The private pay treatment industry is in great danger of losing its moral compass and it seems as though few of those involved are concerned or willing to redefine our course. In fact, the Boards of IECA, NATSAP and OBHIC have repeatedly shown a lack of courage and foresight in addressing the emerging ethical issues. As a result, there is a rising chorus of parents and legislators who are now stepping in to address the concerns themselves. It will take concerted leadership by a group of consultants, program administrators, therapists, field instructors, counselors, etc. to head off overly restrictive legislation and public distrust.

I believe we lost our way largely as a result of three factors: First, this is a relatively new industry (for all intents and purposes, having started only 20 years ago). Second, there is a great deal of money to be made in the business of helping kids and their families. Third, the families that we assist are generally in the midst of crisis and willing to quickly trust those with a sympathetic ear and a willingness to offer help. As a result of these three factors, many have realized the potential of being in business and have started programs and practices to fill the need. A way of doing business was set up early on, and few have questioned it along the way, even though some of it is at the expense of the consumer and the very people we started out to help.

Even more disturbing than "this is the way it's always been done" mentality is the one of arrogance and greed that is becoming more prevalent among some program administrators and consultants. I question the ethics of a daily rate of almost $500.00 when profit margins exceed 20%. One might be doing wonderful clinical work, but at some point a program crosses a line from charging a reasonable fee over to the extortion and manipulation of a parent's desperation. I believe the recent raising of rates in some wilderness programs has more to do with the market being closed to healthy competition because consultants and programs have de facto cross referral arrangements. The reality is that if a consultant ever accepts a referral from a program, then that constitutes a conflict of interest and a dual relationship. And yet, many well intentioned consultants accept the referrals, and programs continue to justify sending them. A consultant at some point will have benefited enough from the acceptance of referrals from a program that they are no longer looking for the most appropriate placement for a youth, but rather looking for how to keep the flow of referrals coming from that program. The ethics boards of IECA, NATSAP and OBHIC have all refused to specifically prohibit this practice even though each of their ethical guidelines forbids dual relationships and anything that might impair the judgment of their members. This reluctance to protect the consumer has undercut our industry's integrity and betrayed the families that we work with. Even more grievous is the step recently taken by the NATSAP ethics board in which it removed discussion of this particular issue from future consideration and debate.

Representative George Miller has engaged some of his staff (led by Chief Investigative Counsel Michael Zola) to investigate the various ethical and illegal activities of our industry. I worry that arrogance and shortsightedness will make us complacent, feeling confident that their - and the families who call them with concerns - investigations will focus only on the well known bad apples in our midst. Miller's staff, however, is fully aware of the blurred boundaries between programs and consultants. The recent student loan industry scandal has striking similarities to how many in the private pay treatment industry are now taking advantage of unwitting families, and Miller's staff will be looking for ways to again protect the consumer.

I am calling on the members of NATSAP, OBHIC and IECA to take the following steps immediately: