Author Archives: Jeffrey Lynne

About Jeffrey Lynne

Jeffrey C. Lynne is a South Florida native, representing individuals and business entities relating to licensing, accreditation, regulatory compliance, business structure, marketing, real estate, zoning and litigation pertaining to substance abuse treatment facilities and sober living residences. Mr. Lynne has been recognized across the region as a leader in progressive public dialogue about the role that substance abuse treatment has within our communities and the fundamental need and right to provide safe and affordable housing for those who are both in treatment for addiction and alcoholism as well as those who are established in their recovery.

BREAKING NEWS – Google Reinstates Ads for Addiction Treatment Centers, With Pre-certification by LegitScript

Google will start accepting ads for addiction treatment centers again, Reuters reports. The company suspended the ads in September after The Verge reported that Google ads were being used to direct people to shady addiction treatment centers and away from legitimate facilities. Starting in July, treatment centers can run ads on Google but only after they’ve been vetted by LegitScript, a firm that also verifies online pharmacies.

Google told Reuters Monday it would resume accepting ads from U.S. addiction treatment centers in July, nearly a year after it suspended the lucrative category of advertisers for numerous deceptive and misleading ads.

According to the just-released revised advertising policy press release from Google:

In May 2018, Google will update the Healthcare and medicines policy to restrict advertising for recovery-oriented services for drug and alcohol addiction. This policy will apply globally, across all accounts that advertise addiction services.

Here are some examples of addiction services that will be restricted under this new policy:

  • Clinical treatment providers for drug and alcohol addiction, including inpatient, residential, and outpatient programs
  • Recovery support services for drug and alcohol addiction, including sober living environments and mutual help organizations
  • Lead generators and referral agencies for drug and alcohol addiction services
  • Crisis hotlines for drug and alcohol addiction

Outside the United States, ads for addiction services are currently not allowed.

In the United States, advertisers will need to be certified by LegitScript as addiction services providers before they can advertise through AdWords.

Not all drug and alcohol addiction services are eligible for LegitScript Certification.

Those not eligible for certification, such as sober homes and referral agencies, are not allowed to advertise for drug and alcohol addiction services on Google.

LegitScript charges a fee for processing and monitoring applicants, but fee waivers may be available in certain circumstances.

According to John Horton, CEO of LegitScript:

All of us at LegitScript are really excited about this new program. In many ways, it’s a natural extension of the work we’ve done for years to make the rogue internet pharmacy problem — a driver of prescription drug abuse and other problems — smaller. One of the most pernicious problems our country faces today is opioid addiction and other substance abuse. In the midst of this crisis, some opportunistic addiction treatment providers have been cashing in on patients’ recovery efforts and insurance billing opportunities. The worst of these have not only failed to provide treatment, but have encouraged ongoing drug abuse in patients trying to break the habit.

At the same time, addressing opioid addiction rates requires effective drug treatment strategies: patients and their families need to know which treatment providers are credible and legitimate, and which ones should be avoided. We hope that our program will help provide patients and our partners (like Google) information about which programs provide genuine treatment and which are, in essence, scams.

An important note about cadence: during the first three months, we’re going to intentionally take it slow. Irrespective of how many applications we receive, we’ll probably only certify about 20 to 30, simply so that we can make sure and get the process right. After that, we’ll ramp up the speed. (This goes into the “lessons learned” bucket from our existing healthcare merchant certification program.) This also works well with Google’s timeline, since they have indicated they will actually begin allowing these advertisers in July.

To learn more about LegitScript Certification and submit an application, visit LegitScript’s website.

US advertisers that are certified by LegitScript must also be certified by Google before they can begin advertising.

Advertisers with LegitScript Certification can request certification with Google starting in July, when the form is published.

Interest in treatment for abuse of opioids and other prescription drugs has soared in recent years amid what authorities have described as a nationwide epidemic.

Scammers found that Google ads were an easy way to defraud treatment-seekers in an industry in which regulations vary greatly by jurisdiction, authorities and patient advocacy organizations have said.

Google suspended alcohol and drug treatment advertising on search pages and millions of third-party apps and websites in the U.S. in September, the week after tech publication The Verge posted a lengthy story about scams. Google expanded the prohibition globally in January.

The move cut off at least $78 million annually worth of advertising in the U.S. alone, research firm Kantar Media estimated.

Most advertisers can buy ads through Google with few hurdles to clear. But Google has adopted additional vetting for locksmiths, garage-door repairers, drug makers and online pharmacies following public pressure. Google has said it also will begin seeking more documentation from political advertisers this year.

The addiction treatment rules apply to in-person facilities, crisis hotlines and support groups.

LegitScript will evaluate treatment providers on 15 criteria, including criminal background checks and license and insurance verification. They must also provide “written policies and procedures demonstrating a commitment to best practices, effective recovery and continuous improvement,” according to LegitScript, which will charge $995 upfront and then $1,995 annually for vetting.

The National Association of Addiction Treatment Providers and the National Center on Addiction and Substance Abuse support the standards, John Horton, chief executive of LegitScript, said in an interview last week.

A vetting process for sober-living houses and non-U.S. treatment centers has yet to be set, he said.

Horton acknowledged the “extra step” may frustrate rehab centers.

“It’s unfortunate, but this is one way the market gets cleaner and people get the help they deserve,” he said.

Marcia Lee Taylor, chief policy officer of the Partnership for Drug-Free Kids, to whom Google has donated advertising space, said earlier efforts to certify treatment services have failed because there was no “business incentive to answer all these invasive questions.”

Tying access to the world’s biggest online advertising system to certification makes applying worthwhile, Taylor said.

The new rules do not affect free business listings on Google Maps, which also have been susceptible to fraud. Google said it is continuously developing ways to combat Maps spammers.

More about this new model will be part of my presentation “Public Policy and the Law of Marketing Treatment Programs” at the 2nd Annual Treatment Center Executive & Marketing Retreat hosted by the Institute for the Advancement of Behavioral Healthcare in Hilton Head, SC, April 30 – May 1, 2018.

Reduction of Mental Healthcare Workforce Contrasts with Need

According to, the U.S. healthcare sector added 22,400 jobs in March, an improvement from February and roughly in line with its average monthly gain over the past year. The largest decline in the healthcare sector took place within residential mental health facilities, which shed 4,100 jobs, according to the U.S. Bureau of Labor Statistics’ newest jobs report released Friday. That’s after those facilities made 700 new hires in February. Ambulatory healthcare services continued its steady growth in March. That sector saw the most new hires within healthcare: adding 16,200 jobs. Hospitals added 9,900 jobs, an improvement from 9,300 new jobs in February. Within the ambulatory sector, dentists’ offices added 4,400 jobs, physicians’ offices added 3,700, outpatient care centers added 3,500 and home healthcare.

Any why is this?

Three main reasons:

  1. Difficulty of Marketing/Brand Recognition – Unlike more traditional forms of healthcare, assisting a patient with selecting a mental health/substance use disorder provider is not as easy as making a referral to a local provider. It is inherently constrained by the refusal of insurance carriers to provide robust IN-NETWORK benefits and providers and by local zoning authorities hindering and obstructing the siting and growth of such facilities. You can’t employee people if you can’t open your facility (and keep it open).
  2. Failure to Pay – You can’t pay the army of employees you need to do this right if you don’t have steady, predictable income, unless you want to staff your facility with interns and unqualified people with little to no experience. I believe our citizens deserve better.
  3. Workforce – People have never flocked to this segment of healthcare as a professional or occupation due to lack of education, lack of ability to make a living, and stigma. In the early days of mental health care, psychiatrists themselves were criticized by their medical school peers as not practicing “real medicine.” On top of that, only the wealthy could afford such services. With insurance only now beginning to pay, the reimbursements are so low that a healthcare provider is stuck with offering volume care over quality. Providers are simply unable to pay competitive salaries and therefore the already limited mental healthcare workforce is going elsewhere.

What Does It Mean When We Call Addiction a Brain Disorder?

When the 2016 Florida Legislature allocated funds for the formation of the Palm Beach County Sober Homes Task Force, my first instinct was that the State of Florida was looking at the conundrum we here in South Florida were facing through the wrong shade of glasses. To target “sober homes” was simply feeding into the local movement to eradicate addicts in recovery from living amongst society, a long-standing issue which required the U.S. Department of Justice to intervene nationally under the Fair Housing Act and the Americans with Disabilities Act.

The “problem” that we were all experiencing was not “sober homes” [a term, by the way, which has taken on a pejorative meaning, and therefore now rightfully distinguished as either a “Recovery Residence” or a “flop house”], but rather the economy created within the health care sector for delivery of clinical services; the “churn and burn” of patients’ insurance benefits. Law enforcement and government regulators were unable at the time to grasp the vast underground network that was truly the foundational underpinning of everything that was going wrong. Flop houses were merely the effect; the cause was the demand from “health care entrepreneurs” for bodies to put through the machine to bill insurance and make money and the failure of the entire system to sufficiently develop a standard for treatment and post-treatment recovery that health insurance would be required to pay for as being “medically necessary.” This disconnect was further exacerbated by old school, traditional ways of recovery, such as AA and sober living providers, for whom “treatment” was not available decades ago, and who today understandably question the “medicalization” of addiction treatment and care.

As one of the original appointees to the Task Force, it was a pleasant surprise to find that the Palm Beach State Attorney’s Office inherently understood this as well. Their focus was on the entire health care industry serving those afflicted with Substance Use Disorder, and would NOT allow itself to be used as a puppet to develop more sophisticated exclusionary zoning tactics that for far too long had been used to ostracize addicts from cities and make access to care difficult at best. The empaneling of the Palm Beach Grand Jury to study the entire industry simply underscored and emphasized Dave Aronberg’s commitment to fact-finding.

The “Proviso Committee” of the Task Force were made of up health care practitioners, government officials, and industry representatives, who themselves, as a committee, would examine the modern paradigm of addiction care and associated recovery organizations to make recommendations to the Florida Legislature on how to effectively address where the wheels came off the wagon in Palm Beach County and to prevent similar issues developing statewide. Mr. Aronberg noted early on both that “we can’t arrest our way out of this problem” and that addiction treatment and recovery communities have been a long-standing, respectable, and honorable part of the fabric of Palm Beach County.Early on, the Task Force came to recognize the disparate opinions within the field itself. While some felt strongly the focus should be on recovery support services, others leaned towards a medical model of care (to include MAT). Advocates on both sides seemed (and appear to continue to be) at odds over what is the “right” way to address the current opioid epidemic, and well as how to define “best practices” for our future. Even those on the medical/clinic side seemed to debate whether addiction was rightfully classified as a “disease” or a “brain illness.”

As our science has evolved (rather quickly, it seems of late), Dr. Nora Volkow, the director of the National Institute on Drug Abuse (NIDA), which is part of the National Institutes of Health (NIH), attempted to address the medical side of addiction care and the role that recovery support services has, in her article published in Scientific American entitled “What Does It Mean When We Call Addiction a Brain Disorder?” In the article, she writes:

Yet the medical model of addiction as a brain disorder or disease has its vocal critics. Some claim that viewing addiction this way minimizes its important social and environmental causes, as though saying addiction is a disorder of brain circuits means that social stresses like loneliness, poverty, violence, and other psychological and environmental factors do not play an important role. In fact, the dominant theoretical framework in addiction science today is the biopsychosocial framework, which recognizes the complex interactions between biology, behavior, and environment.

Critics of the brain disorder model also sometimes argue that it places too much emphasis on reward and self-control circuits in the brain, overlooking the crucial role played by learning. They suggest that addiction is not fundamentally different from other experiences that redirect our basic motivational systems and consequently “change the brain.”

Some critics also point out, correctly, that a significant percentage of people who do develop addictions eventually recover without medical treatment. It may take years or decades, may arise from simply “aging out” of a disorder that began during youth, or may result from any number of life changes that help a person replace drug use with other priorities. We still do not understand all the factors that make some people better able to recover than others or the neurobiological mechanisms that support recovery—these are important areas for research.

But when people recover from addiction on their own, it is often because effective treatment has not been readily available or affordable, or the individual has not sought it out; and far too many people do not recover without help, or never get the chance to recover. More than 174 people die every day from drug overdoses. To say that because some people recover from addiction unaided we should not think of it as a disease or disorder would be medically irresponsible. Wider access to medical treatment—especially medications for opioid use disorders—as well as encouraging people with substance use disorders to seek treatment are absolutely essential to prevent these still-escalating numbers of deaths, not to mention reduce the larger devastation of lives, careers, and families caused by addiction.

My takeaway from this is article is that my layperson opinion remains unchanged – medical treatment and recovery support services are the “yin” and “yang” of the same medallion. They cannot be separated but rather should be integrated into a continuous model towards sustainable recovery. Each path is different, as each person’s genetics as well as upbringing and life-experiences are unique. We are each a small universe onto ourselves. Therefore, it is my opinion that the billions of dollars being thrown into the “medical” side of the equation but failing entirely to fund the “recovery” side is to simply a band-aid. While I recognize and appreciate American hesitancy to adopt a welfare state for anyone, including the disabled, we must therefore double our efforts to fund and explore brain science so that effective modalities can be implemented which provide people seeking recovery with an accelerated jump start. Medication-Assisted Treatment is but one of those more recent efforts. But we can do more, and as a nation, should spend more, doing so.

Legal Action Center’s Response to President’s “Initiative to Stop Opioid Abuse and Reduce Drug Supply and Demand”

Yesterday in New Hampshire, President Trump outlined his administration’s three-pronged plan for addressing the opioid epidemic. While the strategy includes certain components critical to expanding access to evidence-based addiction care, it lacks specificity on health approaches and falls well short of the comprehensive public health response needed to address a crisis that is currently claiming the lives of over 175 Americans each day. Further, the plan’s emphasis on the failed punitive policies is out of step with what we know from decades of public health and public policy data.

One stated goal of the President’s “Initiative to Stop Opioid Abuse and Reduce Drug Supply” is to “expand access to evidence-based addiction treatment in every State, particularly MAT for opioid addiction”, a critical need which we strongly endorse. The Legal Action Center supports certain additional tactics outlined in the President’s plan to “increase availability of the life-saving overdose reversal drug Naloxone, to expand access to residential SUD treatment and to improve treatment options for people within the criminal justice system, and looks forward to hearing the details of their operationalization.

However, the President’s proposal does not sufficiently address the reality that bringing an end to the opioid epidemic is dependent on a significant federal investment to strengthen and expand the national system of care for all substance use disorders. Many communities, especially in rural areas, have a complete dearth of qualified addiction treatment providers. Strengthening the existing addiction care workforce and developing expertise in the rest of the healthcare system to help prevent and treat addiction also is critically needed. Addressing this gap in coverage will require both short and long term investments and policies that align with the goal of expanded access to effective community-based prevention, treatment and recovery supports. The 2010 Affordable Care Act, for the first time in history, included coverage of substance use disorders as an Essential Health Benefit, and the 2008 Mental Health Parity and Addiction Equity Act requires insurers to cover mental health and addiction services at a level that is equal to coverage of medical and surgical services. The federal government should be working with States to enforce the Parity Act, and to ensure that all insurers, including Medicaid, Medicare and commercial plans, are covering all evidence-based services – including all three FDA approved addiction medications – at par with other health conditions.

Good access to Medicaid is critical to achieving the goal of expanded access to substance use disorder care. This includes expanding – rather than restricting– Medicaid eligibility, which provides coverage for millions of Americans who struggle with substance use disorders. The Legal Action Center strongly supports and has long advocated for making residential substance use disorder care more accessible to people enrolled in Medicaid by repealing the IMD exclusion and CMS issuing waivers until Congress changes the law. At the same time, the initiative’s stated goal of expanding access to evidence based treatment cannot be achieved if the Administration continues to take regulatory actions to weaken the Medicaid program through severe funding cuts and enrollment restrictions such as work requirements and lockout provisions. The administration must stop taking actions to limit people’s ability to get Medicaid if it is serious about stemming the opioid crisis.

Similarly, the Legal Action Center strongly supports the need to link people struggling with addiction in the criminal justice system to the care they need, but this action must include people with all forms of substance use disorder, not just opioid use disorder as proposed by the President’s Initiative. We agree with, and have long advocated for, diverting as many people with addiction away from the criminal justice system and connecting them to treatment. We encourage the administration to support diversion as early in the process as possible and to consider use of other home and community-based settings. We also urge the Administration to ensure that there is good access to evidence-based harm reduction approaches, including syringe-exchanges and safe consumption facilities, as well as all three FDA-approved addiction medications and residential treatment.

The Legal Action Center strongly opposes several aspects of the President’s Initiative that focus on punitive approaches. Research has clearly and repeatedly shown that a heightened focus on enforcement does not work to either reduce drug supply or demand, and that the ‘War on Drugs’ disproportionately targeted low-income communities of color and fueled mass incarceration. There is wide agreement among the American public as well as on both sides of the aisle that we need to shift away from a punitive approach to drug policy to a much more effective and less costly approach of treating addiction and supporting effective re-entry policies. There is also robust evidence that the majority of those incarcerated have diagnosed substance use disorders, and that many of them have been incarcerated as a result of criminal activity arising directly from their addiction. This includes those who are convicted of low-level drug dealing to support their addiction. We strongly condemn the suggestion that the death penalty should be sought for drug trafficking, since all evidence shows that such a policy would not reduce drug use, would be very costly and would fall disproportionately on people of color and those without financial means.

While we appreciate the administration’s recognition of the need to develop a plan to address this critical public health emergency and some of its proposals, we urge the Administration to invest sufficient resources to successfully combat the opioid and other substance use epidemic; prioritize proven health responses including expanding health care coverage of substance use disorders and quality prevention, treatment services and medications, evidence-based harm reduction approaches, and recovery supports; and not return to failed punitive policies of the past that did great damage to our country without reducing drug misuse and addiction.

Why Does the Media Continue to Pander with Discrimination?

I read the local Sun-Sentinel newspaper this morning regarding endorsements for Delray Beach local elections and was absolutely floored. What I read was straight-up discrimination, from a media source that would defend to the death its other Civil Rights – the right to free speech.

Of all the grounds upon which to suggest a candidate was unfit for office was the fact that Adam Frankel, a criminal defense attorney with a strong civic record for prior service to his city, should be discredited because:

“As an attorney, Frankel also represented defendants from the drug treatment industry. Given all the problems that industry has brought Delray Beach, Frankel’s decision was bad. His explanation is worse.”

Shame on you, Sun-Sentinel Editorial Board, made up of Rosemary O’Hara, Elana Simms, Andy Reid, and Julie Anderson.

Shame on you for perpetuating discrimination.

Shame on you for being ignorant.

Shame on you for pandering.

But I suppose that is why the paper’s competitor, The Palm Beach Post, has won award after award for journalism with integrity in balanced reporting in this space.

The Statistics:

According to the National Survey on Drug Use and Health[1] conducted by the Substance Abuse and Mental Health Services Administration (“SAMHSA”), a division of the U.S. Department of Health and Human Services (“HHS”), 21.5 million American adults (aged 12 and older) battled a substance use disorder in 2014 and almost 80 percent of individuals suffering from a substance use disorder struggled with an alcohol use disorder; over 7 million Americans battled a drug use disorder. One out of every eight people who suffered from a drug use disorder struggled with both alcohol and drug use disorders simultaneously.

At the same time, the Office on National Drug Control Policy (“ONDCP”) reported as far back as 2007 that Substance Use Disorders cost American society close to $200 billion in healthcare, criminal justice, legal, and lost workplace production/participation costs. In 2016, the U.S. Surgeon General released his comprehensive report: “Facing Addiction in America – The Surgeon General’s Report on Alcohol, Drugs and Health” which concluded that, “[a]lcohol misuse, illicit drug use, misuse of medications, and substance use disorders are estimated to cost the United States more than $400 billion in lost workplace productivity (in part, due to premature mortality), health care expenses, law enforcement and other criminal justice costs (e.g., drug-related crimes), and losses from motor vehicle crashes.[2]

Most recently, a Pew Research Center survey conducted in August 2017 found that 46% of U.S. adults say they have a family member or close friend who is addicted to drugs or has been in the past.[3] Globally, the World Health Organization (WHO) had declared addiction to be a “global burden” stating that “psychoactive] substance use poses a significant threat to the health, social and economic fabric of families, communities and nations. The extent of worldwide psychoactive substance use is estimated at 2 billion alcohol users, 1.3 billion smokers and 185 million drug users.”[4]

Notwithstanding these statistics, local governments are loathe to provide the real estate and resources in order for service and housing providers to exist. Our country holds in little regard the private sector providers, while we laud the efforts of the government-funded agencies (which are not funded to innovate and find solutions to addiction but merely to be glorified pharmacies these days). How’s that been working out for us?

Typical Response from the Public:

Public perception drives policymaking by informing and educating the policymakers (i.e., elected officials) as to our national priorities. The recent mass shooting at Marjory Stoneman Douglas High School on February 14, 2018, is but one stark example. But with regard to addressing the massive public health concern of Substance Use Disorders, including alcoholism, the American public continues to hold tight to the perception that people with Substance Use Disorders and those who support service providers have a moral failing and have a lack of constitution. By blaming the addict for not taking personal responsibility for their own mental health, the public was not prepared to have their elected officials spend necessary funds to build the required social and physical infrastructure deemed necessary to seize the rapid growth of this epidemic. Our local and national media feed off of this stereotype and propagate it as it is an inherent truth.

Contrary to popular opinion, these people did not “choose” to become addicted to substances. Some of them have found that the use of substances mitigates cortisol levels induced my extreme stress (for example, Post-Traumatic Stress Disorders, or “PTSD”)[5] which underlying mental disorder only became popular to address during the past 17 years since military service men and women would return home with active substance misuse, similar to when soldiers returned from Vietnam in the 1970’s.[6]

More recently, most Americans have become addicted to prescribed substances intended to control pain (Opioids) or anxiety-related disorders (Benzodiazepine), both of which were readily known to have highly addicted qualities. These chemicals were scientifically demonstrated to “hijack” the dopamine receptors in the brain causing a deadly cycle of increased dosages often times leading to overdose and death.

For these Americans and all persons who suffer from addiction, their substance misuse is caused by a brain illness and is not a choice. Notwithstanding data, evidence, and science, this “truth” appears to be somewhat irreconcilable with prevailing American culture which demands adherence to a Puritanical code of rugged individualism and self-responsibility. Truth be told, there is currently no evidenced-based approved cure for addiction; the patient must be a willing and active participant in their own recovery, for the remainder of their lives.

As a result, public policy arguments banter back and forth trying to find consensus on how to address Substance Use Disorders and co-occurring mental illnesses, without much success. This failure or refusal to address addiction and mental illness comprehensively and effectively is the product of a lack of education on the subject-matter and the inability of policymakers to let go of long-held prejudices and preconceived notions of “who” addicts really are.

All the while, the press and mass media are directly responsible for perpetuating myths and misunderstanding.

Why I Chose to Represent Treatment and Housing Providers:

I graduated from the University of Miami School of Law, with honors, in 1997. In 2010, I relocated my private law practice of representing individuals and corporations relating to private property rights, land use and zoning before governmental entities, to Delray Beach. Almost immediately, I found myself being approached by drug and alcohol treatment centers to represent them with regard to local government attempts to regulate them out of that city.[7] Key to this issue was a new term, a “sober home”, which I later came to learn was appropriately termed a “Recovery Residence.” The mere existence of these homes in local neighborhoods became the issue of the day, as residents were fearful of who was living in these homes and the inherent threat addicts posed to their children, as well as their property values.

As a lawyer, who was required to take an oath to uphold the mandates of the United States Constitution, no differently than Mr. Frankel, I wanted to understand the problem so that I could serve the entirety of the public, not just my clients. I wanted to educate myself on what the real issues were, so that I could best serve not only my clients, but also to protect both this vulnerable population who were receiving these services as well as the local communities in which such homes and treatment providers were located.

I quickly became aware of the most notoriously open secret in Delray Beach – the existence of a vibrant and cohesive “Recovery Community” which was an organically evolved gathering of disparate individuals from across the United States, seeking to live together in collective sobriety and recovery from past misuse of substances. For the first time in my 45+ years as a South Floridian, I felt a sense of welcoming from a “community” that I had never experienced before in my life. Almost instantaneously, I had a literal dual déjà vu moment that has remained with me ever since, flashbacks to two significant events in my professional life that I did not realize up until that moment which had an impact on me.

The first event was my experience as an Assistant City Attorney for the City of Boca Raton in which the City had adopted a local zoning ordinance mandating that recovery housing providers may only be located in specific commercial zoning districts of the City, rather than residential. As the City was litigating this matter, the U.S. Department of Justice as well as the American Civil Liberties Union (“ACLU”) interceded into the case on behalf of the plaintiff housing provider, declaring that: “No citizen should be refused an equal opportunity for housing in their community… The Fair Housing Act protects all Americans from housing discrimination, including those persons recovering from substance abuse problems.”[8] This was the first time I was exposed to the writings explaining the long-standing public policy behind the Fair Housing Act, which was part of the original Civil Rights Act of 1967. That case, Jeffrey O. v. City of Boca Raton, 511 F.Supp.2d 1339 (S.D. Fla. 2007), became a landmark case for housing rights. I became fascinated by the writings amongst intellectuals, housing rights advocates, federal judges, as well as the Congressional Record itself, relating to the adoption of the Rehabilitation Act of 1973; the Fair Housing Amendments Act of 1988; and the Americans with Disabilities Act of 1990. And I, too, realized, that I had harbored preconceived notions about “those people” which I never had the opportunity to explore, until then.

The second event, which happened almost concurrently in time, was the publication on November 16, 2007 of the front-page article in the New York Times entitled: “In Florida, Addicts Find an Oasis of Sobriety.” [9] This stellar piece of insightful journalism lauded the acceptance, tolerance, and seamless integration of people in recovery into the fabric of the City of Delray Beach, exactly as I was experiencing it in real time in 2010. It was a story about hope and community. However, while the article was intended to illustrate a shining example of how a community had transformed itself to support its residents (new and old) with past addictions, elected officials and other homeowners viewed the article as a Scarlet Letter of shame and as having a negative impact upon the tourism industry from the north that local businesses heavily relied upon in the winter months.

What once was tolerance and acceptance quickly devolved, right in front of me, to antagonism, vilification, and alienation. Just as quickly, service providers to this population began to contact me as a known local zoning attorney representing businesses and private individuals regarding property rights litigation, to see what I could do to protect them.

By 2010, new local laws were being adopted, endeavoring to restrict service providers for people afflicted with Substance Use Disorders as well as those who provided sober living environments. However, this was not entirely discriminatory or without basis. South Florida, as had the rest of the nation, was experiencing three events simultaneously – the explosion of “Pill Mills” (the sale of mass quantities of opioids from supposed pain clinics); the Great Recession of 2008 (in which housing prices plummeted); and the adoption of the Patient Protection and Affordable Care Act of 2010 (which mandated, for the first time, that insurance companies cover mental health and addiction-related disorders). All three events combined caused a virtual overnight rush of unscrupulous people into Delray Beach to buy inexpensive single-family homes, fill them with young people addicted to opioids including heroin, and drug test them under the guise of providing a supposed “sober living environment” for which treatment providers would pay a hefty sum to get easy access to their insurance benefits.

While cities like Delray Beach were trying to grapple with this new reality, the “straw that broke the camel’s back” for the City of Delray Beach was the purchase by the non-profit Caron Foundation of Florida of two luxury homes on the beachfront. “Those people” had crossed the imaginary “line in the sand” of the Intracoastal Waterway, and into the “protected neighborhood” of the wealthy and politically connected. In what ultimately became the federal case of Caron Foundation of Fla., Inc. v. City of Delray Beach, 879 F.Supp.2d 1353 (S.D.Fla. 2012), the court ruled, once again, just as it had in 2007 that local governments may not use its zoning authority to discriminate against a protected class of citizen – in this instance, those with disabilities, of which Substance Use Disorder was deemed to be a part.[10]

What came next was an unequivocal shock to my system. After being involved in that case, I quickly began to experience abandonment from my peers and colleagues. It was now I who was wearing the Scarlet Letter. I was ostracized and stigmatized by those who I considered to otherwise be very educated and enlightened people, simply because of “who” I was representing – service providers for people overcoming addiction. When I tried to educate and enlighten my peers, I found their minds to be closed as having predisposed ideas of what “addicts” are and how they were a “danger to society.”

As other similar zoning cases progressed before the City, members of the public would jeer me, physically assault me, and explain how they felt pity for my parents for who I had become. I, too, would be further ostracized, criticized, rejected, scorned, labeled, hated, jeered, and mocked. I had to make a choice – take the easy road of doing “something else” in the law (which, at the time, was unclear, as my local zoning law practice was now being attacked by the NIMBYs), or I could take the road less traveled, the one without the fanfare, the one without the security of income, but with knowledge that I was doing the “right” thing.

In a moment of quiet meditation, I was then reminded of the oft-quoted poem by Martin Niemöller, which today is posted prominently at the United States Holocaust Museum in Washington, D.C.:

First they came for the Socialists, and I did not speak out—
Because I was not a Socialist.

Then they came for the Trade Unionists, and I did not speak out—
Because I was not a Trade Unionist.

Then they came for the Jews, and I did not speak out—
Because I was not a Jew.

Then they came for me—and there was no one left to speak for me.

That was enough for me to decide to choose the path less taken, the path of uncertainly and fiscal insecurity, if for no other reason, because if I did not stand up for these people, in these times of uncertainty, then who would?

Since August 2010, I have always made myself available to those seeking to provide Substance Use Disorder treatment and sober living residences so that they could be free from discrimination and serve a population that has always been in dire need of services, but only if they would agree to do so in an ethical manner. For many providers, understanding where ethics began and where laws were broken was not clear without guidance from a lawyer. There was NO guidance from the very agency that was to regulate them – DCF. None. Zero. Not until the Palm Beach County State Attorney’s Office began an earnest attempt to bring the law’s mere existence to the attention of the public was there any modicum of clarity for those who did not seek guidance from legal counsel. And for those who did, both the public and the media such as the Sun-Sentinel has no hesitation to besmirch their reputation, such as that of Mr. Frankel.

Through it all, I have maintained a very simple truth – the cure to addiction is not sobriety; it is community. Mental health issues and co-occurring Substance Use Disorders continue to be blamed as the root cause of an unsustainable American society. I assert that these are simply the symptoms and byproducts of a society that no longer sustains its citizens. Media such as the Sun-Sentinel, meanwhile, enjoy propagating the negative to shame addicts and people who represent their service providers to go elsewhere.

That foundational understanding has been shared across generations, long before the creation of social media, and yet it has persisted. But addictions and mental health continue to tear communities apart due to, in my long experience, a lack of education, understanding, and resources. One of the few resources of education and information is our press, which refuses to engage in progressive public dialogue about the role that Substance Use Disorder treatment has within our communities and the fundamental need and right to provide safe and affordable housing for those who are both in treatment as well as those who are established in their recovery. Because it doesn’t sell newspapers. Rather, such media outlets pander to the lowest common denominator, which is ignorance, fear, and stereotype, prejudice, and anecdotal conjecture, because they can quantify how many website links the public clicks through to read, and then sell that data to advertisers. For news outlets like the Sun-Sentinel, it’s not about fair reporting – its all about money. Their values are compromised.

That said, I know many fine reporters for that paper. But this isn’t about them. It’s about the business decisions made by media outlets that compromise the integrity of the First Amendment and the Freedom of the Press. They have abdicated the right to be a part of the enlightened culture in our community, at least for today, in my eyes.

There is no doubt that, in recent years, many terrible, highly publicized things have occurred within this industry, encompassing healthcare fraud, deceit, victimization, and numerous overdose deaths.[11] Though through it all, we have fought very hard to have Delray Beach maintain the moniker of “Recovery Capital of the United States,” because it is that sense of community that I experienced back in 2010 which brought others who needed that connectivity simply to survive. I, as well as others, saw that connectivity as the glue that binds any community. Entities such as the Delray Beach Drug Task Force have consistently endeavored to educate adults within our communities on how to support similar recovery communities so as to protect the vulnerable and at the same time maintaining the integrity of our communities. At the same time, the press continues to try to tear it down.

Confronting Addiction:

I woke up this morning reminded yet again about the preconceived notions and hardened temperaments about “those people” that are deeply engrained in American society and perpetuated by mass media. There is no denying that fraud in all of healthcare is a huge problem, for which Substance Use Disorder treatment providers are not immune. But the myopic focus on the recent negatives of the Recovery Community make educating and advocating for this population difficult at best. This remains particularly saddening for me as Palm Beach County and the City of Delray Beach, specifically, had a long and honorable reputation for being a welcoming “Recovery Community” for those who sought to “pick themselves up by their bootstraps” and start life anew. But with all the community backlash, as highlighted repeatedly in the press, we continue to face a national health epidemic for which a lack of open-minds as to education continues to obstruct readily achievable and cost-effective, evidenced-based solutions.

Our collective ability to formulate timely and effective local, state, and federal policy continues to be stymied due to ignorance and intolerance of others. Though State Attorney Dave Aronberg’s Sober Homes Task Force[12] has successfully recommended legislation adopted by the State to curb the same type of abuses found throughout healthcare nationally, I continue to find the ability to communicate with one another on this topic to remain frustrated by the failure of even the most educated amongst us to recognize how the truth about addiction and service providers can be applied in a collaborative framework.

A Refusal to Be Educated:

In my effort to be a part of the education movement, I have journaled my experiences and have lectured across the country at various professional conferences. But I have also found that my ability to effectively communicate and educate adults who are policymakers has been limited in part by their lack of willingness to unclench their fists and open their ears. Still, lawyers and people like Mr. Frankel move forward to find balance in our society yet remain chastised in the press for doing so. Large media outlets like the Sun-Sentinel suggest a fine lawyer like Adam Frankel, Esq., should not get elected because he associates with “those people.”

Shame on you Sun-Sentinel. Mr. Frankel is a fine attorney who has worked collaboratively with the Sober Homes Task Force. Rather than report on all of his efforts to clean up the industry from the inside, you quickly set aside journalistic integrity and resorted to muckraking.













A Mental Health Tragedy

Dear Clients and Friends:

To say that I am still in shock from yesterday’s events is an understatement.

While my boys do not attend Marjory Stoneman Douglas HS in Parkland, Florida, it is a school that I pass regularly in the neighborhood and a place where friends and family do send their children.

But whether it is next door or across the country, this is already the 18th gun-related incident at or near a school this year, which includes suicides.

A young man, interviewed by local news on the scene, said what was on my mind: “While this is devastating and traumatic, I am also sad for the shooter, who clearly was in emotional pain to the point where he felt he needed to do this.”

Today, our government offers “prayers and wishes” to the families of those killed or injured. In the background, our leaders are seeking to slash the public health budgets of the Department of Health and Human Services (HHS) as well as the Centers for Disease Control (CDC).

This comes on the heels of the end a the national registry designed to provide information to the public about evidence-based mental health and substance use interventions and programs, known as the “National Registry of Evidence-based Programs and Practices: (NREPP), which was funded and administered by the Department of Health and Human Services and has existed since 1997 to help people, agencies and organizations identify and implement evidence-based behavioral health programs and practices in their communities.

Before yesterday’s tragedy, I was engaging in one of my favorite exercises – drafting my annual “State of the Union” letter (so to speak) about how far we have come together in ridding our great State of Florida and the nation itself of the scourge of those who place profit ahead of patient care. That letter is attached.

In other medical modalities, emotionally connecting with the patient (a doctor’s “bedside manner”) appears to be no longer necessary. We dispense medications. We perform procedures. They don’t have to care about the patient anymore. They will soon will be replaced by Artificial Intelligence.

But in mental health care, behavioral health care, and addiction treatment and housing services, it is essential that there is a direct connection between provider and patient. That connectivity is what allows those suffering with these afflictions to begin their recovery.

A doctor performs surgery and moves on.

Your relationship with your patients last a lifetime, as a lifeline.

In the background, there is the need to actually run a business to provide these services and we are very cognizant that the overhead costs of providing those services continue to rise.

Taking this into consideration, we have not raised our fees for services in 8 years, knowing that our clients were being attacked on all fronts – NIMBY local government zoning decisions; inconsistent and inequitable state regulation; arbitrary and blatant illegal actions by insurance carriers; and people I can only describe as “bottom barrel slime dwellers” who prey on your patients as commodities to bought, sold and traded. Some wear street clothes, others wear suits.

We want you all to know and feel that we support you and want to see you rebuild what was once a thriving and grand “Recovery Community” here in South Florida, so that we can replicate that success across our country, to include mental health services.

We are only now beginning the next chapter of where and how these services will be delivered to the public. We want to be there, at your side, as you do so.

Thank you for support as a client, a colleague and as friends, and for allowing us to serve you with integrity.

Click here to find out more

California Proposes Legislation to Stop Body Brokering, Following the Lead of Florida

While people have called the treatment industry in Florida the “Wild West,” the real wild “west” has been California, which, unlike Florida, does NOT have any form of law on the books that criminalizes or prevents patient brokering (accepting or receiving payment for health care referrals, or using something of value to induce or entice a patient to select a specific treatment provider).

California appears to continue to try to get something on the books to stop the rampant abuses in patient placement which Florida has been light years ahead of the nation in addressing, thanks in very large part to the creation of the Palm Beach County Sober Homes Task Force and the heroic efforts of Palm Beach County State Attorney Dave Aronberg; Chief Assistant State Attorney Al Johnson (and Chair of the Palm Beach County Sober Homes Task Force); and Assistant State Attorney Justin Chapman, the lead investigative prosecutor in all such cases.

The right people, in the right place, at the right time, who understand that the treatment and housing industry in Florida has historic roots, for which this latest chapter is not indicative of the phenomenal work that Florida-based providers have offered to our nation’s afflicted for over 50 years.

The Orange County Register (which, like the Palm Beach Post, has done an exceptional job of reporting on this crisis of ethics) reported yesterday in their article “Bill Aims to Plug Holes in Addiction Treatment Industry,” that California State Senator Pat Bates introduced legislation on Wednesday (1/17) to try to address these issues.

“For more than 20 years, several bipartisan efforts to address the challenges surrounding the state’s drug rehab history have gone nowhere due to opposition from vested interests,” said Bates, R-Laguna Niguel.

“While I’m under no illusion that pursuing greater oversight will be any easier this year, doing nothing is not acceptable for constituents who have contacted me on this issue. The Southern California News Group’s thorough 2017 investigation into the industry makes it clear that reforms are needed.”

Much like the nationally recognized and heralded reporting on this same topic by The Palm Beach Post – “Addiction Treatment: Inside the Gold Rush” – the Southern California News Group’s investigative reporting found that as opioid addiction has soared, unscrupulous treatment center and housing operators flocked to fill the void of existing providers for which insurance money now existed under the “Essential Health Benefits” requirement of the Affordable Care Act.

Like Florida, people with Substance Use Disorders (which, sadly, SCNG still refers to as “Addicts”) from across the country but mostly the western states areas were lured to California with offers of free travel, rent, cigarettes, and other inducements.

But unlike Florida, California has had a very “hands-off” approach to regulating the industry, which has made the barrier to entry to treatment so low, it is virtually non-existent.

As we have been reporting here at SLN for years, historically there has been no insurance coverage to treat Substance Use Disorders.

This lack of revenue caused physicians and other licensed health care providers with proper credentials to stay out of this system of care.In addition, many physicians were equally guilty of discrimination of not wanting to work with “those people”.Further, since there was no economic incentive to enter this space, the system of care significantly lagged in keeping up with the science.

Profit drives innovation. Innovation drives efficiencies and cures.Since 2010, and now faced with a pool of money and long-standing demand, the time was ripe for addiction professionals to find a calling for which they could also make a living.

But with the untimely opioid epidemic, demand was too high to fast; there were not enough professionals; and the laws in place that licensed such programs were outdated.

The bill, SB 902 is still a work-in-progress, the Senator said, with language to be crafted with the help of those involved. She wants to improve patient well-being and increase public safety of neighborhoods hosting rehabs and sober living homes, she said, and aims to stop the industry’s bad actors, not those with strong records of helping people.

In 2016, the California Senate Health Committee rejected her SB 1283 that would have allowed a city or county to craft health and safety standards specifically for sober living homes (likely because it violated the Fair Housing Act, as drafted).

This past November 2017, a bipartisan group of the U.S. House of Representatives’ Energy and Commerce Committee asked California and five other states, including Florida’s Dave Aronberg and Al Johnson, for information on allegations of patient brokering.

Sen. John Moorlach, R-Costa Mesa, represents an area that’s is alleged to be home to one of the densest concentrations of treatment providers and sober living residences in the state.

Both Costa Mesa and Newport Beach have waged an open war with treatment and housing providers, but not under the guise of trying to correct the industry and make it better, but admittedly, the force such people out of their borders as being “undesirables.”

“I will be as supportive as I can be,” said Moorlach. “As with any industry, there are bad players. And they’re the ones that need to be addressed.”

At least they are beginning to “say” the right things. But their motives will be borne out in their actions.

Florida is a shining example of what you can do when you embrace the treatment, housing and recovery community, and work in tandem with providers to make the area the “gold standard” for such health care.

To learn more what you can do, also visit the National Recovery Council at


We have been monitoring Florida House Bill 1069 since it was first filed 12/21/17.This morning was the first hearing before the House Children, Families & Seniors Subcommittee, led by State Rep. Gayle Harrell who, along with State Rep. Bill Hager, has been a champion for cleaning up the Substance Use Disorder treatment and housing services industry that provides health care services to both the insured and uninsured.

The initial version of the legislation sought to:

  • Remove “day or night treatment with community housing” as a licensable service component and replacing it with “treatment with housing overlay.”
  • Prohibiting a licensed service provide from having a contractual or referral relationship with a recovery residence to provide treatment with housing overlay unless the recovery residence is certified.
  • Allowing a licensed service provider to accept a referral from a noncertified recovery residence if the resident has experienced a recurrence of substance use and it appears that the resident may benefit from such services.
  • Requiring certified recovery residences to comply with the applicable provisions of the Florida Fire Prevention Code for either one-family and two-family dwellings, public lodging establishments, or rooming houses, or other housing facilities, as applicable.

Yesterday, an amendment was filed to the legislation that:

  • Deleted the proposed amendment regarding “day or night treatment with community housing” [meaning, for now, it would remain as licensable component]; BUT
  • Now prohibits a licensed service provide from having a contractual or referral relationship with a recovery residence with which it receives a “direct or indirect benefit.”

The amended language, found in Lines 170-173 of the bill, provides: “A recovery residence or its owners, directors, operators, employees, or volunteers may not benefit, directly or indirectly, from a referral made pursuant to subsection (1) or subsection (2).

This is different than the language that the Sober Homes Task Force proposed which stated: “A recovery residence or its owners, directors, operators, or employees may not receive a pecuniary benefit, directly or indirectly, from the referral.”

The removal of the word “pecuniary” has caused some to pause with concern, since the proposed law to be interpreted to mean that a treatment provider may no longer own a recovery residence where that program’s residents live.

What was intended (and all would agree), was that licensed service providers are allowed to benefit from a referral to a certified recovery residence so long as their patient lives in a certified recovery residence, while attending out-patient treatment.A treatment provider inherently benefits from providing housing for a host of reasons including ensuring that what is taught in therapy is applied in practice at the residence (thereby avoiding relapse which relapse leaves a scar on the treatment provider) and for business purposes, the patients are not illegally lured or induced to go elsewhere, which allows the provider to continue to be able to be compensated for providing the services.

Licensed treatment programs benefit directly and indirectly because patients are in their program and pay rent to cover housing overhead.Adding the word “pecuniary” by the Task Force was intended to clarify that there can be no direct or indirect financial benefit for any referral. No kickbacks. No patient brokering. No offering free room and board in exchange for the patient attending “XYZ” treatment center. Nothing.

If a treatment provider wants to also provide housing, that housing must be FARR certified and managed by a Certified Recovery Residence Administrator (CRRA).

But what does “indirectly benefit” now mean?

A plain reading of the proposed language could potentially lead to confusion and the conclusion that, even if a treatment program owns or controls a FARR certified recovery residence, if their patients reside at that provider-owned recovery residence, the treatment center is inherently “indirectly benefiting” from the referral. It’s not a clearly erroneous or obscure interpretation.

And what of the residential component of a “Day of Night Treatment with Community Housing” license (aka “PHP” or partial hospitalization)?

DCF mandates (as it interprets its own rules) that a PHP license holder provide room and board to patients at that level of care.

The rule, 65D-30.0081, is entirely silent on that point.

The rules regulating that component, as currently existing and as proposed, still do not clarify whether room and board must be paid for by the patient. Insurance clearly does not cover it.

If the proposed legislation is not further clarified as to what a “benefit” is, who is to say that the PHP license holder isn’t “indirectly benefiting” from offering room and board at no charge to the patient?

On the other side, the corruption that has plagued the recovery industry is a direct byproduct of the economic relationship between out-patient providers and housing.The Task Force sought to close any loophole for provider-owned housing that allowed unethical bad actors to own sober homes simply as a way to avoid the legislative intent to provide a certified recovery residence setting for all patients.

For now, we will all wait and watch to see how this plays out. Clarification in the statute or allowing the Palm Beach County State Attorney’s Office, though legislative delegation, to provide written guidance, would be useful.

We continue to remain optimistic and have faith that our elected leaders, who have done a phenomenal job with such prior legislation to date, will correct and clarify this. The legislative process tends to be very quick in Florida so we hope this doesn’t get overlooked as it could have direct, adverse impact upon the provision of this health care service statewide.



Far too many people have voiced concern that they were not aware of this change in law.

We are not aware if notices were sent out to treatment providers.

While we can sympathize that many providers were not aware (believing that provider-owned housing remained exempt, including Community Housing under a PHP license), the old saying that “ignorance of the law is no defense” remains effective.

Please contact FARR (the Florida Association of Recovery Residence) or DCF with any questions regarding this issue.

Click here to find out more

The War on Drugs Has a Dark Side

Hello all, and Happy New Year!

We haven’t posted in a while because, quite frankly, the news about our Treatment and Housing Recovery Business industry is becoming repetitive, as other jurisdictions are just now discovering that we really don’t (and never had had) a plan to address alcoholism and addiction.

The opioid epidemic simply shined a 10,000 Lumen spotlight on it.

All news outlets are reporting on President Donald Trump’s signature yesterday (1/10/18) of new legislation aimed at giving Customs and Border Protection agents additional screening devices and other tools to stop the flow of illicit drugs.

Speaking at a “surprise” bill signing ceremony flanked by members of Congress from both parties in the Oval Office, Trump described the bill as a “significant step forward” in the fight against powerful opioids such as fentanyl, which he called “our new big scourge.”

“We used to have the ‘Age of Aquarius.’ Everyone thought that was a big drug age. That was nothing compared to this,” he said, citing a nickname for the 1960s that’s perhaps best associated with a song from the musical “Hair.”

He warned that drug traffickers are “using our postal system and they’re killing our people.”

The legislation will supposedly pay for new portable and fixed chemical screening devices to detect and intercept fentanyl at ports of entry and in the mail, along with other laboratory equipment and personnel, including scientists.

Trump has made fighting the opioid epidemic a centerpiece of his administration, though critics say he hasn’t dedicated nearly enough money or resources to make a difference.

And here is where it gets interesting, and actually rather disturbing, at how this Reality TV/Life-Imitates-Art presidency has shades of undertones of the “War on Drugs” meaning a “War on Addicts.”

Trump suggested during his remarks that he’d like to take a more aggressive approach to the drug crisis — but the country’s not ready for what he has in mind.

“So we’re going to sign this. And it’s a step. And it feels like a very giant step, but unfortunately it’s not going to be a giant step, because no matter what you do, this is something that keeps pouring in,” he said.

“And we’re going to find the answer. There is an answer. I think I actually know the answer, but I’m not sure the country’s ready for it yet,” he added. “Does anybody know what I mean? I think so.”

No, Mr. President, we don’t know what you mean. Are you talking about (as Attorney General Jeff Sessions has been strongly implying) that the “War on Addicts Drugs” was widely successful and need to be fully funded again?

I write this after having just rented the action/comedy “Kingsman: The Golden Circle” which is a James Bond-esque film to the first about an underground group of British spy operatives.

However, this sequel punched me right in the gut at a personal level. As others were laughing, I was watching what felt like reality TV.

In this second installment (spoilers ahead), the villain is Poppy (Julianne Moore), an international drug dealer who holds millions of drug users for ransom by poisoning the illegal drug supply. After offhandedly declaring the United Nations useless, she negotiates with the president of the United States who agrees to pay a ransom in exchange for the antidote, part of which includes legalizing all drugs.

But the President has no plans to actually play along. Instead, he decides to lock up the contagious users and let them die, on the logic that it will rid the world of the scourge of drug use forever. “This presidency has just won the war on drugs!” he exclaims.

Once again, I am reminded of the glaring conspiracy in which the political and business elites have effectively teamed up to destroy the lives of ordinary people in order to make a profit.

Survey on SUD Disqualifying Offenses from Employment

Dear friends:

Please take a brief moment to complete this 3-question survey if you have ever been arrested in the past and have attempted to obtain employment within the Substance Use Disorder treatment and/or Recovery Residence fields.

The Florida Alcohol and Drug Abuse Association (FADAA) [yes, they will be changing their name to get with the times] has been working vigorously for many years now trying to update Florida’s Level 2 background screening and the exemption process.

This background check is required to hold many positions within the SUD treatment space. It also disparately impacts the ability of those with significant real world experience from getting involved.

However, DCF does have an exemption from disqualification process, recognizing that by excluding someone who committed a crime as a result of their active drug misuse, this would undermine the entirety of the effectiveness of the system.

The Florida Legislation is reviewing whether to exclude some drug charges from the disqualification matrix, so that after a period of time, there is an automatic exemption from disqualification, rather than having to go through the lengthy and expensive exemption application process, which tends to discourage good, rehabilitated people from providing their wisdom to the treatment marketplace.

Questions have been posted as to the 8 most common offenses for individuals seeking to work in this arena.

In order to try to give them this information, we have created a very short 3-question survey to gather this information anonymously.Here is the link to the survey:

We are trying to gather all information before the end of this week.


We very much appreciate your time and quick response!