And what I want to say is this. Think about

the human impact that this is going to make. And when I

say human impact I'm not just talking about statistics,

but I'm also talking about the abandonment and the

emotional devastation people will experience. So, all I

ask is that you hold off on doing any sort of, you know,

these sort of rules that could really affect our ability

to do what we do and that you support HB4325 in the

process. Thank you.

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ALANA NICOLAZZO: Hello. Thank you so much for

having us this morning, especially you, Miss Court

Reporter, who's been tirelessly working away. My name is

Alana Nicolazzo, A-L-A-N-A, last N-I-C-O-L-A-Z-Z-O.

I would first like to take a minute to thank

all of the LPCs, LLPCs, psychologists, social workers who

have come out not only support on this day but how we've

come together as a profession. Every single one of you

should be proud of yourselves.

We are at the very front line in the trenches

with the EMTs, with the doctors, with the hospitals, with

the psychologists and psychiatrists. Our degrees, our

licensures, our profession should not be taken lightly.

And I don't think anybody in this room or anybody who's

waiting outside to get in to testify will disagree with

that.

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I have been trained in multiple areas, like

everybody else in this room. I graduated from Oakland

University under some phenomenal professors, some of

which you have heard today speak. It is important to

note that Michigan is second from the bottom in this

country of services for mental health. It is really

important that LARA take their time to not have premature

and disruptive changes in this pending legislation that

would render such rules obsolete for us to practice.

We are qualified, as you heard, and I just want

to say how proud I am of everybody for standing up to a

potential law change that was clearly written by somebody

who does not understand our education practices and our

ethics that we follow on a day-to-day basis. So, thank

you, LARA, for your time, thank you everybody in this

room. You all should be proud of yourself no matter how

this ends.

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CHRISTINA POLK: Good afternoon. My name is

Christina Polk, C-H-R-I-S-T-I-N-A, P-O-L-K. I'm a

licensed professional counselor here in Michigan. I'm an

Oakland County University alumnus, a CACREP accredited

program for counselors. I'm the clinical director of

resources for an organization called New Oakland Family

Centers. I currently supervise close to 50 LPC and LLPC

interns. I have nine years of experience in this field

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with specific emphasis and training in crisis and trauma.

Professional counselors make up a solid 50 percent of our

staff and 30 percent of our leadership.

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I'm here to vehemently oppose the licensing

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board's proposed rules changes for counselors' scope of

practice. I understand the statute and rules for

counselors in Michigan are outdated and the language

needs adjusting. However, the answer is not to limit the

services we've been providing to consumers for 30 years.

It is not us, as counselors, who need updating. Our

rigorous training in theories, multicultural issues,

testing and assessment, the diagnostic manual, group and

individual therapy, research and statistics, and our

experience in practicum, internship, and 3,000 additional

hours post grad meet 2019's needs for the mental health

crisis in the State of Michigan.

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The waitlist and needs for these consumers are

already overwhelming us. Cutting resources and

clinicians from an overburdened system is not a good

idea. LARA's responsibility is to protect the people of

this state, and this is not the answer.

The immeasurable impact this would have on our

state colleges universities congress running counseling

programs would be absolutely devastating. It would be

calamitous to small businesses. And the list of loss

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goes on and on.

Again, the effects of this rash decision go far

beyond the language in the statute. The job loss and

financial effects on our state would be astronomical.

The psychologists who support these changes,

respectfully, have very little understanding of our

curriculum and scope as evidenced by comments made in

recent hearings and in their newsletter.

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I urge everyone in this room with any

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legislative power to turn your attention to the passing

of House Bill 4325. I urge you to look at me and the

many other counselors in this room. I certainly hope

that we never have to meet any of you under the

circumstance that you or your loved one is dealing with a

mental health crisis, but the statistics tell us that

this is likely.

MS. DITSCHMAN: Your time is up.

ELIZABETH TEKLINSKI: My name is Dr. Elizabeth

Teklinski. I'm a Ph.D., an LPC. T-E-K-L-I-N-S-K-I. I

am a spiritual care advisor and I'm a professional

counselor working in palliative medicine in hospice in

northern Michigan based out of Traverse City.

Every day the very best medical specialists,

physicians, psychologists, nurses, social workers, nurse

practitioners, physician assistants, and others refer

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patients to my services. I often hear that my services

for people losing hope are, quote, better than any other

kind of medicine there is.

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I'm here to share a personal story that informs

my professional mission and work as an LPC. Twenty years

ago when my daughter was born in rural northern Michigan

with a life-threatening congenital disorder she was

removed from my arms, given platelet transfusions,

air-lifted to University of Michigan Mott Children's

Hospital. There she was admitted to the most serious

neonatal intensive unit. I was told by a rather cold and

dismissive neonatologist that she would die. Quote,

sometimes babies just don't come home.

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She was fed formula through a feeding tube

while I saved breast milk. She was intubated and placed

on a respirator. I was not allowed to touch her too

much. I was utterly alone, I believed, without hope. My

grandmother recommended that I pray.

A miracle happened. She survived and lived

well beyond the 25 percent chance of a one-year life

expectancy. She just celebrated her 20th birthday.

Today I'm fortunate to work as part of a highly

skilled and trained interdisciplinary team who is led by

the only two Board certified, fellowship trained

palliative medicine physicians north of Grand Rapids.

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Our medical director, Dr. Roman Barraza, M.D. and Mayo

Clinic trained Ph.D., created my position to integrate

spiritual, existential-filled life support care to all,

to patients in northern Michigan facing life-limiting

terminal illnesses. I am brought bedside to patients in

the hospital as soon as the medical treatment is deemed

limited in cure. We treat when hospice founder, Dr.

Cicely Saunders --

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MS. DITSCHMAN: Your time is up.

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CYNTHIA GRIMMER: Greetings. My name is

Cynthia Grimmer. That's spelled G-R-I-M-M-E-R. I'm here

representing abused children, the most vulnerable

underneath these proposed changes.

I have a message for the governor. We know how

the Flint water crisis went. Please don't let it be the

mental health crisis on your watch. I have a message for

LARA. Please don't bar treatment for even one child, not

even one abused child.

I am an LPC. I'm a survivor of severe sexual,

physical and emotional child abuse. And I also have

clients who are severely abused. The turmoil and the

train wreck that happens as a result of abuse is huge.

The anguish that comes back and comes back and comes back

cannot be explained. Please don't bar help for them.

Abuse looks like this. My father pushed me

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into the ground to kick my knee that just had surgery 24

hours earlier when I was 16 years old. Why? Because I

didn't put the paper away. What was the real reason?

Because he was mentally ill and did not have access to

the LPCs that I have access to. These LPCs gave me new

hope and future.

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I am an occupational therapist. I also am a

founder of an institution that serves 138 families with

academic services per week. Why? Because of the help I

received from LPCs that stopped the mental illness from

going any further. I'm also a mom with three successful

children.

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A child I'm working with currently was

punctured by -- this is HIPAA compliant --

MS. DITSCHMAN: Time's up.

STEPHEN BARDZILOWSKI: Hi. My name is Stephen

Bardzilowski, and I'll spell that. It is S-T-E-P-H-E-N,

B-A-R-D-Z-I-L-O-W-S-K-I. I'm employed -- yeah, that's

right. I'm employed by Rainbow Rehabilitation Center

that treats traumatic brain injury. I'm a Master level

counsel for the past 30 years.

And he just want to get to the point I oppose

the changes made by LARA, it must not be adopted, and I

support House Bill 4325. And I just want to say, I mean

this respectfully, I found this out, the changes of

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losing license, a couple of days ago just by a co-worker,

and I just wanted to say that it would be like -- I'm a

first responder, along with my other comrades here, but

first responders for major issues, mental health crisis.

And the analogy would be if I'm an EMT driver and they

said you don't have a license, so we can't practice. So,

I mean that respectfully, but I look at that as a need to

help people in need and in crisis, and it's also a public

health safety issue, and to those also impacted directly

by mental health issues within the families.

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So, I strongly support the Bill 4325 and the

needs to help with people with mental illness. Thank you

very much for your time and I appreciate it.

ANGELA HALLISY: Hello. My name is Angela

Hallisey, A-N-G-E-L-A, H-A-L-L-I-S-Y. I am a graduate of

Central Michigan University. We have been trained and

supervised in application of all of our therapy skills as

well as our diagnostic skills before we are ever allowed

to receive our license.

I am representing River Trail Counseling

Associates where we see adoptive and foster care kids and

families deal with trauma, mood disorders and other

issues. Our clients come from the areas of Monroe

through Flint to our office in Auburn Hills due to the

level of need and our level of expertise. With this

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population there are a few options for care. They have

been left by life family and peers.

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Removing our LPC therapists will compound their

abandonment and trauma. The work we do with these

families, reducing violence in the home and preventing

violence in the schools. We address the underlying

trauma while supporting the family to improve their

skills as well.

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I ask that LARA stop the implementation of the

rule change to allow time for HB4325 to pass. If the

rule change goes into effect the children that we see in

treatment will be once again abandoned and traumatized,

this time at the hands of our own government.

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I also work for a company called Wright

Behavioral Consultants. We work with traumatic brain

injury clients. These clients have already been put in a

place of stress because of the changes to auto no-fault.

They are facing removal of essential services in the next

year. We had hope that we could help them through this

transition. Our entire company is employed by LPCs and

LLPCs. Our employer is Dr. White. She has a Ph.D. in

counseling and an LLP. She employed LPCs because every

time what she's looking for for these brain injured

clients she sees more often than what we receive in our

training in therapy. We already are fighting, all the

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language insurance --

MS. DITSCHMAN: Your time is up.

THE WITNESS: Thank you.

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LaNEISHA MURPHY: LaNeisha Murphy, L-A, capital

N-E-I-S-H-A, M-U-R-P-H-Y. Thank for your time. Licensed

professional counselors are uniquely trained and

qualified to accurately perform what their title

exemplifies, the work of counseling. By passing these

new rules LARA will be violating the Public Health Code

of Michigan, specifically Act 368 of 1978, Sections

333.18101, and 333.18214, Section 5, by prohibiting the

use of counseling principles, methods or procedures and

counseling techniques, the former of which is a clinical

term that includes both diagnosis and counseling

techniques/psychotherapy.

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In my graduate program from Capella University,

which is CACREP accredited, I took two courses that

specifically focused on diagnosis of mental illness, one

course on assessments, and five separate courses on

counseling techniques.

Today I oversee 60 to 75 home-based children

and adolescent family cases as a supervisor at one of the

largest non-CMH mental health providers in Oakland

County. In this position I carry a caseload of three to

ten cases because there's a dearth of mental health

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clinicians in my county, in addition to my supervisory

duties. I oversee the supervision of counselors, social

workers, and psychologists. I'm in private practice

carrying a caseload of 15. I'm an approved clinical

supervisor, earning a national credential, which means I

can supervise LPCs.

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What you are doing today will devastate this

state. I am just one person. Over my short tenure of

seven years I have had the privilege to serve over 100

different families using psychopathological therapy and

family therapy.

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Hundreds of Michigan children and adolescents

will be put directly at risk. Think of the child that

will be not served by a licensed professional counselor

whose training helped them divulge the abuse and neglect

that was going on in their home. Think of the young

adult that no longer --

MS. DITSCHMAN: Your time is up.

LaNEISHA MURPHY: -- has their licensed

professional counselor when the urges to cut resurface.

Think of the young adolescent who did not have his

licensed professional counselor to talk to and decided to

take matters into his own hands against a school full of

bullies. Think of what you're doing to this state.

ANNE PARPAS: My name is Anne Parpas, A-N-N-E,

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P-A-R-P-A-S. I have been an RN for over 20 years, as

well as an LPC for six years which I integrated into my

practice. I'm also a LLPC supervisor with the State of

Michigan. I'm the owner and one of the therapists of

Integrated Health Consultants in Wyoming, Michigan, a

multidisciplinary private practice that I started six

years ago.

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I have a team of clinicians ranging from LLPC,

LPC, LMFT, LLP, PsyD and psychologists for the purpose of

collaboration, consultation, and integrative care to

bridge the gap between medical and behavioral health. We

treat couples, veterans, all presenting mental health

issues, infants, parents, adolescents. We get weekly

referrals from Metro Health, Spectrum Health, Mercy

Health providers, psychiatrists, as well as throughout

our local schools, organizations, businesses and

community members.

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We currently have 22 clinicians, 10 of them

being LPCs. We see 350 to 400 clients a day. We

currently have 848 active clients and average 106 new

clients per month.

I'm an independently credentialed licensed

professional counselor with 18 insurance company and

EAPs, which is important to me so that they can have

access for care for the community. In order to

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participate with insurance companies an LPC must have and

maintain and meet qualification standards. A provider,

exercising prudent clinical judgment, would provide to a

patient for the purpose of preventing evaluating,

diagnosing and treating symptoms.

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I would be in breach if the LARA changes are

put into place. If these changes are made by LARA half

of our practice would not be able to treat clients,

forcing us to abandoned hundreds of clients, which is

unethical, illegal and criminal.

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It would create a devastating loss of a team of

half of our team of practitioners, loss of wages, loss of

clinicians that provide quality evidenced-based

treatment, significantly decrease the support and

collaboration that we have with our referral sources,

leaving them to deal with the ramifications of patients'

loss of their amental health provider, which would

further increase the gaps and barriers to mental health

treatment --

MS. DITSCHMAN: Your time is up.

ANNE PARPAS: -- and substance abuse treatment.

Please, I strongly oppose LARA changes and House

Bill 4325 to move forward. Thank you.

PETER CAPPON: Thank you for the platform for

my peers and for me to voice our concerns today. I'm

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here because I have some unfortunate news and I have some

good news.

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My name is Peter Cappon, and I have been an

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LLPC in Michigan for about 16 months. Before that time I

spent a little under three years of full-time graduate

level counseling education pursuing not just one, but

actually my second entire Master's degree in the field of

counseling. You see, in Michigan, Michigan does not make

it particularly easy to become a professional licensed

counselor. In fact, it is quite the opposite.

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I received my first Master's degree in

counseling in another state, and upon moving back to my

home state it was made clear that my first degree would

not get me the licensure I was pursuing. There are many

people who have graduated from that first program who

currently work in that very state, as well as countless

other states across the country. However, I, along

with -- I'm going to have to jump forward here.

I think my point is basically this. We have

high standards. You can do the research. You can look

for yourselves. But we actually make it quite difficult,

and compared to the rest of the country even. We are

competent, highly trained counselors and we are held to

high standards. I ask that you please push back at least

the rule changes you're talking about. Give us a chance

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to move House Bill 4325 with no amendments as quickly as

possible so that we can continue to take care of people

in this state. Thank you.

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(Short recess had from 1:59 PM to 2:11 PM.)

KIMBERLY STAGG: Hi. My name is Kimberly

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Stagg, K-I-M-B-E-R-L-Y, S-T-A-G-G. And I'm not an LPC.

I'm an advocate, a friend and a client. If LARA's

proposed rule changes go into effect I will be one of the

hundreds of thousands in Michigan who will lose a

therapist.

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Let me tell you about my therapist. She's the

first person I've been completely real with. I have no

secrets from her, and her treatment of me has never

wavered. This level of trust is not common in my life.

She accurately and effectively diagnosed and worked with

me when, due to a change in medication by my

psychiatrist, I became suicidal. She gave me the

language I needed to explain what I was feeling. She did

not placate me, nor did she blow off my concerns and

fears.

She was all in during my sessions and

encouraged specific behaviors and homework to work

through the overwhelming mental battles I was

experiencing. She followed up weekly and even had me

come in for an extra session a couple times. She didn't

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let it go until she trusted I was all right. It was the

first time I had felt safe and supported in such an

honest way free of judgment.

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Months later, back to work and successfully

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living my life, I still use the tools she taught me. I

remember the conversations we had. I've rebuilt myself

based on what I learned from her. Yeah, my therapist is

amazing, but that's actually not my point.

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So many people in Michigan have a counselor

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that has changed or saved their life. So many don't.

The LPCs opposing the proposed definition changes are

passionate about helping their clients. They are the

ones that provide the tools, acceptance and support to

help us walk through life successfully.

Throughout this hearing you've heard many

arguments against LARA's suggested rule changes; the cost

to Michigan, the unemployment of thousands of therapists,

and more. Don't forget, though, your decision affects

the lives of clients like me every day. Save a life.

Keep Michigan's LPCs in practice and stop the proposed

rule changes. Thank you.

MICHELLE BRENNAN: Hello. My name is Michelle

Brennan, M-I-C-H-E-L-L-E, B-R-E-N-N-A-N. I'm a

registered nurse and an advocate for increased access to

mental health services in Michigan. In my line of work

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with the elderly population I witness firsthand the

direct natural mental impact on patient outcomes when

mental health is not addressed as part of a holistic

treatment plan. Untreated mental health issues have the

tendency to develop into physical health issues.

Significant mental health issues are on the

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rise, and as a health care provider I can confidently

state that a lack of access to mental health services

greatly increases the risk that patients will revert to

self-harming behaviors, including self-medicating,

suicide attempts, and engaging in abusive acts towards

themselves and others. Our community, at large, is

already in a disparity of the mental health services, and

with a population of people over the age of 65

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anticipated to be a majority by 2030 any changes to

LARA's regulations to reduce the number of qualified LPCs

is sure to have not only immediate but also long-term

effects on positive patient outcomes.

As access to affordable health care declines

more seniors revert to suicide as they can see no other

option at a future. With appropriate intervention these

narratives have a potential for positive outcomes. We

cannot afford insurmountable costs associated with

ongoing and repetitive hospitalizations that occur as a

result of these self-harming and addictive behaviors.

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The cost of conquering the opioid crisis is devastating,

lacking the resources to manage the overwhelming crisis

sweeping our nation.

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As a nurse I rely heavily on an

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interdisciplinary approach to health care for our

patients. LPCs are an integral component to ensure an

appropriate care plan and development, effective

treatment plans that our need to meet our patient's needs

and promote healing.

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MS. DITSCHMAN: Your time is up.

MICHELLE BRENNAN: Thank you. I oppose the

changes.

BRYAN NIXON: Good afternoon. My name is Bryan

Nixon, and I'm an LPC in Grand Rapids. I've been

practicing for about 12 years and seen hundreds of

clients during that time. One thing that I've become

abundantly clear on is the reality that as humans we are

formed in relationship, we are harmed in relationship,

and we are healed in relationship.

Research clearly shows that the quality of

relationship between client and their counselor is

primarily what determines the outcome of treatment. LPCs

know this both explicitly and implicitly. In addition to

our extensive training in diagnosis, we are trained in

psychotherapy techniques that address the relational

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trauma that exists within the fabric of most mental

health conditions. It is the relationship that heals.

The rule change that you are proposing will

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change our scope of practice which has been the precedent

for the past 30 years and will cause a massive shock-wave

to tear through the state that you are sworn to protect.

It will instantly sever the relationships of 10,000 LPCs

with their clients. The relationship trauma of ripping

clients away from their counselors will be devastating on

its own, but it won't stop there. It will exacerbate

current mental health struggles that clients are having.

It will resurrect past mental health struggles that

clients and their counselors have worked hard to

overcome, and it will create an irreparable rupture in

the trust of Michigan citizens in the mental health care

system in the state. It will affect not only LPCs, but

therapists of every stripe.

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I beg you, on behalf of LPCs and our many

clients and the future of mental health care in Michigan

wait just a little longer, allow House Bill 4325 to

continue making its way through the legislative process

as it will eliminate the need for the rule change. Do

not pull this trigger unless you're prepared to have this

blood on your hands.

BENJAMIN REISTERER: My name is Benjamin

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Reisterer, B-E-N-J-A-M-I-N, R-E-I-S-T-E-R-E-R, and I'm a

proud licensed professional counselor. I'm also a

supervisor to limited license professional counselor.

I'm an Afghanistan veteran. And I stand before you in

opposition to these proposed changes for LPCs.

I used my post 9-11 GI bill to become an LPC.

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He went to war to be able to help people heal. I left my

wife, my two-year-old daughter, my friends and my family

to go to the other side of the world to qualify for this

benefit so I could get the training, the supervision and

experience that you all asked of me to become an LPC.

If you make this change it will essentially

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mean that you have stolen my GI bill from me, that the

time spent away from loved ones and the hardships that I

endured will have been for naught simply to satisfy

arbitrary words on paper.

According to an article in the Lansing State

Journal last month, which also happened to be suicide

awareness month, the suicide rate in Michigan is 16.9

people per hundred thousand. For veterans, though,

that's much higher at 26.2 people per hundred thousand.

The VA has established vet centers all over the

country and Michigan is lucky to be home to eight of

then. Yesterday I took the time to call all eight

centers and found out that the LPCs represent over

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20 percent of their staffs combined. When you ponder

whether or not to implement this change please think

about the stats I cited and recognize that this could

essentially strip many Michigan veterans of the

therapeutic relationship they are relying on, while also

creating longer lines. How much worse would these

veteran suicide stats get if the proposed changes were a

new reality in the coming weeks?

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I ask you to hold all those affected in your

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mind before act. For you this is as simple as a stroke

of a pen or a keystroke that could be forgotten, but for

us, for us it is literally lives and livelihoods. And I

urge you to scrap these changes and allow the legislature

to pass House Bill 4325. House Bill 4325 is the humane

and just solution to this issue. Thank you for your

time.

JENNY ERMIGER: Hi. My name is Dr. Jenny

Ermiger, J-E-N-N-Y, E-R-M-I-G-E-R. I am blessed to be

the director of counselor education at Siena Heights

University. Personally I've been a practicing counselor

for 23 years. I am representing Siena Heights University

and the students we serve.

Changing the scope of practice directly impacts

both current and former students. Many are here today.

In good faith a student enters into a contract with the

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university and completes a rigorous plan of academic work

and training that leads to counseling licensure. Imagine

just graduating and hearing this recent news and learning

your profession could essentially be dismantled. Imagine

just learning there is no longer a solid career plan to

pay back thousands of student loans and your ability to

practice has been significantly changed. Just imagine.

Part of the Siena Heights' mission is to

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advocate for social justice. I am here because this just

doesn't feel just. I urge you to reconsider these

proposed changes. They will interfere with our students

and the thousands of counselors that serve the

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underserved. Let's continue to honor the sacredness of

the client and therapist relationship. Thank you.

DIANA BELYEA: Hi. I'm Dr. Diana Belyea.

That's D-I-A-N-N-A, B, as in boy, E-L-Y-E-A. And I have

been a high school counselor for 21 years and a clinical

counselor for 21 years. So, I have both perspectives,

and I don't think you've heard enough from the school

counselors.

People think that school counselors don't need

to diagnose and treat. However, we're the mental health

professionals that are working with families. Where else

would a family meet a mental health professional? I will

be the person that it's a mother, that her daughter's

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depressed, suicidal, and she needs to take her to Arbor

Oaks immediately or she cannot come back to school. I

have to threaten the parents because the parents are so

scared, they don't want to believe for a second that

their child could be that ill.

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So, I do diagnose as a high school counselor

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and I have for 20 years. Who else is going to recognize

what children are going through? When their parents come

to my office I have to be able to give them information.

I'm the person that tells them where to go from here.

Many, many parents, not because they don't love their

children, it's hard for them to understand that their

child actually needs to see a mental health professional.

You will not have mental health professionals

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in the school, you won't. Just like the teachers, where

are they now? We used to have a thousand teachers for

every job, but now we have a shortage. I wonder why. I

think we've had a lot changes to the teaching profession

and now we're doing it to the counseling provision. I

don't think we really care about children here, we just

say we do. Thank you.

CHERI LaLONE: Hi. My name is Cheri,

C-H-E-R-I-E, LaLone, L-A-L-O-N-E. I am a licensed

professional counselor, one of the few in the room that

represents the Community Mental Health system. I work

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for a six-county agency, Community Mental Health for

Central Michigan. My first three years I spent in

Isabella County, and then I transferred in January of

2018 to Clare County.

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Of the six counties that we serve five are in

the top eleven most impoverished counties in the State of

Michigan. Clare County is the third. There are

literally no resources, no pediatricians, very few

primary health care physicians, it's about 3,000 to 1 for

primary health care. And average caseloads in my agency

for an outpatient therapist are 70 to 85 each.

I transferred, like I said, in January of 2018.

Three weeks ago we finally got fully staffed in our

outpatient and our home-based programs. That is

unconscionable that now LARA, to avoid or to push the

legislature into acting, is put my clients, my patients

and my livelihood in the middle of this juxtaposition.

LARA doesn't have the ability to make law. That's what

the legislature is for. Let 4325 do it is job.

The senators and representatives are listening

to us for the first time because we're coming together as

a unified voice with social workers and with licensed

professional psychologists. We have to be able to do

this job.

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I can't look at the 80 clients that I have on

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Monday and say I didn't come here and fight for you.

They're hearing the news. They're devastated. They've

spent their entire lives in situations that we wouldn't

want to spend five minutes in; and yet, they trust me. I

provide that therapeutic rapport in my office. I share

with them I understand your anxiety and your depression

because I was there 20 years ago after my first, my

second child was born.

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MS. DITSCHMAN: Your time is up.

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CHERI LaLONE: Thank you.

JULIE ARTINIAN CALLAWAY: Thank you for

allowing me to speak today. My name is Julie Artinian

Callaway, J-U-L-I-E, A-R-T-I-N-I-A-N, Callaway,

C-A-L-L-A-W-A-Y. I'm an LPC, NCC and LLMSW. I graduated

from Eastern Michigan University in 1999. I also

graduated from my MSW -- that was my LPC. I graduated

with my MSW from EMU in 2015. I have 20 years of

experience as a counselor and two as a social worker.

As a NNC I've kept up on CEUs since graduation.

Having worked in a variety of settings from nonprofit to

the LLC private practice that I own now, I worked with

various types of clients who have experienced trauma and,

of course, been trained in trauma. I've also been

qualified as an expert in court.

In counseling I was supervised for 700 hours of

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counseling during my program and 3,000 hours postgraduate

while working with clients. To be clear, in order to

move from LLPC to LPC we have to obtain 3,000 hours of

supervised training in a work setting after we graduate.

Over the years I've attended hundreds of hours

of training in trauma, play therapy and supervision, just

to name a few. In my current practice I work with two

other LPCs and two LMSWs. We have four years left on our

office lease agreement. We don't know how we will pay

this.

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Since working in the same downtown of Adrian

for the last 16 years of my career I've come to know many

families in our community. In my practice families may

begin counseling, learn to cope, and reach their

treatment goals, then refer others to me. Some of the

folks with trauma are children from foster care, kids and

adults who have been abused sexually and/or physically,

and, of course, veterans and their families, just to name

a few types.

With this rule LARA is changing the scope of

our practice for LPCs. We've already been diagnosing, as

you already know.

MS. DITSCHMAN: Your time is up.

THE WITNESS: Please wait for the HB4325 to

avoid all this damage. Thank you.

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SHAWN ARCHER: I'm Shawn, S-H-A-W-N, last name

is Archer, A-R-C-H-E-R. I am also LPC and a nationally

certified counselor. I have a Master's degree in

leadership and counseling, as well as a Master's degree

in gender study. I have been doing this work for about

20 years ago.

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And I brought my visual aid. This is one

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binder that I have of trainings I have attended above and

beyond my counseling license, not required by LARA,

something I believe in, but it's important to do to stay

within my scope and to give the best to my clients.

Because of those 20 years, I work in a nonprofit, huge

turnover, I'm able to share this information with new

people coming in the door. They don't have to start from

scratch. I can help get them settled so they're not

burned out within six months. This is important.

These rule changes will take this, my degree,

all of these degrees off the table, and that's just not

acceptable. So, I ask you just to pause and let us get

through HB4325. Thank you.

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RAIZEL WEISS HEITZER: Hello. My name is

Raizel Weiss Heitzer, R-A-I-Z-E-L, W-E-I-S-S, no hyphen,

H-E-I-T-Z-E-R. I'm an NNC and an LPC. I'm here to add

my support to House Bill 4325 as a positive solution to

this issue.

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Rather than a comment I have a few questions

for LARA. LARA's mission statement states to provide

outstanding service to our customers, both internal and

external, by assisting with the reduction of rules and

regulations, advancing good public policy and best

practices as relates to consumer, economic activity and

workforce improvement through policies or statutes. If

it is your intent to provide outstanding service why are

you not offering a positive solution by supporting House

Bill 4325?

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I will not repeat the exact coursework in

diagnosis and training methodology or the hours of

vigorous training that LPCs go through, although it bears

repeating. It has been documented. We are highly

educated and experienced mental health providers who help

over 100,000 people in Michigan every year. Clearly

these changes will hurt LPCs and all the adjacent staff

and agencies, our vulnerable clients, the unemployment

rate, our university programs, overburdening the systems

in place who work in mental health, and overall health of

the State of Michigan.

So, I ask you who is pushing for these changes?

Who would benefit from these changes?

AMANDA SANDLES: Hello. My name is Amanda

Sandles, A-M-A-N-D-A, S-A-N-D-L-E-S. My sister is an

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LPC. I've been a grateful patient of an LPC. I am a

survivor of sexual assault. And I am coming from the

medical school where our dean was sentenced to jail for

misconduct in office regarding the Larry Nassar abuse,

and was tried for his own criminal sexual assault against

students.

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I am currently applying to an emergency

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medicine residency here and across the country. I began

working in medicine in the ER registration ten years ago.

Now that I'm back in the ER full-time I can tell you that

the length of stay for psyche patients in the emergency

room has increased drastically, and I have seen multiple

patients who have been waiting for over a month to get

placement.

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And ER is a stressful if place for someone

seeking physical health care, let alone an acute

psychiatric event, and the simulation in an ER can

actually precipitate further progression and severity of

their symptoms. Just recently we had a patient who was

on hold for psyche placement who was near a loud patient

and he was triggered by loud noise. The patient who was

on psyche hold choked the other patient. A staff member

had to get involved. The staff member got assaulted, the

other patient got assaulted, and then the psyche patient

had to end up in restraints. And it never had to happen

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in the first place because an ER isn't equipped to deal

with mental health care.

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Lack of billing code leveling for psyche

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medical care makes it so that there's no financial

incentive for hospital systems to provide extra mental

health support staff in the ER. ERs and other health

care systems are being overburdened due to the lack of

systemic support for mental health care and mental health

professionals in this country and in this state.

In the closing of the State's Caro inpatient

hospital has further increased the burden where now the

waiting list for inpatient treatment is over 250 people.

These patients are left looking for outpatient treatment

and left relying on health care options that aren't built

to provide proper care for them like emergency rooms.

Taking away 10,000 LPC providers from a community that is

already suffering from --

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MS. DITSCHMAN: Time.

THE WITNESS: -- of total providers will cause

harm to the people we have all collectively committed to

serve. Please pause until HB4325 is passed.

KATHRYN WATSON: Hello. My name is Kathryn

Watson, K-A-T-H-R-Y-N, W-A-T-S-O-N. I am an LPC and NCC.

I've been counseling for several years, and I graduated

from Eastern Michigan University in the mental health

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care program. I am a mom of two boys, two and three.

They are well-fed, loved, nurtured, have a home,

clothing. But every day I work with many children that

do not have this experience.

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I work at Beatty Early Learning Center

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Community in Ypsilanti, Michigan with three and

four-year-old children. This is a preschool for low

income families. Many of our students have faced

homelessness, trauma, gun violence in their communities,

neglect, difficult life transitions such as having a

parent incarcerated or a family member die in their home.

For the 127 students in our school I am the

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only consistent mental health care provider that is there

each and every day. I work one-on-one with these

children to establish trust, build relationships and

teach coping stills for the anxiety and behavioral

changes. Many of these preschoolers have learned from

their early life experiences not to trust adults and fear

change. I know through the work we do together I have

become a constant in their lives, someone they can trust

and count on even if it's just a few hours a week.

What will happen to these preschoolers, these

three and four-year-olds, who many have attachment

disorders and fear of abandonment if I can no longer

provide services? You only hear me speaking right now,

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but when you look at me think of 127 children that will

be affected by this. Look at this room filled with

people that represent clients they serve. Can you

imagine if we brought them all here today how we'd fill

the room and the streets with our clients?

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Thank you for your time.

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SHEILA HIBBS: Hello. My name is Sheila Hibbs,

S-H-E-I-L-A, H-I-B-B-S. And I am a licensed professional

counselor. I have been fully licensed since 2007 and

have held many clinical positions throughout that time.

I also serve as the director of quality and management at

Integrated Services of Kalamazoo, which is the community

mental health and support program for Kalamazoo County.

Integrated Services of Kalamazoo services close to 7,000

individuals annually, and we employ 30 other limited

license or fully licensed professional counselors.

Each of these counselors and therapists are

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educated, trained, qualified and appropriately licensed

to diagnose and provide therapy. It is also a

requirement of the community mental health services

program, per our contract with the Michigan Department of

Health and Human Services to achieve network adequacy,

capacity and standards that are necessary to meet the

needs of our community. Without licensed professional

counselors we would not be able to meet those

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requirements.

I am humbled on a weekly basis to have the

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privilege to listen to, support and provide therapy to

youth, adults and families. I work with youth

experiencing suicidal ideation, bullying, insecurities,

anxiety and depression. I work with young adults who

have recently lost a parent who was their whole world.

They have been working through the grieving process,

including the feeling of guilt to once again experience

happiness and joy that they didn't think was ever

possible. I have sat with individuals in emergency

departments who have overdosed as a suicide attempt and

had the true belief that there was no other reason to

live.

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The impact statement by LARA for Number 32 says

explain how the rule, proposed rule changes impact the

business growth --

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SHEILA HIBBS: Thank you.

ANNA RICHARDS: Hello. My name is Anna

Richards. That's A-N-N-A, R-I-C-H-A-R-DS. And I'm here

to oppose LARA's proposed rules and in support of HB4325.

I am a licensed professional counselor as well

as a nationally certified counselor. I graduated from an

accredited program. It has been my life's mission to

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become a mental health clinician. For me it started with

an inspirational Alan Thicke from watching Growing Pains,

a psychiatrist Mike Seaver, when I was a child.

From the time I was ten I've been on this path

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and carefully chose a program that would not only allow

me to work as fully licensed practitioner and allow me to

open my own private practice, but one with moral values

and code of ethics resonated with me in a way in which I

am unable to describe with words. I found a home, a

tribe if you will, with my program, my colleagues and our

scope of practice, something that has been in place 30

years, as you have heard, and specifically 16 years prior

to my choosing a profession.

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Let me discuss my background a bit, if I may.

I specialize in grief and loss and trauma and anxiety.

One of the specialties is adults with foster children. I

also discuss that my resume includes working at Beaumont

Hospice also in Ann Arbor, Schoolcraft College. I'm very

well-rounded in medical nonprofit career educational as

well as clinical type settings. My accredited degree and

licensure has afforded me the ability to gain experience

in these areas.

I now have my own private practice in

Ann Arbor. One of the areas I specialize in for my

educational setting is identifying perfectionism and its

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often crippling effects. It brings significant amounts

of anxiety with it. In the educational setting you might

meet someone who has straight 4.0s, and that's an area of

conversation. I work with highly successful people,

including employees from U of M, St. Joe's. I work with

high level competent professionals; nurses, dentists,

occupational and art and music therapists, social

workers, pharmacists, graduate fellows, Ph.D.s, research

coordinators. Many of these are navigating --

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MS. DITSCHMAN: Your time is up.

JENNIFER BURGER: Hello. My name is Jennifer

Burger, J-E-N-N-I-F-E-R, B-U-R-G-E-R. I represent Hegira

Health, Incorporated and also the LPCs in the State of

Michigan. I'm a licensed professional counselor and a

nationally certified counselor. I earned my Master's

degree from Vanderbilt University, which is a CACREP

accredited program. I've been in practice for 15 years

and have dedicated my career to the treatment of severe

mental illness, including bipolar disorder,

schizophrenia, and those with severe trauma resulting in

post-traumatic stress disorder.

I've been able to do this difficult, but

rewarding, work because I am qualified. I've received

training in the assessment, diagnosis and treatment of

those with mental health and substance use problems. I

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completed a practicum and internship in both the

community mental health and hospice settings. I've taken

and passed past two national counseling exams, the

national counselor exam, and the national clinical mental

health counseling exam. I provided 2700 hours of

clinical experience under supervision prior to being able

to work independently. I'm definitely qualified.

For the past eight years I've worked for Hegira

Health, Incorporated, a nonprofit agency in Wayne County.

I'm the administrator of our adult outpatient services

department. The individuals we are honored to serve not

only struggle with the symptoms of mental health and

substance abuse disorders, but struggle with these

symptoms under the threat of funding cuts regularly in

the mental health arena.

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With the proposed changes to LPC rules are we

now have to tell them that they will lose their counselor

altogether? At Hegira alone LPCs have served over 6,790

individuals during the last fiscal year that just ended.

Think of the magnitude of that and how that echos

throughout the State of Michigan.

With the proposed rule changes LARA is changing

the scope of practice for LPCs who have practiced for 30

plus years. Please pause on implementing these changes

and allow HB4325 to work its way through the legislative

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process. Thank you.

BETH PETERSON: Whoever handed a Poptart over

cell door of the bathroom thank you. That's a

hypoglycemic therapist.

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My name is Beth Peterson, B-E-T-H,

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P-E-T-E-R-S-O-N. I am a licensed professional counselor.

I'm trained in EMDR. I'm also a doctoral student in

counselor education and supervision at a CACREP

accredited school, university. And I have given up a

whole day of studying for my competency exams. I'm in my

third year and I'm facing those this fall. So, thank you

for hearing me.

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I am also the owner of Milan Christian

Counseling. In the school year of 2010 and 2011 there

were a number of students at Milan High School who had

taken their lives to suicide. There were countless other

students who had attempted suicide or who struggled with

suicidal thoughts, and the increase of non-suicidal

self-injury was on the rise. So, my former business

partner and I opened up Milan Christian Counseling at

that time. And since then we have received numerous

voices of gratitude from former clients for saying their

lives or for improving the quality of the lives that they

lead.

I just want to speak briefly to the way we

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coordinate with medical professionals, psychiatrists,

primary care physicians, and nurse practitioners who

prescribe medication for our clients. Every time I meet

with a client I ask them how compliant they are with

taking their medication. I look for new symptoms and I

speak frequently with their medical providers. We have

psychiatrists and primary care physicians who often look

to us for our expertise and they want to know what we are

seeing in the counseling room.

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MS. DITSCHMAN: Your time is up.

OLIVIA DORGAN: I want to first thank for the

opportunity to speak with you. My name is Olivia Dorgan,

O-L-I-V-I-A, D-O-R-G-A-N. I am an office manager at a

private practice, Pawsitive Counseling Center located in

the small town of Fremont. Pawsitive Counseling Center

is an LPC-owned practice specializing in the counseling

of young children under the age of 12 through play

therapy and canine assistive therapy.

The changes proposed will affect me directly as

I will lose my job of two and-a-half years, a job I love

coming to each day. LARA's proposed repeal of

definitions under the LPC rules will change the scope of

practice for counselors, including their ability to

diagnose. This will have a devastating effect on

thousands of patients in the state. At Pawsitive

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Counseling Center alone this will affect over 60

patients, at least 80 percent of those patients being

under the age of eight.

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There is already a mental health crisis and a

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shortage of mental health professionals. As an office

manager I handle the scheduling of patients we see. Due

to the already existing shortage of available therapists

in the area I have a waiting list exceeding 50 people.

Most of these are children under the age of eight. It's

hard enough to tell people that they have to wait because

there's no one else able to see them, but taking away the

one person in our area that can see them would be

absolutely devastating.

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I ask you to please wait on implementing the

proposed rule changes. The solutions that meet -- the

solution that meets both LARA's needs and the LPCs' needs

is HB4325. Give us time to pass it into law. Continue

to protect the public and allow LPCs to continue to

practice as they have been. Thank you for listening.

MARY ROTTIER: My name is Dr. Mary Rottier

tear, M-A-R-Y, R-O-T-T-I-E-R. And I am a counselor at

Positive Counseling Center. I actually own the practice.

I'm currently licensed as an LPC in both the states of

Georgia and Michigan. I'm also a registered play

therapist supervisor with the Association for Play

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therapy. I have a Master's degree in clinical psychology

from Georgia Southern University and a doctorate in

counseling psychology from the American School of

Professional Psychology.

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I have 20 years of counseling experience,

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including two internships and three years under the

supervision of both a psychologist and an LPC supervisor.

I currently own two practices, one in Georgia and one in

Michigan, that specialize in seeing children and their

families.

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Six years ago I was excited about the

opportunity to move to Michigan to continue furthering my

career. However, now I'm disheartened that after 20

years of practic I may no longer be able to provide

counseling services to the clients I serve. It is also

extremely confusing to me why I would be able to continue

to serve clients in Georgia but not in Michigan,

especially with the same credentials and at the highest

degree possible in my field of counseling. I've had

plenty of extensive training in diagnosis, as well as

counseling techniques.

I currently serve about 68 clients in my

private practice. In fact, I have just recently extended

my hours to accommodate the needs of children in my

community. I'm the only provider that specializes in

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working with youngs kids as young as three in the fields

of anxiety, trauma, and attachment.

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The rules that LARA proposes would be

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catastrophic for my clients. We have very few providers,

the majority which are LPCs. Where would all these

clients go? Who would help the young sexual abuse

victims I see, the children whose parents are divorcing,

the children who have lost a parent, the suicidal

teenagers, or the kids who are engaging in self-harm

behaviors.

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I was trained as a therapist to do no harm.

The current rule changes would force me to do that, to

abandoned clients that are in desperate need of services.

Please pass 4325. It meets the needs of both LARA and

the clients in our community. Protect the mental health

crisis. Thank you.

FELICIA MOSES: My name is Felicia Moses,

F-E-L-I-C-I-A, last name spelled M-O-S-E-S. I want you

to remember that name today when you go to sleep. I am a

Central Michigan University grad student with a GPA of

3.98. Every class that's on this list on Page 6 I have

taken except of practicums and internship, which is next

year.

I stand tall with the LPCs. I stand tall with

the LLPCs. I stand tall with the doctors. I stand tall

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with all the classmates. I stand tall for myself.

Because you know why? I'm spending thousands of dollars

in a program. When I left Federal Court working there

for 22 years God put it upon my heart to work with people

that are lot of people that are addicted, people who have

controlled substance, people who are abused, people who

are addicts. I am that person to stand tall for them.

Do not strip me of my dream to become an LPC.

Do not strip me of my chance to be able to leave this

world, to leave CMU and stand and say come on, my name in

Felicia Moses, may help you today. Do not strip that

chance for me to be able to graduate from a program

because LARA decides that they want to repeal some

language.

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As I leave this place today, sitting in this

chair since 8:00 a.m., I have to say to Dr. Morgan, to

all the doctors and the ministers and all the

psychologists and the psychiatrists and the social

workers whether you're with us or not I stand tall today.

I am with you. I will pray for you.

And as I have learned humanistic approach,

cognitive behavior I'm going to leave here with you by

saying I will pray for you. I will forgive you.

TANYA BANKSTON: My name is Tanya Bankston.

I'm a Central Michigan student. My graduation date is

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December 12, 2019. I just finished my 600 hours of

internship. I don't have the initials to go behind my

name, but what I do have is the real life case study from

a real client.

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My client I met in December. He was suicidal.

I spent the first two months gaining his trust,

developing suicide safety plans, talking to his family

members, making sure that those words that he spoke were

not idle threats. Okay? Months two and three I gained

more trust. I convinced him to go to a doctor to get

some medication. His doctor called me to ask me what

were my thoughts, what should I do for the client. This

is a medical doctor asking me for my opinion.

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Seven months later my client is still with me.

Now he's asking me Tanya, is there real hope? He's still

with me, and I saw him just two days ago. And I finished

my 600 hours in July. I'm still seeing him today to let

him know that somebody cares. I support HB4325.

T-A-N-Y-A, B-A-N-K-S-T-O-N, Tanya Bankston.

RICHARD POWELL: Hello. My name is Richard

Powell, R-I-C-H-A-R-D, P-O-W-E-L-L. I'm an attorney.

I'm a counselor. I'm a Ph.D. candidate at Oakland

University. And I'm happy to be here. I'm also here to

represent the Rochester Center for Behavioral Medicine.

Administrative rules must be a reasonable

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interpretation of the law. The current regulatory

definition of counseling techniques is a reasonable

interpretation of the law. Since 1978, starting with an

exemption written into the scope of practice of

psychology, the words counseling techniques in the

Michigan Public Health Code have been understood to allow

counselors to practice various approaches to

psychotherapy and diagnosis consistent with counselor

training and a code of ethics.

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In 1993, in response to a request from the

Board of Counseling, the Attorney General agreed with

inclusion of diagnosis and psychotherapy and counseling

techniques in the scope of practice definitions. And

since that time the rule has largely been challenged from

a statutory construction point of view.

In 1995, 2003, 2012 the Board of Counseling,

the Legislative Service Bureau, LARA, and the Attorney

General's Office reapproved the wording in our scope of

practice. Our statute includes the practice of

psychology through our training and counseling

techniques. Counseling techniques are nationally,

regionally and locally, academically, professionally and

scientifically understood to include diagnosis and

psychotherapy.

Has everyone been wrong? What makes more sense

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is that the original rules definitions reflect the

believable rational understanding of the words counseling

techniques. To assume otherwise is to adopt a pre-1970s

understanding of mental health and the law. Thank you.

REBECCA VANNEST: Hello. I'm Dr. Rebecca

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Vannest, R-E-B-E-C-C-A, V-A-N-N-E-S-T, LPC, nationally

Board certified, licensed school counselor, small

business owner, adjunct professor, supervisor, pending

registered play therapist.

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School counselors in Michigan have the second

worst caseloads in Michigan. I personally have had

anywhere between 350 and 950 students on my caseload at

any one time. In my first year in counseling I called

Child Protective Services 60 times to protect children.

I also conducted 200 suicide assessments. This means

sick students were in danger. The students were between

the ages of four and ten.

In approximately 15 years I have conducted

around 200 suicide assessments in schools. School

counseling offices have essentially become ERs due to the

suicide and mental health crisis.

Some say we are a danger to the public. I have

reviewed data from LARA's website for 2019. The State

Board of Counseling did discipline some counselors, a

quarter of 1 percent of the profession. I'll say that

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again. A quarter of 1 percent of the profession. Yet,

we could lose 30 percent of our providers.

Michigan is bottom of the nation for mental

health, school counseling ratios, child abuse, human

trafficking, and water. Let's get on the right side of

this issue.

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As I have listened to my brothers and sisters

today for six hours I have realized we need a

multidisciplinary committee of mental health providers to

advise the governor on the mental health crisis in the

State of Michigan, which I believe is important to her.

I will be first in line to serve.

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JASON VANNEST: Good afternoon. Thank you for

having us to speak before you today. My name is

Dr. Jason Vannest. That's my hot wife that just got done

speaking.

I'm a licensed professional counselor, a

licensed school counselor, a nationally certified

counselor, and in the final stages of certification as a

registered play therapist. It's in the mail. I'm a

trained clinical supervisor, university professor,

therapist, and perhaps most importantly, school counselor

for children ages four to ten years old.

Most people when they hear that they say oh,

how cute, little teeny babies, four-year-old, and it is

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cute, and it is a lot of fun. What some may not realize

is that some of these kids are born drug addicted, these

kids have genetically predisposed towards severe mental

health disorders. They come from homes where they are

beaten, starved, raped by siblings and/or parents. They

bring debilitating pathological struggles to school with

them each and every day, and they need help.

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I service nearly 1,000 children each school

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year, that's three zeros, and cannot begin to meet their

needs on my own. This is why I rely on these good people

out here to refer to to get them the necessary help and

support.

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Children are dying for help, literally dying.

Suicide is the second leading cause of death for people

10 to 34 years of age. LPCs provide 30 to 35 percent of

that care. I'd like to know which board members,

politicians or legislators want to add their name to a

movement to rob mental health services and care from 30

to 35 percent of our children, teens, sisters, brothers,

and parents whose lives depend on it.

Nothing against you folks, but I am literally

disgusted by the bureaucracy and red tape bull crap --

MS. DITSCHMAN: Your time is up.

JASON VANNEST: -- that is preventing these

mental health mental health services from the people who

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depend on it.

ALEXANDRIA PHELPS: Hello. I should say good

evening. It feels like the evening because I've been

here since 8:00 in the morning. My name is Alexandria

Phelps, A-L-E-X-A-N-D-R-I-A, P-H-E-L-P-S. I'm an MA,

SCL, LLPC and NCC. I currently work as a school

counselor in the number two school in Michigan, and I

hope to speak for those today in the education system

that may not even be aware of this or how this day will

affect them should LARA rules go into effect.

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Michigan is the 49th worst state for school

counselor to student ratios in the country. One to 250

is recommended. Michigan average is 1 to 732. Anxiety,

depression, and suicidal ideation are at the forefront of

mys conversations in the school system with 14 to

18-year-olds every single day.

LARA's proposed rule changes would cause

significant loss of referrals for school counselors in

Michigan and even longer wait times for students to

receive mental health services. These laws would

directly affect my ability to follow my American School

Counseling Association code of ethics to refer out when

students require additional mental health care.

School counselors should not be long-term

mental health service providers. I already face symptoms

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of burnout at just 25 years old. It is pivotal that LARA

stop or delay the implementation of these rules changes

in order to allow House Bill 4325 to become law so

overworked school counselors and overworked and untrained

teachers do not become students' only available mental

health providers. Thank you.

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DEANNA KEMPKE: Hi there. My name is Deanna

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Kempke, D-E-A-N-N-A, Kempke, K-E-M-P-K-E. I'm a licensed

professional counselor and a nationally certified

counselor. I have a small business, a full-time

counseling practice in Ann Arbor. The proposed rule

changes will put me out of business, affecting not only

my two high school age kids but the women I counsel in my

practice and the community I serve.

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My practice is within walking distance of the

University of Michigan, as well as two high schools and

one middle school. I work primarily with young women,

many of whom have experienced emotional abuse and sexual

trauma. Many of my referrals come from the university's

counseling center. For those of you who may not be

familiar with university counseling centers, you need to

know that the waitlist is often long and the sessions are

limited to six. This simply is not enough time to meet

the needs of someone who has been sexually assaulted,

self-harmed, and has persistent suicidal ideation.

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The university relies on me and other

professional therapists in my community to help these

women. I also receive referrals from the psychiatric

emergency room, as well as Ann Arbor public school

counselors who, again, do not have time to counsel

students presenting with mental health issues.

My practice is robust. I typically fill 145

sessions a month. Since Me Too I've had to create a

waitlist. I am repeatedly told by my patients that it's

hard to find a therapist. It takes a lot of courage to

ask for help and, unfortunately, when people muster up

the wherewithal to do so they often encounter roadblocks.

Practices are full. There simply are not enough

therapists to meet the growing demand for mental health

services.

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If the proposed rule changes go into effect

I'll have to close my business. I am then ethically

bound to refer my patients to another clinician. I have

no idea where I will find help for the 45 women on my

caseload.

MS. DITSCHMAN: Your time is up.

DEANNA KEMPKE: Gee whiz.

MICHELLE SIEV: Hello. Thank for allowing me

to speak. My name is Michelle Siev, M-I-C-H-E-L-L-E, S,

like Sam, I-E-V, Victor. I am a licensed professional

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counselor, a nationally certified counselor. And I have

been helping clients since 2012. I work in traumatic

rehabilitation, traumatic brain injury rehabilitation

programs and community agencies from 2012 to 2016.

I'm now the owner of a private practice which

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will essentially go out of business if this rule goes

into effect. I am well-educated as you have heard

already from all the other LPCs in the room. And because

of my code of ethics I took time to learn my skills and

to learn my profession before I went into private

practice. I wanted to make sure that I had the things

that I needed in order to serve my clients.

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I became a counselor because I wanted to make a

positive difference in people's lives. I was a teacher

prior to becoming a counselor, and I was making a

positive difference there, but I felt that the need was

so great to be able to work individually with people.

I imagine many of you in LARA have the same

motivation, and that is to, you know, help other people,

but this change is not going to be helpful. This change

is going to be devastating. And, you know, there's an

expression that doing the right thing is often the harder

thing, but in this case the right thing is actually the

easy thing. Just hold on, let HB4325 pass, and thank you

for your consideration because if you do what you're

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saying you're going to do this will be a devastating

step. Thank you.

CAROL ANN HINES: Hi. I'm amazed as at what

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you guys are doing. I'm back there crying. I'm not an

LPC. I'm a recipient.

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MS. DITSCHMAN: Can you state your name?

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CAROL ANN HINES: Oh. My name is Carol Ann

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Hines, H-I-N-E-S. No Es on either first part.

Anyway, yeah, I graduated in '70. I've been

getting help almost all my life. And it's a good thing,

too. I'm still alive. That counts. I know people who

haven't been alive. These are grief bracelets. Okay?

People die from suicide or depression. I don't want to

die, thank God.

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I've got the support of my God, my church.

I've got the support of 12 step programs, but that's not

enough. And I got a counseling session on Tuesday and I

took my meds this morning. Seeing someone to talk to

regularly has helped me work. Not a glamorous job, but

I've worked. I've even got an Associate's degree. I've

been hospitalized fewer times and I'm alive. Those are

three big things that help save money.

I'm representing a group that is a mental

health peer support group on FaceBook. We're called

Broken People, and we're over 500. We vote, too. And

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yeah, my dad used to say well, this is a funny part, I

was in Pinerest, they said that my caseworker suggested I

get testing from the psychologist. I wanted testing. I

wanted the real diagnosis to stand up. They gave me

memory testing. Oh, yeah, my memory's fine. I wondered

where theirs was. Oh, well, that's supposed to be funny.

I wish you would just slow down. Maybe you're moving too

fast. Thank you.

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KIMBERLY MATEUS: You have a good personality.

My name is Kimberly Mateus, K-I-M-B-E-R-L-Y, M-A-T-E-U-S.

Thank you for giving me the opportunity to speak with you

today and hopefully holding a second hearing to allow the

hundreds of people waiting outside those doors to speak

as well.

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I obtained a Master's degree in counseling from

Michigan State University in 2008. Over the past ten

years I have worked with individuals who suffer from

traumatic brain injury and spinal cord injury. Due to

the unexpected acute trauma suffered by my clients and

their families there is also a need for family therapy as

well. I have also been asked to provide testimony at

courts for concerns related to guardianship for my

clients.

Due to the nature of my client's injuries,

which are typically the result of motor vehicle

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accidents, many suffer from PTSD as well as face

difficulties with obtaining transportation to sessions.

Therefore, this necessitates that most therapy sessions

are held at their residences. Many of these residences

are in rural settings with few therapists in their

community. If you change the scope a practice for

counselors, including our ability to diagnose, you would

deprive my clients from having access to essential

counseling services.

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It is the State's responsibility to shepherd

and protect the public. Taking the therapists of many

clients is not productive, and there is currently a

mental health crisis and a shortage of therapists.

I'm not sure how much time I have, so --

MS. DITSCHMAN: 30 seconds.

KIMBERLY MATEUS: Great. As a small business

owner and the head of a single income family I would have

no way of paying for basic necessities such as food and

shelter, much less pay back my student loans to get my

Master's degree in counseling.

I strongly urge you to wait, slow the process

down so that the legislative system can work and HB4325

has time to pass. Thank you.

KATE SELLERS: My name is Kate Sellers,

K-A-T-E, S-E-L-L-E-R-S. I am your patient. The only

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reason I am alive and standing here as a productive

member of society is because of the dedicated and

consistent work of trained counselors like y'all. I am

your daughter, I am your wife, I am your mother.

My parents, my husband and my son have been

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spared the pain of attending my funeral due to the

compassion and availability of licensed professionals

that have been able to diagnose and treat me. By working

with multiple LPCs through the years I have discovered

different types of psychotherapy and the combination that

keeps me functional in my job and in my life. Through

many group therapy sessions I have attended I have met

over 500 people in this same situation. Without people

like you, their counselors, they would be dead, in a

hospital, homeless or jobless. Because of LPCs they are

able to live, to work, to pay your taxes, to vote, and to

get fulfillment out of life.

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Since I had been admitted in the St. Lawrence

psychiatric ward after a suicide side attempt in May of

2017 counselors have held my hand, sometimes literally.

Along the path of recovery, from the initial diagnosis to

awareness of available medication, to finding the

combination of therapy techniques that work best for each

and every individual patient it is education, training

and professionalism of how these LPCs that have kept me

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and hundreds of people like me above ground, out of the

ER, and on the road to their best life.

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LARA, I beseech you, do not put through the

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proposed changes. Please wait until HB4325 is approved.

I ask this for myself, on behalf of all the other people

that have benefited from the training of LPCs. And I am

terrified of what may happen to me, my family, and my

friends if the guidance of these counselors is taken

away.

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This is a life and death issue. If the

proposal goes through LARA has issued a death sentence.

Yes, it is that serious and it is that simple. LARA's

arbitrary proposal is not more important than my life.

LAURIE ORLANDO: Good afternoon. I'm Laurie

Orlando, L-A-U-R-I-E, O-R-L-A-N-D-O. I'm an attorney

practicing in Michigan for 33 years. I am also a very

proud LPC. I've been licensed in this state since, it's

been a little over 14 years now. I'm also trained in

supervision and I supervise many people. I have two

private practices, one in Macomb County, one in Oakland

County, so I'm representing both of those practices

today, Treeside Psychological Clinic in Lake Orion and

Orlando Counseling Services in Macomb.

I am at a loss to understand why LARA feels the

need to push through on these proposed rules. The

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regulatory impact statement that I have heard and based

on all the testimony today is insufficient. There's not

been enough consideration given to the impact that those

rule changes would make. To say that LARA wants to clear

things up that they've done wrong in the rules before

just makes absolutely no sense.

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We have an entire state, an entire industry

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where LPCs are embedded in our institutional settings, in

all of our hospital and health care systems, in private

practices. And every single one of those businesses will

be detrimentally affected for no reason. To wipe out an

entire profession does, yes, it hurts our clients most,

but it also hurts us.

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I drove up here today with my son, who just

incurred $50,000 in student loan debt to get his Master's

in counseling, who now is licensed and just starting out

in his career that's going to be wiped away. I also

drove up here with another LLPC I supervised who just

gave up her 25-year career somewhere else to go full-time

into the practice of counseling. She's also fighting,

suffering from, or recovering from breast cancer --

MS. DITSCHMAN: Your time is up.

LAURIE ORLANDO: -- and sitting outside. This

is wrong, just wrong.

DEBRA LOVING: My name is Minister Debra,

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D-E-B-R-A, Loving, L-O-V-I-N-G. I have owned a private

practice for seven years, and during that time I employ 8

employees, 35 contractual clinicians comprising of social

workers and LPCs and LLPCs. We are Joint Commission

accredited. We are substance abuse certified. We work

with children as young as three. Our eldest client is 91

years old.

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We have accomplished many things. We see about

20 new clients per week coming through our door. We

service over 300 people a week. That's just at the one

agency. We had three agencies open up by year three, and

all that was done by an LLPC or an LPC.

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Today I am standing in awe, and everybody, all

my brothers and sisters that are all here, all the social

workers and psychologists. I have a team that's

comprised of two psychiatrists and a psychologist. What

we accomplished we have accomplished together.

There are a few that are opposing. There's

always going to be somebody opposing. When you're trying

to do something good something bad is not far behind.

But this is what I say today is I can't sit here and

believe that everybody sitting inside LARA is these

horrible and terrible people, so I'm speaking to the

individuals that have the power to make change. I'm

speaking to your character. You're going to have to go

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against some adversaries and you're going to have to go

against some people that would otherwise want something

different.

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But you have heard too many testimonies today

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to understand that if HB4325 does not go through you've

heard the travesty. So, please, today I'm asking that

any member of LARA make a conscious decision. And please

don't forget everybody that everybody that is sitting in

this room, is standing in this room, and will be standing

in this room, you have already preapproved our license.

You said it was okay to practice. And now that we're

doing amazingly great things people are feeling a little

vulnerable and a little worried. But it's going to take

a whole village. The village needs to come back, it

doesn't need to dissipate. So, I speak to your character

today and speak to your reputation. Thank you for

letting me speak.

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ROLISIA SIEBERT: Hello. My name is Rolisia

Siebert, that's R-O-L-I-S-I-A, S-I-E-B-E-R-T. I'm an LPC

in private practice. I'm a supervisor and I'm a

qualified intellectual disability professional. My

clients need me, and that's who I'm speaking for today.

I started in field because I wanted to speak

for the ones whose voices are hidden due to trauma or

abuse. I'm here representing the children and adults who

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struggle with abandonment and inconsistency. Yes, this

is my livelihood, but that's not why I'm here today. My

clients struggle with suicidal thoughts, self-harming

behaviors, anxiety, depression. They trust me with their

deepest and their darkest secrets.

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I followed the requirements. I completed my

training. I was supervised for the required amount of

time. I invested in myself because I wanted to be an

investment for my clients. If I cannot practice in the

scope that I have been doing for the last 15 years it

will be detrimental to my clients and to the State of

Michigan. It will impact our environment. It will

impact our community.

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LPCs are part of the team. We all know our

parts. We know our scope. And we play the part. So,

then they don't take that part. We work together. And

before LARA makes a decision we're all playing our part.

Thank for our time today. I want to say thank

you. I get up every single day ready to save the world

one client at a time. Please do not take that from me.

Thank you very much.

SCOTT BANGHART: My name is Scott Banghart,

B-A-N-G-H-A-R-T. I'm a licensed school counselor, an

LPC, and a national certified counselor.

I am here today to speak on behalf of my

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transgender son. After his attempted suicide my wife and

I had to wait nearly two months to find a therapist who

could treat him. He has developed a healthy relationship

with his counselor, who is an LPC. When he and I are

discussing last night the potential fallout of LARA's

decision he looked at me and his eyes were the look of

fear, saying dad, I'm not telling my story again.

So, as a father I'm asking you to please let

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House Bill 4325 run its course and allow my son to

continue to see his therapist. Thank you.

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CHRISTINE LYON: Thank you for sharing that.

My name is Christine Lyon, C-H-R-I-S-T-I-N-E, L-Y-O-N.

I'm an LPC. I'm nationally certified. I graduated with

an MA. I have the credentials.

I scratched out my entire speech while I was

sitting here because I've been sitting in the room with

you guys, you guys, and it's led me to some insights and

I'd like to share them. I get that you're frustrated by

having to wait for State statute to be fixed, and I'd

even go so far as to guess that you wish you weren't

forced to be in this position. I believe that you feel

that you need to do this. And as every counselor knows,

accountability is important.

Our previous bill didn't make it through the

State Senate. We didn't get it done. We didn't show up

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like we're showing up now. But you guys got us moving

and, as you may have noticed, we're mobilized. We will

work tirelessly until this bill passes. We need you to

believe in us.

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Every counselor also knows that a first pass at

an intervention can be a vital building block toward

healthy and last change. The previous bill was that

building block. Please notice the difference in the

climate, in the advocacy, and the support for this bill.

Please consider pausing, delaying your actions and

letting State statute catch up to where we already are.

Thank you.

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MARCY SZNEWAJS: Hi. My name is Marcy

Sznewajs, M-A-R-C-Y, last name is S-Z-N-E-W-A-J-S. I'm

an LPC, a NCC, and a certified clinical trauma therapist.

And I'd like to address LARA's stance, kind of

similar to what Christine was just saying, that they must

move forward because we didn't take action on the last

bill, and the last bill failed and they don't want to

wait for this one. Well, it's my understanding that the

prior similar bill failed because of late hour

unnecessary and harmful changes that were made by the

Senate. And that was in part caused by a

disproportionate influence that was given by the people

that aren't in our profession. And we weren't aware,

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and, you know, that's on us. But now we are aware.

And I would like to please ask that LARA listen

to the people who know our profession rather than the

people who don't know our profession and don't know our

board and don't know our ethics. We're here. We're

ready to educate. And going from this point forward we

are passionately advocating and educating both the

Senate, the House and our governor about what it is that

we do, our ethics, our credentials, our training.

We can get this done, but we need time. So,

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please give us the time we need. We're here. We're

ready to advocate. We're ready to educate. We just need

time. So, please stop, pull back, withdraw, give us the

time that we need. Thank you so much.

JEANINE MADSEN: It's been a really long day.

And I have rewritten -- my name is Jeanine Madsen,

J-E-A-N-I-N-E, M-A-D, as in dog, S, as in Sam, E-N. I'm

an LPC, NCC, CAA, EC, EMDR trained therapist.

I'm giving my personal testimony as an LPC who

will be directly impacted if LARA changes our implemented

and, in fact, our scope of practice. By now you are

aware of the disbelief and shock that licensed

professional counselors are living. The idea that via a,

quote, small change by LARA we could all lose our

livelihoods is incredible. I understand the need of the

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State to have consistent and clear standards, and that is

filled at a Master's level. Psychologists, social

workers and licensed professional counselors should all

be able to practice what they've been educated and

trained to do.

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We all have a little different approach and we

are all needed in the face of the growing opioid and

mental health crisis that is currently present in

Michigan. My clients will be greatly impacted if I am

unable to see them. I work with vulnerable populations,

people who have substance abuse problems, teenagers with

self-harming behaviors, high suicidal anxiety.

My normal conversations with clients include

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talking extensively about self-harm, suicide, access to

guns, casual drug use, shooting up, probation, physical

and sexual abuse. Can you imagine discussing whether or

not a client has access to means to take their own life?

Now imagine if you or one of your loved ones is one my

clients.

By holding off on changes to LPCs' scope of

practice and waiting for HB4325 to go through the

approval process you will ensure that thousands of

licensed professional counselors can continue to do what

we love, maintain access for the citizens of Michigan who

need prompt and professional care for mental health, drug

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and alcohol abuse, and other issues. Thank you.

LAURA MAMMEN: Hi. My name is Laura Mammen,

L-A-U-R-A, M-A-M-M-E-N. I'd like to first start by

saying that it's been a privilege to be in this room the

last few hours and listen to everybody and their moving

stories. It's been very moving to sit in this room and a

privilege to hear from all my colleagues and clients and

other professionals that are supporting us.

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I am a licensed professional counselor, a

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licensed marriage and family therapist, a nationally

certified counselor, and approved clinical supervisor. I

am also chair of the Board of Marriage and Family

Therapy, although today I'm not representing the board,

I'm representing my interest as an LPC.

I graduated from a CACREP accredited program

that focused on techniques. I have been practicing for

18 years now, and am a clinical program manager at a

nonprofit in Grand Rapids, Michigan. We primarily serve

children and families, mostly the Medicaid population.

We like to refer to it as mission-driven work because we

all know that we require such a high level of education

compared to the compensation that we get in our

profession.

I oversee six programs of different, serving

different children and their needs, and in five of six of

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those programs we employ counselors. And I am terrified

of losing those counselors because they would be unable

to practice. I speak with other nonprofits in Grand

Rapids and we are all having great difficulty finding a

therapist that we need to serve the clients in our

community. There's not enough therapists in our

community to meet all the mental health needs.

I am asking that LARA not move forward on

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putting the counseling techniques and diagnosis in the

education section. We need that in our scope of

practice. We need to identify a problem so that we can

treat it. Thank you.

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SARAH KOON: My name is Sarah Koon, S-A-R-A-H,

K-O-O-N. I attend today with grave concern related to

the proposed LARA rule change that will directly impact

LPCs in the State of Michigan. I practice as an LPC in

Kent County as a contractor for the local CMHC. And

without a doubt, the children, family and adults I, as

well as my colleagues, serve will be greatly impacted by

this rule change. Ethically I will be abandoning my

clients and morally I would be -- I can't read that

word -- oh, restricted from participating for the greater

good, which only puts the community in which I live and

serve, only hurts the community in which I live and

serve.

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The rule proposed by LARA is contradicted by

the over three decades of service LPCs have contributed

to the mental health communities in Michigan. And what a

shame it would be for Michigan to abandon not only 10,000

plus licensed professionals, but also leave 150,000 plus

patients without proper care or concern. I urge LARA to

slow down and allow for House Bill 4325 to pass. Thank

you.

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(Short recess had from 3:32 PM to 3:42 PM.)

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LEA DICKSON: Hello. My name is Lea Dickenson,

D-I-C-K-E-N-S-O-N. I am a student in the clinical mental

health counseling program. I'm almost halfway through

the program. Currently I understand that the language in

the rules and how it's understood is being

challenged/changed, that our profession is at stake of

losing our ability to diagnose and to use the term

psychotherapy. I find it slightly amusing that the class

that I am taking this semester is diagnosis and

conceptualization. So -- and here's the DSM-V to prove

it.

So, in this class we are trained extensively on

how to diagnose from a treatment plan, to conceptualize

cases, give a presentation, and conduct an intake

session. I'm actually working right now on a

presentation with a classmate, so I find this very

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baffling. Not to mention we will be thoroughly studying

every section of the DSM-V, which is same tool used by

other mental health professions.

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If we are being trained in diagnosis it would

make sense that we use it. Diagnosis class is required

to be taken by any student in the clinical mental health

counseling program, so why are you treating us like we

aren't qualified?

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Our American Counseling Association code of

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ethics also addresses diagnosis. It states that

counselors take special care to provide proper diagnosis

of mental disorders, techniques, including personal

interviews used to determine client care, locus of

treatment, type of treatment, recommended follow-up are

or carefully used. If we are not allowed to diagnose

then we're not able to ethically do the job we are

trained to do.

LARA's rule change will put us in direct

violation an of our code of ethics. If these changes are

made they will have drastic effects on the hundreds of

thousands of patients that seek care from counselors.

10,000 counselors will not be able to get insurance

reimbursement if we are not allowed to diagnose, leaving

us with no jobs and the need to move out of state. It is

wrong to leave hundreds of thousands of people without

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affordable care with suicide and the opioid crisis on the

rise.

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I plead that you rethink this change. And I

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also want to be able to counsel in the state in the

future, if these changes happen I will be forced to move.

MS. DITSCHMAN: Your time as up.

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HANNAH BONENFANT: Hello. My name is Hannah

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Bonenfant, spelled H-A-N-N-A-H, B, as in boy, O-N-E-N-F,

as in Frank, A-N-T. I am a second year student in the

clinical mental health counseling Master's program at

Oakland University. I am speaking before you today to

express my deep concerns about LARA's proposed rule

changes regarding counselor's scope of practice.

The majority of our work as counselors involves

diagnosis and treatment, or counseling techniques as LARA

puts it. And if we aren't allowed to provide those

services to our clients then we can't help them at all.

I understand that there is a substantial amount

of confusion about whether counselors are trained in

diagnosis and counseling techniques, but the truth is

that at our program at Oakland University all clinical

mental health counselors in that track are trained in

diagnosis and case conceptualization. And all

counselors, including school counselors, are trained in

the same theories of psychotherapy techniques that all

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other mental health counselors are trained in.

If LARA's rule changes were to be put into

effect counselors in the State of Michigan would be in

direct violation of the ACA code of ethics, E5, a proper

diagnosis, which requires counselors to give each client

a proper, carefully constructed diagnosis so that the

counselor can provide proper treatment and services to

that client. This would be akin to expecting a doctor to

treat a patient without knowing what is wrong with them.

It is an unethical, dangerous and impossible task to ask

of any mental health professional.

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This will leave over 150,000 people without

mental health services mainly due to an inability to pay

for their services of a psychologist or a psychiatrist,

who both charge exponentially more for their services

than counselors. Limiting mental health services to only

those who are wealthy enough to pay for them is simply

not a step in the right direction. Therefore, I urge

LARA to rethink their rule changes. Thank you.

AMENA KHAN: Good afternoon. My name is Amena

Khan, that's A-M-E-N-A, K-H-A-N. I'm currently a student

in the Master's program for counseling at Oakland

University. As a counselor in training and a resident of

Michigan my concern regarding these proposed changes is

linked not only to all the client but specifically the

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immigrant community of the state.

I have a personal connection to this community

as my immediate and extended family immigrated from

Bangladesh in the early 1990s. Legal entry into the

United States is a complex and extensive process. For

this reason my relatives immigrated at different points

in time. This disjointed travel with stressful, and

those who arrived first had the additional pressure of

being alone in a new country with an unfamiliar language.

At that time the Bangladesh community was still growing

and resources were limited.

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If LPCs from diverse backgrounds had been

available to this population of new immigrants they may

have eased the transition into American life. The

presence of LPCs in Michigan has been needed for decades

and continues to be a necessary means to address the

diverse mental health concerns of Michigan residents.

I was drawn to this profession due to the need

of mental health professionals in my community as well as

Michigan as a whole. The City of Hamtramck, which is my

hometown, contains Yemen, Polish, Bangladeshi, Albanian,

and Bosnian families, as well as a large Muslim

population. It is important to note that a cultural and

ethnic center, such as Hamtramck, demands culturally

competent counselors who have the ability to diagnose and

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treat as needed. How much time do I have left?

MS. DITSCHMAN: 30 seconds.

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AMENA KHAN: Another consequence of this

proposed change would be the inevitable loss of clients.

If clients cannot be diagnosed and treated at their

counselor's office they will reasonably look for other

professionals. However, many counselor serve clients

with insurance companies which may not be wildly

accepted. Leaving LPCs without the ability to diagnose

and treat would likely result in clients who may not have

other options for mental health care.

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I strongly encourage LARA to wait for HB4325 to

pass, as this bill would negate the need for any of the

proposed rule changes to LPC practice. Thank you for

your time and consideration.

LORI GOLDEN: Hi. I'm Lori, L-O-R-I, Goldin,

G-O-L-D-I-N. I'm an LLP and an LPC and I practice in a

rural Community Mental Health Agency in northern

Michigan.

Fifteen years ago I had something life-changing

happen to me. I made the decision to leave my

high-paying career in which I traveled around on a

private jet as a personal assistant to a very wealthy

family. I made the decision to go back to school. But

I'm not here to talk to you about my education because

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everybody in this room is educated. I'm not here to

discuss my two hour and twenty minute round trip. I'm

not here to discuss my student loan debt because

everybody here in the room has that. I'm not here to

discuss my financial concerns should I lose my job if

LARA made these changes. I'm not here to discuss my

highly trained and educational forte because everybody

here in the room is highly educated and trained as an

LPC.

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But what I am here to discuss is I am trauma

trained. I am the DBT consultation leader at my agency,

and I am EMDR trained. But I'm also here to assist my

clients. I have a caseload of 46 in my rural community

that I practice in. And if LARA makes these changes who

is going to take the calls of suicidal clients? Who's

going to answer the phone when they're calling me because

they have a knife in their hand and they want to cut or

they have a knife in their hand and they want to slit

their throat? Who is going to take the phone calls when

they want to overdose? Who is going to take the phone

calls when they want to put the gun in their hand and

pull the trigger? Who?

It won't be me because you will have changed

the rules and I'll be out of a job. So, I'd like your

phone number because you're going to have to take the

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calls of my clients because all of the LPCs in my agency

and all the LPCs in our state will be out of a job.

So, thank you for allowing me to speak and I

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hope you reconsider. Thank you.

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ISAAC WATTS: I am Isaac Watts, I-S-A-A-C,

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W-A-T-T-S. I have been an LPC for 15 years. I am a

private practitioner doing community work with the adult

and children's legal system. I am a member of the

community critical response team. I'm the only

African-American male Master's level clinician in the

Kent County Community Mental Health system. That's

psychologists, psychiatrists, MSWs, LPCs. I am it.

With Kent county I work as a crisis

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intervention therapist treating persons who are suicidal

and/or homicidal. In order to work with this population

I had to prove to the CMH that I could, that I had a

Master's degree in counseling, counseling psychology,

social work or psychology, that I was certified, licensed

to practice in the State of Michigan, that I was

credentialed through the Michigan Certificate Board for

Addictions Professionals, a thorough working knowledge of

the practices and principles of psychological, emotional,

sociological, assessment and diagnosis, thorough working

knowledge of professional ethics, standards and

practices, lived experience with mental illness, and the

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list goes on and on and on.

Leaving the Grand Rapids Theological Seminary I

was told that you wouldn't have the credentials and you

wouldn't have the education to be able to serve the

community. And when I went into Network 180 I proved all

those people wrong. I am able to assess and diagnose and

create treatment plans to help the most severe of the

people that we work with in our community.

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And I would urge -- and I would urge LARA -- I

would urge LARA to slow their roll and know that we are

more than capable in our education. If I, from lowly --

MS. DITSCHMAN: Your time is up.

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ISAAC WATTS: -- Grand Rapids Theological

Seminary, is capable of doing this work I know the rest

of us are capable to do it as well.

CLARISSA SANTANA: Hello. My name is Clarissa

Santana, C-L-A-R-I-S-S-A, S-A-N-T-A-N-A. I'm a counselor

training at Wayne State University.

Prior to joining Wayne State's counseling

program I was an advocate for a nonprofit organization,

and one of the clients assigned to my case was a

16-year-old that was suicidal. This teenager attempted

so many times to take their life, and the only thing that

was holding them back was the four point restraints that

they were in. One day as I sat with them, brushing their

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hair and talking to them they looked at me and said thank

you for caring, but you know I'm going to do this and I'm

going to be successful one day.

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I went home knowing that I wasn't trained

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enough to help them, that I didn't know the skills, the

techniques, any theories to apply to be able to help this

client. So, I researched and carefully selected a

program that was CACREP accredited, a program that is one

that is training me to become the licensed practicing

counselor that I aspire to be one day, one that is

training me successfully to become confident in my skills

and to be able to help clients these.

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I didn't do this for the money. I didn't do

this to get a title. I did this because I'm passionate

for mental health. I care about clients. And I hope

that one day I will be able to see what happened to that

client and to work with others just like them. I ask

that you support us so we can support our community.

Thank you.

DEQUINDRE JERNIGAN: Good afternoon. My name

is Dequindre D-E-Q-U-I-N-D-R-E, J-E-R-N-I-G-A-N. And in

2015 I began my journey to pursue a career as a licensed

professional counselor. The journey wasn't an easy one,

but I accepted the call to be challenged as a student at

Wayne State University. Now I'm at the finish line,

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currently completing my requirements for internship.

And the thought of House Bill 4325 not passing

not only terrifies me, but breaks my heart that

thousands, if not more, people will be without adequate

mental health care. For me this is not just about not

having a career that I worked for four plus years after I

graduated, this is about the future of mental health for

my community, the State of Michigan, and for my two

future children, which is why I wear these two ribbons on

my chest today.

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Don't take away the ability of LPCs to diagnose

patients and bill insurance companies. In doing so you

not only affect people currently in need of mental health

professionals but the generation of individuals yet to

come.

So, in closing, I just have one question. For

House Bill 4325 doesn't pass who's going to pay these

student loans?

CAITLIN FLEMING: Hello. My name is Caitlyn

Fleming, C-A-I-T-L-I-N, F-L-E-M-I-N-G. I'm a Master's

student at Wayne State University as well, in my last

semester, graduating, hopefully, in December.

My very first experience with mental health in

general was Court ordered counseling at the age of seven

for the effects that emotional and physical abuse had on

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my family, as well as addiction. I have seen many mental

health professionals over the course of my lifetime, even

through a suicide attempt at the age of 16.

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Eventually I met a counselor, an LPC

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specifically, who was able to help me as if nobody else

had, who demystified the process of therapy, who gave me

the skills and techniques in order to completely change

my self-esteem. As a child I was told that I was a

burden to everyone caring for me. It took me years to

gain the confidence you see before you today. I'm a

product of successful therapy of LPCs who diagnosed me

with major depressive disorder. I have the confidence to

call a public forum and invite House Representatives,

which two of them came, this week to show their support

for House Bill 4325.

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I'm dedicated to helping people in Detroit and

their mental health. I've heard that our response is a

little late. A little late is better than never. I also

wonder why we continue to struggle with climate change,

why there still is not clean water in Flint. There are

many things that we know are unjust, and yet, we have not

taken the action that we need to.

It's true that our profession has not united

before like we have today, but again, better late than

never. And just because these changes are not coming in

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November does not mean that urgency is not needed. Also,

there's been 40 years of precedent where diagnosis has

been a part of our scope of practice, and precedent is

formally recognized in the rule of court.

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Thank you very much. I ask that you please do

not pass these changes. They are detrimental to clients,

to mental health professionals, and everyone involved.

Please support House Bill 4325. Thank you.

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ERIKA MAGERS: My name is Erika Magers. It's

spelled E-R-I-K-A, M-A-G-E-R-S. I'm a licensed

professional counselor in addition to being a Board

certified art therapist. I am primarily an art therapist

and also licensed as a counselor because that's how we're

able to practice in Michigan. I have two degrees, over a

hundred credit hours in graduate studies. Everything I

had to do for counseling I also had to do the art therapy

version, so I have double the education in diagnosis and

counseling and therapy treatments.

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Since I became licensed I've continuously

worked with underserved and high risk populations. I've

worked as a therapist for adjudicated youth, for teens,

and for years doing in-home therapy for children with a

serious emotional disturbance diagnosis. I have worked

in private practice treating anxiety, depression and

PTSD.

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Currently I work for a Tribal Behavioral Health

Department. I am the only provider that does trauma

work. I serve in a six-county area. It is essential

that I'm able to continue to practice because there will

be no one else there to do my job. We currently are down

a number of clinicians in our department because there is

such a shortage of therapists in northern Michigan that

there are people without services.

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LPCs are essential for keeping people from

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committing suicide, preventing additional deaths from the

opioid crisis. I'm particularly concerned about my

clients and other people of color who will be

disproportionately affected by these rules because

counselors do serve the underserved population.

So, I just want to encourage LARA to hold off

with the rule changes and be mindful of how this will

affect the Native American community and other people of

color.

GREGORY HAYES: My name is Gregory,

G-R-E-G-O-R-Y, Hayes, H-A-Y-E-S. I am a licensed

professional counselor. I received my education from

Western Michigan University, a CACREP program, which

means that I am educated in diagnosing.

I'd like to take you back to a very warm

July 20th, 1969. My neighborhood was crowded around a TV

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set and we were watching men walk on the moon. And why

were we doing this? Because my father was one of the

lead engineers that designed the guidance system that got

us to the moon and back. And everybody congratulated him

on the work that he did. And he said you know what, it's

about the people that we serve. And that's what

counseling is about. It's about the people that we

serve. Don't rob us of that opportunity to serve.

Now I'll move forward to 2012, December. I

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graduate with my Master's. And my father said to me

remember, it's about the people that we serve.

MR. MacINTOSH: Just another reminder. We're

at the top of the hour, 4:00 o'clock. Again, the hearing

closes at 5:00. So, we have a couple more rows to go.

So, if you don't feel like you're going to get a chance

to speak you should certainly get your comments in via

e-mail or you can write them on your comment card. We

can set them up here right on the stage. So we're coming

on 4:00 o'clock, one hour.

DAWN WISEMAN: My name is Dawn Wiseman,

D-A-W-N, W-I-S-E-M-A-N. And this is a very emotional

subject for me, so please bear with me. I'm here to

represent adoptive parents and foster parents and

children out of the foster program.

And I would like to recognize my 12-year-old

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daughter who left the house with me at 6:30 today and has

the stamina to survive with all of us adults. She wanted

to come today because she thought, when she heard I was

coming, that it was important to hear, to be here and be

present. So, I am so proud of her for that.

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It is very hard to find services for our

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children that we adopt through the foster program. I am

an educated adult adopting children, and I am struggling

to find the services for my children. What I ask of LARA

today is I understand -- I'm a very literal person, and I

understand lining things up so they make sense and

they're across the board, but what I would like you to do

is look outside of the norm and join us in giving us the

support to our government elected officials to pass this

legislation that we so desperately need so that we are

aligned and we have the literal same verbiage. That

would be the way to send our energy in the way that would

best serve the laws and the people of our community so

that we continue to be served, we continue to be able to

work, and we continue to love and have long effective

lives for our children. Thank you.

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RONALD FLEMING: My first name is Ronald, my

last name is Fleming, F-L-E-M-I-N-G. I am an

African-American clinician. I'm going to say it one more

time. I am an African-American male clinician. There

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are not a lot of me. Okay? And you're going to take

what is LPCs African-American male and sideline this.

Okay? African-Americans are not in the system to help

make decisions like they should be.

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And so, when we start hollering words like

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institutional racism that's what these kinds of things

that are coming up now that we're talking about today, we

would include that in institutional racism because you're

going to take 10,000 people and remove them from the

system and the people that need them the most will not

have access.

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And there is a theory that's being tossed

around in the African-American community about trauma,

and they're stating that 80 percent of us are traumatized

from the Jim Crow era back. Okay? And so, in order for

that trauma to be evaded you're going to need people like

us, especially people like me and the African-American

clinicians that are in this room. Amen. All right.

KRISTEN DeLANGE: Hello. My name is Kristen

DeLange, K-R-I-S-T-E-N, D-E, capital L-A-N-G-E. I have a

Master's of Science in mental health counseling. I'm a

licensed professional counselor, a national certified

counselor, a certified advanced alcohol and drug

counselor. I've been a counselor for almost 11 years,

and before that I did several years of crisis work using

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my Bachelor's degree, a double major in psychology and

Spanish.

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Thank you for taking the time to listen to my

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testimony. I am really so grateful for everyone who came

to support us and our opposition of LARA's proposed

changes for counselors. This is changing our profession

identify. And I don't want to repeat all the coursework

that we have taken to give us the ability to diagnose and

utilize counseling techniques to service our clients and

our communities.

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One thing I have not heard in the hours that

I've sat here is since I speak Spanish I serve and work

with the Latino-Hispanic population, and they're a

grossly underserved population despite their enormous

presence in our state. And last night I was taking

pictures off my phone and I got an error message on a

computer that read catastrophic failure. And that is how

I see these proposed changes for our system, a

catastrophic failure, because our system cannot support

the amputation of 30 percent of our helping

professionals.

We need to be on the ground to help. Help us

work together. Work with us. We want to continue to do

our jobs and do it to the best of our ability to serve

our communities because it affects not only us, not only

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our clients, but their families, their communities, their

schools, their employers, and the criminal justice

system, and beyond. Help us to make Michigan better and

be part of the solution. Thank you very much.

RUTH SPALDING: Hi. I have a time here. Help

me out. My name is Ruth Spalding, R-U-T-H,

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S-P-A-L-D-I-N-G. I'm a licensed Master of social work

and a certified advanced alcohol and drug counselor. I

work in private practice that serves LBGTQ plus other

folks. We have a waiting list that's much longer than

three months, so the three-month figure has been put in a

lot.

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But I'm here as a colleague. And LPCs have

been operating in our system for three decades. They're

fully integrated into every aspect and layer of mental

health and infrastructure. I rely on my colleagues for

consultation, for support, for clinical coverage.

I know folks have talked about wait times for

clients, about abandonment, about suicide rates, the

opioid epidemic, but imagine forcing all of that on the

remaining providers who cannot possibly absorb clients.

Imagine not being able to find any clinical coverage or

being able to get any time off. Imagine the amount of

burnout that would increase. There's already burnout.

Let's get real about that. But the burnout, it's just

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not sustainable. Imagine the loss of depth and breadth

of knowledge from colleagues that would no longer be able

to give input on diagnosis or therapeutic techniques.

I've been blown away, by the way, for everyone

sharing their stories. All of that would be lost. So,

please delay and allow passage of House Bill 4325. Thank

you.

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TAMARA EPSON: Good afternoon and thank you.

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Excuse me. I'm very nervous. My name is Tamara

Epson(sp). I've been a fully licensed LPC for 12 years.

I was licensed in Georgia. I attended Georgia Southern

University and earned a Master of Science in clinical

psychology. I took courses in neuropsychology,

psychopathology, personality assessment, intellectual

assessment, developmental psychology, and psychotherapy

skills. These were the titles of my courses. That, in

itself, indicates that I am qualified to do what I do,

just as all of the people that have spoke before me have.

I moved back to Michigan with my family about

six years ago and I transferred my license from Georgia

to Michigan, and you told me that it was okay. I've been

doing this for six years. I've been an LPC. I've been a

supervisor.

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Currently I'm working in private practice.

Half of us are LPCs. Our practice will fall apart if we

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cannot continue doing what we are doing. This practice

is at risk of going out of business, and we have

currently a two to three-week waiting list. Psychiatry

in Calhoun County where I work has a three to four-month

waiting list. Other offices that do not accept Medicaid,

Medicare clients as we do, do not have the capability to

support what we do, to pick up our slack if we cannot

continue what we are doing.

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We are not seeking to expand our scope of

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practice. We are seeking to maintain the standard of

care that we have all been trained and overly qualified

to do for over 30 years. Please support HB4325. Thank

you.

FREDERICK HOGAN, II: My name is Frederick

Hogan. F-R-E-D-E-R-I-C-K, H-O-G-A-N, II. I am here on

behalf of 43 people on my caseload to give them a voice

since they're not even aware of what's going on in this

state. And if pausing or slowing down isn't an issue I

would just ask LARA to simply desist in harming the

residents of this state. Thank you.

ANTHONY SOLITRO: Anthony Solitro,

A-N-T-H-O-N-Y, S-O-L-I-T-R-O. The opportunity to speak,

thank you. The opportunity to have a voice, to be

listened to, that's what we do. Right? That's what

we're all about. Right? For Michiganders, for the

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people of our state. The power to listen.

As a licensed professional counselor using

knowledge and education, skills and training, Diagnostic

and Statistical Manual, of course, trauma training, I'm

daily struck by the opportunity and the continued need

for what we do. I've heard numbers, numbers this week,

like 150,000 human lives, clients, would be affected in

mental health crisis if this tragic ruling goes through.

The debate over what I've now determined comes

down to the nomenclature, the title of our license mode

of practice, not our education or skill set. And

selfishly, I was driven to think of my own clients, the

people I've come to know, to see grow, to be healed, to

achieve lasting progress and freedom from the effects of

trauma through my and my colleagues' skill and

empirically-based techniques.

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And most importantly, for those whose journey

is far from over, and imagine telling them that in the

midst of their crisis, in the midst of an era of

epidemics like the opioid crisis and teen suicide

epidemic. And the courage of such victims to speak out,

that their skilled mental health clinician must turn them

away because they simply chose the wrong mental health

professional to go to.

I heard this presiding body, and our decency

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and our objectivity, please, if not for the thought of

us, let your conscious rule be on behalf of the client,

on behalf of the people, on behalf of Michigan. Thank

you.

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URSULA BROWN: Hello. My name is Ursula Brown.

I am an LPC in Detroit, Michigan, and I am in private

practice, so this will directly affect me. My whole

business will be gone, and the 70 people that I serve

will be without a therapist.

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I'm also unique. I'm a woman of color, and

there's not that many of us. Nationally

African-Americans are 20 percent more likely to be

diagnosed with mental health issues. And the biggest

barrier is because they don't find people who look like

them. It is a cultural barrier. The majority of my

clients are women of color like me, and that's why they

came to me, because they felt comfortable that I would

understand what they were going through. I want to be

able to continue my work.

I went to a CACREP accredited college. I did

everything in good faith. And now you're telling me that

it's not good enough. What more do I have to do? I'm

looking at this impact statement, and all the things,

you're actually increasing the requirements of what we

have to do in order for us to prove that we are able to

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basically do clinical work. And yet, and still, you're

taking away diagnosis. That doesn't make sense.

I would like for you guys to really look at

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what you're doing. Look at how this is going to affect

the people. And please look at what you're actually

asking of us, because if you want us to do more then you

also need to do more as well.

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Just allow us to do the job that we have been

asked to do, that we've did, that we did in good faith.

We did everything that was asked of us. I don't want to

leave the women of color without another woman of color

to basically serve them.

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MS. DITSCHMAN: Your time's up.

NASREEN PAYTAS: Hi. My name is Nasreen

Paytas, N-A-S-R-E-E-N, P-A-Y-T-A-S. I'm an LPC from

Midland, Michigan with Stillwater Professional

Counseling. We're all LPCs. I love what we do, as we

all do. But it's not about me.

You know, we all submitted paperwork to LARA to

get licensed and there was never an issue. In our

disclosure statement we kind of have to say what we do,

how we do it, and if there's any problems where to send a

complaint to. And LARA, with that disclosure statement,

issued our license. Beyond that it's almost like a bait

and switch. You go through the education, you go through

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everything that is required, you submit the paperwork,

and then sorry. I understand.

I was in child welfare program manager for

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foster care licensing. I understand the legislative

rules and statutes. There's the precedent that we have

diagnosed. We have done treatment plans. We do

interventions. We are good at what we do. But how can't

LARA bring the precedent and work with the legislature to

make this right, not just for us. I mean, yeah, it's our

livelihood, it's our vocation, but also, mostly, greatly

for our clients.

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That yes, there's the hardest, the most worst

cases, but there's also people just like you and I who

just need a little bit of help for a little bit of time.

And we do that for them, too.

MS. DITSCHMAN: Time's up.

NASREEN PAYTAS: Thank you.

MOLLY SOWELS: Good afternoon. Thank you for

having us all here. My name is Molly Sowels. I am an

MMA, LPC, licensed in the State of Michigan. I'm also

licensed as a trauma focus cognitive behavior therapist,

also certified by the State of Michigan to do this

therapy with children who have been traumatized ages 7 to

18.

So, two minutes is what we're allowed to talk,

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120 seconds, the time allotted for me to speak today. By

the time I'm done speaking in that two minutes research

tells us that three people will have suicided. Current

statistics show that every 40 seconds someone suicides.

It is also a fact that suicide is the second cause of

death for our young people age 15 to 24 in the State of

Michigan.

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Recent research from America's health rankings,

the annual report in 2018, tells us, quote, suicide may

be prevented through strategies that empower individuals,

families, and communities, including, number one,

improving clinical and community preventative services;

number two, enhancing treatment and support services.

And I question today what the hell's going on

when we're actually decreasing. The proposed changes

that LARA's making are actually, they will decrease

preventative services, including all of the LPCs.

You've heard the numbers, 10,000, 150,000

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people affected. And we will be doing the opposite, we

will not be enhancing treatment and support services.

And I would speak to -- I don't care at all to talk about

myself or my education, my profession. I can find

something else to say. But all of the people that would

be affected, it's tragedy. It's tragedy that's going to

happen.

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HANNAH FADIL: My name is Hannah Fadil,

H-A-N-N-A-H, F-A-D-I-L. And I'm currently a graduate

level mental health counseling student at Grace College.

And after I graduate I plan to pursue licensure as a

licensed professional counselor in the State of Michigan.

First off, I'd like to extend my greetings and

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gratitude to LARA for allowing myself and others to

testify on behalf of LPCs and LPC students as myself.

The program I am currently attending is a CACREP

accredited program, meaning that in order to graduate

from the program I am required to be proficient in

identifying mental health disorders as identified by the

DSM, creating treatment plans, and using psychotherapy to

treat those disorders. I must also be able to provide

group counseling.

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These required proficiencies for all

counselors, regardless of specialization, are stated

clearly in the CACREP standards, which I provided for

you. I have also taken the liberty of underlining where

in the CACREP standards it is written that all CACREP

approved counseling programs, whether Master's level or

doctoral level, and regardless of specialization, are

required to teach their students how to properly diagnose

and treat mental health disorders, as well as use proper

assessments and psychotherapy techniques when treating

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clients. This means career counselors can diagnose.

The information that I have mentioned can be

found in the CACREP standards on Pages 10 to 14. The

original document can be found on the CACREP website

under resources.

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My question to you, if CACREP and LARA, in the

education section of the rules, as a counseling student

to learn how to properly diagnose mental health

disorders, is required, and as well as learning to use

the prior psychotherapy techniques, if all that's

required why are you limiting my ability as a counselor

to practice what I've learned and am qualified to do,

then what is the point of my education? Is not the point

of education to impact the world?

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I will be fully educated and qualified to

assess and diagnose mental health disorders. I will be

fully educated and qualified to treat clients who are

suicidal, fighting addiction, struggling with PTSD,

suffering from anxiety, et cetera, et cetera.

MS. DITSCHMAN: Your time is up.

HANNAH FADIL: Thank you so much.

KERRIE CLARK: My name is Kerrie Clark. I'm a

licensed professional counselor with a private practice

in Grand Rapids. I currently have 60 clients.

93 percent of my clients use insurance. I see people of

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all ages for a lot of issues, but I specialize in working

with people with trauma, especially children and

transgender individuals, people that are underserved and

the most vulnerable.

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Cutting my clients off from services would not

only be a difficulty for many of them but could also be

dangerous, as has been discussed because many of them

will become suicidal when one of the only people that

they trust in their life abandons them. As proof of

this, of how some people don't have the support network

that they need, I have a message from a client of mine

earlier this week that said thank you for being more than

all I have some days.

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Everyone has been very selfless in their

clients today. I'm going to be a little selfish for a

second. Because losing the ability to charge insurance

would be personally devastating as well. I've been in

private practice for over six years. I'm very proud of

the business that I have created. I am proud that I got

my Master's degree. I had all the right training. I did

what I was supposed to do. And now through no fault of

my own I could lose everything I worked for.

I just moved into a new building with three

other LPCs. We signed a seven-year lease with a

30,000-dollar build-out, amortizing that lease. So, not

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only would I have to close my shop, but I would have no

way to pay a bill that I would still be charged with. I

am also the main breadwinner for my family of three. I

have a four-year-old son. We lead a modest but

comfortable life. If this goes through we will be

completely dependent on the State and would probably lose

our home and have to move in my with my mother at age 36.

MS. DITSCHMAN: Time's up.

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KERRIE CLARK: So, please pause on these

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changes. Thank you.

BRYAN FUNK: Good afternoon. Thank you for

your time and opportunity. My name is Bryan Funk,

B-R-Y-A-N, F-U-N-K like the music. I am an MA licensed

professional counselor and have been in Michigan for 15

years. And I'm a licensed mental health counselor in the

State of Indiana, which I have been for the last 20

years.

I am highly educated. I have a Master's degree

in applied behavioral science, a Master's degree in

counseling, a dissertation short of a Ph.D. in counseling

education supervision. I've worked for 26 years in the

field of juvenile justice and child abuse and neglect.

I'm currently in my position for the last 18 years,

providing therapy to juveniles who have sexually

offended, in addition to being abused and hurt and

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traumatized and locked in bird cages in their lives.

In that years of experience there is very few

in Michigan who treat juveniles who have sexually

offended. It's not a population most people raise their

hand and go yup, that's the one I want to work with. It

seems very difficult, and it is every day.

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I have three therapists I supervise in my

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practice and office. Two of them are also LPCs in

addition to that. So, our entire facility pretty much

would be shut down and no treatment. These young men

will have to go somewhere, likely back to the community,

again, not served by LPCs, which literally places the

community at risk. Thank you very much.

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LAURA MAES: My name is Laura Maes, L-A-U-R-A,

M-A-E-S. And I'm a licensed professional counselor and a

nationally certified counselor. I've been in the mental

health field since 2008. During this time my job as a

home-based counselor also allowed me to spend so much

time advocating for my clients in court that I was deemed

an expert witness by the Courts in my county due to my

ability to diagnose and counsel.

I'm able to use the trauma focus cognitive

behavioral therapy modifier as I've been recognized by

the State of Michigan as having completed my training in

TFCBT. I've also completed training to supervise limited

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licensed professional counselors. I've previously been

an outpatient therapist for six years. In January of

2019 went into private practice.

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Before I knew what was going on with this I

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bought a building because I'm expanding rapidly, that I

needed more space and was planning on hiring more staff

to help with the waitlist we currently have in Jackson

County of people needing mental health services. I

currently have a caseload of approximately 50 people and

have added an extra day to my practice to see clients.

I believe that the number of 100,000 clients

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being affected is low, as I'm not sure how many of the

10,000 LPCs only have 10 people on their caseload. The

repercussions of losing 10,000 clinicians is astronomical

to me, along with being neglect. I should also ad that

our local CMH is made up of 56 percent of LPCs of their

clinical staff.

If we lose our ability to diagnose and practice

within our current scope this would mean that we no

longer be able to do what we have been doing and we would

have to cease seeing our clients or face the possibility

of being sued by the department. It we stop seeing our

clients we could be accused of abandonment. We are in a

terrible situation in either of those scenarios.

I could not only lose my business but my home

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due to the loan I've taken out to get the building, on

top of having to pay back student loans for a degree that

I will not be able to use. I'm sure that I'm not the

only one that is in this type of situation, as one of my

colleagues has recently bought a house.

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MS. DITSCHMAN: Your time's up.

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LAURA MAES: Thank for your opportunity to

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speak.

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MESHIA SCHULTZ: Thank you for giving me an

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opportunity to talk. My name is Meshia Schultz,

M-E-S-H-I-A, S-C-H-U-L-T-Z. I'm an LPC. I also have my

NCC. I actually practice right here right in Old Town

right down the road. So, this place I frequent.

I just wanted today say a couple things. I

feel like a lot of things have already been said. I have

80 clients on my caseload. I have a private practice. I

see an average of 35 clients per week. 60 percent of my

caseload are children. And that increases -- I mean ever

every time an adult leaves my caseload a child comes on

my caseload. Like many of us, I work five to six days a

week. I work late nights. The children that I see I

can't just terminate. They are Court-appointed to me. A

Judge signs a piece of paper, sends them to me. They are

required to see me. They can't just get a new counselor.

And I am so worried about what's going to

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happen to them. They're experiencing abuse and divorce

and neglect. These are the kids that break my heart.

But we celebrate every single day. And I get messages

and they do well in school and they finish full days at

school.

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I just want LARA to just step back and pause,

but really reflect on we all have the education here. We

all have great educations. I graduated from MSU, dual

specialization in community counseling and school

counseling. We have the skills. We just want to keep

doing what we're doing. Thank you.

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MELISSA SATTI: Good evening. My name is

Melissa Satti, M-E-L-I-S-S-A, S-A-T-T-I. I thank LARA

for allowing me to speak today. I'm a licensed

professional counselor, certified clinical trauma

therapist, and EMDR therapist, as well as a trained

clinical supervisor and small business owner. I

graduated from Eastern Michigan University.

I speak to you today in reference to the small

business section, specifically Items 19 and, 24 which

both indicate no harm to small businesses. And that the

proposed rule changes are for individuals, not

businesses. To clarify, our license is our business. My

license has offered me the ability to build a fairly

large group practice in Ann Arbor, Michigan. You can't

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throw a rock in Ann Arbor without hitting a therapist.

We're actually, we have more clinical

therapists per capita than any other county in Michigan.

But despite that, my practice, which employs 24 staff

members, 20 of which are clinicians, are full. And we

are constantly getting referrals from outside agencies.

We see 825 active patients right now, 75 of which are

women and children. But the economic impact that this

could potentially have impacts businesses like mine,

which would not be able to survive without 60 percent of

the clinical staff that I employ since they are

counselors.

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It won't just impact them, it will impact the

social workers, administrative staff, the medical biller,

psychiatric nurse practitioner, and medical assistant

that work for me as well. We have mortgages to pay. We

have rents that we lease out. We have bills to pay,

educations to fund for our children. It will impact our

livelihood.

I urge you not to pass any changes to the LPC

licensure as what you are doing is actually limiting our

scope of practice which we've been doing for 30 years --

MS. DITSCHMAN: Time is up.

MELISSA SATTI: -- and allow HB4325 to pass.

Thank you.

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MELANIE POPIOLEK: My name is Melanie Popiolek,

M-E-L-A-N-I-E, P-O-P-I-O-L-E-K. I'm an LPC, a NNC, a

Ph.D. candidate writing my dissertation, an adjunct

instructor at Oakland University teaching in person

addictions, and a supervisor. I also work at Grace

Counseling in Chesterfield. My whole life is counseling.

I had the great honor of serving my profession

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as past president of the Michigan Counseling Association

and as a past chair of the midwest region of the American

Counseling Association. My whole life is counseling.

As a dedicated practitioner who works primarily

through the lens of feminist theory I am here to talk to

you specifically today about the disparate impact the

rule changes would have on Michigan women, specifically

women business owners.

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ACA reports that 74 percent of their members

are women. Think about that as a snapshot of our

profession. It indicates clearly that our field is

comprised largely of women. The success of women is

important. When women do better their families and

communities do better. Multiple studies show the

intergenerational impact of class, mobility and families.

This means that the proposed changes that LARA's

considering today will have an impact for generations.

This is why LARA needs to consider everything they're

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hearing today very carefully. A large number of our

current and future citizens of our state depend on it.

Personally eliminating my ability to practice

will bankrupt my family. My husband needs a kidney

transplant. My son has a condition called PKU that

requires medications that cost $7,500 a month paid for by

insurance that I won't be able to afford if I can't work.

I'd also like to address something I recently

heard in the news I believe through NPR. I don't have

the quote, but it read something like a LARA

representative said that these rule changes have been

proposed for years, but LPCs hadn't responded adequately,

so it's too late now, it's our fault, we shouldn't be

complaining. I'd like to say there's a difference

between making information available and making it

accessible. A lot of us didn't know about this until

recently.

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MS. DITSCHMAN: Your time's up.

MELANIE POPIOLEK: So, I would say that

indicates that maybe LARA needs a little more

transparency.

HEATHER O'FARRELL: Hi. My name is Heather

O'Farrell, O, apostrophe, F-A-R-R-E-L-L. I'm currently

in my Master's program at Central Michigan University

where I'm doing my internship. I think it goes without

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saying the amount of training that I've had to get to get

to this point where I'm able to see clients, diagnosis,

counseling techniques, everything that's already been

stated.

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I can't tell you how many nights I have missed

putting my four-year-old son to bed because I've had a

crisis call with a client at the women's center that I

work at where they have suffered domestic violence or

sexual assault and had to be for with them and miss out

on my own child. I can only imagine what other LLPCs or

LPCs have had to sacrifice to be there for the client and

to be the voice that they need.

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I just wanted to say that these proposed rule

changes would be a slap in the face not only to the hard

work that I have put in so far as a student, but to all

the hard work that is put in by other LPCs and LLPCs, and

also to the clients who depend on us for services and to

be the voice for them. Healing is not linear and I feel

that neither should our rules. Thank you.

ALYSSA MONTAGUE: Hello. My name is Alyssa

Montague, A-L-Y-S-S-A, M-O-N-T-A-G-U-E. And I am a

licensed professional counselor and a certified advanced

alcohol and drug counselor. I graduated from Spring

Arbor University in 2012, where I was fully trained in

diagnostics and counseling techniques. I'm the first

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person in my family to have a Master's degree. I am the

primary provider for my family, and I have two small

children.

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I am here to support HB4325 with no amendments

and ask that LARA make no changes at this time to our

rules because doing so LARA will be changing our scope of

practice. The change will impact LPCs personally and

professionally. It will be devastating to our clients.

LARA will cause unnecessary harm to our clients.

I have been working in the front lines of our

current drug crisis. I have worked as the primary

clinician in an adult community corrections program that

focused on opiate addiction, and was one of the first of

its kind in the state, and in multiple juvenile

residential centers across the state.

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I currently provide substance use treatment

through the Michigan Department of Corrections and work

as an outpatient clinician for a nonprofit substance use

center where I provide services primarily through

Medicaid and Midstate Health Network.

According to NIDA, in 2017 there were 2,033

overdose deaths involving opiates in Michigan. That's

over 263 deaths per day. That is roughly 11 people per

hour since we started today. Consider what these numbers

will be if we remove a third of our mental health

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practitioners.

I recently received a card from a

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seven-year-old daughter of one of my clients saying thank

you for giving me my mother back. Her mother was a

long-term IV opiate user and she recently lost her father

to an opiate overdose.

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This is more than a profession. This is not a

job. This is passion. This is love. We love what we

do. People need us. LPCs are -- like --

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MS. DITSCHMAN: Your time is up.

ALYSSA MONTAGUE: -- we are irreplaceable and

we save lives. We're not going anywhere.

RENISHA SIMPKINS: Greetings. I am Renisha

Simpkins, R-E-N-I-S-H-A, Simpkins, S-I-M-P-K-I-N-S.

Eighteen years experience in mental health. Female

African-American minority. I own practice in Clinton

Township, Michigan called Out of Mind Counseling Center.

I earned my education from a CACREP accredited

university, as some other people here. And I'm duly

licensed in the States of Arizona and Michigan.

Listen. Any mental health provider, whether

they're a psychologist, psychiatrist, LPCs, MSWs, know a

few things about our ethical code, which you've heard

today, which is do no harm. Okay? If you was to change,

LARA was to change the actual way it's written right now,

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it's a semantic thing to me. What I mean by semantic is

literally about just simple language in it, accurate,

initial inaccurate interpretation of a view of what LPCs'

scope of practice is and the education that we have.

If a rule of LARA is changed now before

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legislation approved House Bill 4325, before that to take

effect, you got over, all you heard today, over 160,000

people will be impacted. As a matter of fact, the truth

is I think we need more LPCs. Okay? We need to update

that record. We need unity now, not division, with all

mental health providers.

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And now even more with LARA, I ask you, LARA,

the State, we pay every year, we get bills when it's time

to pay. Have our back in this. We need more people on

the front line because Michigan is in a crisis of mental

health providers. And the truth is these LPCs today are

educated, qualified, know how to diagnose, and we're on

the ground doing the work. So, we just ask for your

support. Support HB4325. And thank you for you time

today.

HAROLD SEARCY: My name Harold Searcy. I am

not an LPC.

COURT REPORTER: Excuse me. Can you spell your

last name?

HAROLD SEARCY: S-E-A-R-C-Y. I'm aware of

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something that I heard no one else mentioned. First of

all, with the amount of power that lawmakers possess

comes immeasurable responsibility. But the truth is,

whether you are merely a layman such as myself or a

legislator in the position of great power, you, like me,

are either good or evil, for the people or against the

people, you care or you don't care. Unfortunately, if

you choose not to care then you made the choice to be a

mass murderer because hundreds of people who would die,

commit suicide, kill, scenarios that are preventable when

they have LPC counselors leading them back in the right

direction.

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I can't say that someone in the top 1 percent

slipped you a check to make the decision to aide in the

genocide of the mentally ill, but that's what your

decision will amount to. It's amazing to me that some

humans are more sympathetic to animals than their fellow

man. If you, for whatever reason, decide to not

empathize with the LPCs community because of your

personal payola or whatever was more important to you, or

your bottom line, good luck trying to sleep at night

because you choose to still kill and destroy just like

Adolf Hitler. That's exactly what you'll be doing.

Thank you.

HEATHER LAFOLLETTE: Good evening. My name is

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Heather Lafollette. Last name is spelled

L-A-F-O-L-L-E-T-T-E. I am an LPC, and I've been working

in the field for the past 11 years. I graduated from

Oakland University in 2008, which is a CACREP accredited

program. I have primarily been working in a Community

Mental Health agency. I provide training to new

therapists, to interns, and I provide services for our

clients. I've worked both as a supervisor as well as a

therapist. I've also done contractual work, and I've

also just recently in the last five months opened my own

private practice.

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These rules that are proposed that would change

our scope of practice are going to affect everything,

everything that I do, everything that all LPCs do. And

yeah, it's about us, but it's more importantly about the

clients, and I think that's what the focus is, is that

all of the clients, 150,000 or more, are going to be

affected by these changes in taking away our ability to

provide the services that we do. This is why we need

HB4325 to pass and we need it to go through before these

rules. Thank you.

DONNA WIDMAN: Hello. Thank you so much for

the opportunity to speak with you. My name is Donna

Widman, and that's D-O-N-N-A, last name W-I-D-M-A-N. And

I am a licensed professional counselor and nationally

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certified counselor. I've been in private practice for

11 years and recently opened my own private practice,

small business, in May of this year. Currently I serve

about 45 clients myself. So, I think that number of

150,000 affected is grossly underrated. I think there's

going to be a lot more.

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Approximately 90 percent of my clients can only

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afford counseling by using their medical insurance. I

serve clients from lower socioeconomic backgrounds, first

generation immigrants who put their trust in us as mental

health professionals, to see them in crisis, suicide

prevention, grief, chronic mental illness, anxiety,

depression, and more. If the proposed rules changes from

LARA are to occur these clients would suddenly be left to

seek out mental health services in other places that are

already overflooded, and many of them would not get care,

which would put them in a crisis situation.

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LARA and licensed professional counselors share

a common goal of keeping our clients in Michigan, keeping

people in Michigan safe. Our clients have placed their

trust in LPCs. Now, we, as LPCs, place our trust in

LARA, that with a better understanding of the impact that

your decision will have that you will vote against these

proposed changes and let us do our job. Thank you.

GINA HARDY: Hello. My name is Gina Hardy,

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G-I-N-A, H-A-R-D-Y, and I'm a licensed professional

counselor. I live in Macomb and I'm a partner in a

private practice in Madison Heights, where I've been

practicing for the past seven years.

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In my private practice, with my nine other

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clinicians, we see approximately 200 clients per week.

Everyday we are fielding phone calls from perspective

clients who we are routinely trying to find referrals for

or are placing them on a waitlist, as we are consistently

to capacity on our caseloads. Among the clients we see

weekly are individuals who are dealing with trauma,

suicidal ideation, depression, anxiety, and a list of

other mental and emotional disorders.

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I have great concern for these clients if the

proposed rule changes were to go into effect and I am

unable to provide services as I have in the past seven

years to them. Currently we're struggling to find

counselors and psychologists for the volume of clients

that our office has. Taking away 10,000 licensed

professional counselors would only increase the deficit

of mental health practitioners that our state already has

as we face increased suicide rates and addictions.

In addition to the detriment this would cause

to my clients, whom would overnight lose their access to

their counselor, it would force my small business to shut

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down. Counselors' inability to work and losing our

livelihood has far-reaching impact that expands beyond

mental health, but to all of the other businesses that

support my small business, such as my landlord and

biller, to name a few.

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I respectfully request to stop or delay the

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implementation of the proposed rules to allow the HB4325

to make its way through legislation, which would bring

the statute in line with the administrative rules. Thank

you so much for your time.

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CHRISTIN McFADYEN: Hello. Thank you for the

opportunity to speak. I'm trying to go to go quickly so

as many of us can speak before the 5:00 o'clock hour. My

name is Christin McFadyen, C-H-R-I-S-T-I-N, McFadyen,

M-C, capital F, as in Frank, A-D-Y-E-N. I'm a licensed

school counselor, I am a national certified counselor,

and I am an LPC. I received my Master's in the

counseling CACREP program at Northeastern Illinois

University. And I have been a counselor in Michigan

going on seven years.

I have rewritten this, I don't know, maybe 20

times as I've been sitting in here today, as I'm hearing

story after story after story that is exactly the same as

my own. And so, while I'm still going to repeat some

things that you heard, I'm going to change it a little

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bit, anyway.

I could tell you about my experience working

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with youth as a high school and middle school counselor

for six years, but, instead, I have some questions for

LARA. For decades before I even joined the counseling

field it's been interpreted that counselors can diagnose

and treat. I'm trained to diagnose and treat. LARA says

that we should have known that this was coming, but I

received no notification from LARA. I found out through

FaceBook that this was going on, not through my licensing

agency.

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And you say LARA says that they are not taking

away anything that we do, that we never should have been

able to do this. Then why have we been practicing for so

long, and why have hundreds of people been her telling

you how we treat and diagnose patients who need help?

That shouldn't be an issue then.

Whole universities have brought training around

this interpretation of the rule. And so, you're ignoring

30 years of precedence and saying that maybe we shouldn't

have been able to do this, but we have been and we are

doing it and we're killing it. We are making a

difference. And so, you can't say that you're not

stopping us because you are stripping away our right to

help people.

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Please stop with the proposed changes and

support HB4325. Thank you.

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BRAD MESSENGER: Good afternoon. My name is

Brad Messenger. That's M-E-S-S-E-N-G-E-R. I'm the CEO

of Clinton County Medical Center Psychological Services,

Gratiot Psychological Services, Midland Psychological

Services, and Carson City Psychological Services. I have

an MSW from MSU. I've been working for 11 years in the

field, and I have 10 years of small business experience.

My position is unique because I employ and

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supervise licensed psychologists, MSWs, and LPCs alike.

I currently have 43 providers working for me, and I

oversee 100,000 individual psychotherapy sessions a year.

I am personally million dollars in debt to provide mental

health care to underserved populations.

These changes would remove a third of my valued

staff and one-third of my gross receipts, or $2.3 million

in insurance reimbursement this year alone. I want to

know who does it benefit to remove 2.3 million in

insurance payments from a small business that's just

trying to provide treatment? What will I tell the

families that we treat? How will I keep track of my

families? How will I help my work families be supported?

How will I pay them their hard-earned money? How will I

sit them down and tell them that they're fired? In a

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world where money talks, with this kind of money being

saved by insurance companies who is really benefiting

from denying services to the needy? Insurance companies

are for-profit organizations who stand to make millions

of dollars from these changes, and this is not a

coincidence. Thank you.

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CASEY SLAGER: Okay. My name is Casey Slager,

C-A-S-E-Y, S-L-A-G-E-R. Thank for letting us speak

today. I am an LLPC. I left my work as a teacher to

spend three long years completing over 60 credit hours as

a student in the counselor education program at Western

Michigan University, a CACREP accredited program.

Standing here today I have the training

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required by CACREP that is recognized by the ACA and was

made official by LARA. In fact, I was granted my LLPC so

recently, September 16th to be exact, that I just

received an e-mail from LARA asking about my satisfaction

with the licensing process.

I will be honest. I was nervous about the

process. I made a small typo at the bottom my

professional disclosure statement. I said complaints

could be sent to Landing, Michigan instead of Lansing.

What wasn't a typo was when I made clear my intention to

assess and diagnose clients and use psychotherapy

techniques to address mental health concerns.

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Incidentally, neither of these things prevented me from

getting my LLPC.

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I'm a life-long citizen of Michigan. I'm also

a life-long client. I owe my life to the LPCs who have

been there for me. I have, after years of work and

dedication, finally reached the point where I can give

back to my home state. I want to contribute to the

mental health of the 150,000 or more clients receiving

counseling. I want to keep seeing my own counselor.

Please do not pass these rule changes. This

change will render my training, my license, my massive

student loan debt all useless. The ramifications will

ripple far beyond counselors and their clients alone.

MS. DITSCHMAN: Your time's up.

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CASEY SLAGER: Thank you.

HEIDI ZABIK: Hello. My name is Heidi Zabik,

H-E-I-D-I, Z-A-B-I-K. I am the proud mama bear of

Kathryn Zabik, K-A-T-H-R-Y-N, who I am speaking for her

today. She has asked me to read this message.

My name is Kathryn Zabik. I received my

Master's of arts in counseling from Oakland University in

2011. I am an LPC and nationally certified counselor. I

have been certified in trauma-focused cognitive

behavioral therapy in Michigan since 2014.

The stigma of mental health is already too much

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of a barrier and a deterrent for people in need of

treatment. It takes our client a significant amount of

courage just to take that first step when they initiate

psychotherapy. As skilled practitioners we seek to

empower them as they develop trust.

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When clients face their trauma it is not

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uncommon for them to experience an increase in symptoms

for a period of time during their healing process, and

they are counting on our alliance to guide them as they

work through all of that pain. The commitment to healing

can be an ongoing challenge for them. If clients are cut

off from the LPC at any point in their healing process as

a result of these rules changes it will be an entirely

new trauma for them directly associated with their

experience of the therapeutic process. Even a temporary

suspension of the services triggered by your rule changes

will cause devastating and irreparable damage.

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This impending tragedy is entirely preventable

if you would please just delay the filing of the rule

changes so that HB4325 has the time it needs to pass into

law. Please protect our mental health warriors.

Hundreds of thousands of people in Michigan are counting

on you. Please don't let us down. Thank you.

RYAN ZABIK: Hello. My name is Ryan Zabik,

last name Z-A-B-I-K. And while I'm an engineer, I'm

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actually not here to talk about the civil engineering

rule changes. I am here to support my wife and to talk

about the proposed rules changes that will affect her and

the thousands of other LPCs throughout the State of

Michigan, as well as the thousands of clients that they

serve.

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I urge LARA not to implement this rule change

or, at the bare minimum, delay it until the house bill

has gone and been passed fully into law. As I'm sure

many have said already, the impact upon these counselors

in this community, in Michigan would be absolutely

catastrophic. There are many Michigan citizens dealing

with complex emotional issues, thoughts of suicide.

These counselors are often the only people holding these

citizens back from the edge. Do not tie their hands even

for a moment behind their backs or else we will all lose.

If even me, as an ordinary citizen and as a

husband, if I can see how clearly and desperately we need

these LPCs in this state, then surely LARA can see this

as well and stop this rule change from going into effect.

I urge you to stop this and just stop this nonsense.

Thank you.

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MS. DITSCHMAN: It's now 5:00 o'clock. The

hearing is closed.

(Hearing concluded at 5:03 PM.)

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CERTIFICATE

2 STATE OF MICHIGAN)

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)

4 COUNTY OF INGHAM )

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I, Claudia M. Weekly, Certified Shorthand

Reporter, do hereby certify that I reported

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stenographically the proceedings had in the above

entitled matter, at 525 West Ottawa Street, Lansing,

Michigan, on October 4, 2019; and do further certify that

the foregoing transcript constitutes a true and correct

record of my stenotype notes.

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____________________________________

Claudia M. Weekly (CSR-2963)

Notary Public, Genesee County, MI

My commission expires: March 6, 2025

19 Dated: October 14, 2019

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