Catherine Freer Wilderness Letter To US Representatives

As leaders in the private outdoor behavioral healthcare industry, we were instrumental in obtaining regulations in our state and would like to offer our expertise and experience to you as you consider drafting legislation for programs such as our own. Unfortunately, we recently received negative attention at the Education and Labor Full Committee Hearing "Cases of Child Neglect and Abuse at Private Residential Treatment Facilities." We hope that you will take the time to look beyond what was conveyed, listen to the other side of the story, and to consider our recommendations for regulation.

Twenty years ago, Catherine Freer Wilderness Therapy Programs was founded on the belief that combining therapy and outdoor experiences would offer troubled teens and their families a valuable treatment option. Since 1988, our program has helped thousands of adolescents address the issues that are causing them to struggle. These youth, as many will attest, would most likely still be abusing drugs and alcohol, alienated from their families, in jail, or worse if their parents hadn't intervened and sent them to our therapeutic wilderness program. (Enclosed please find letters from clients and their parents discussing their experiences at our program.) We currently hold multiple licensures in the State of Oregon and are accredited by the Joint Commission on Accreditation of Health Care Organizations (JCAHO).

Catherine Freer Wilderness Therapy Programs serves 300 adolescents per year and helps middle class youth whose parents have run out of options for saving them from self-destruction. These are kids that haven't found success in outpatient treatment, have not yet become enmeshed in the criminal justice system, and who don't qualify for federally or state funded programs. These working families often fall through the cracks and can do little to help their children with emotional and behavioral issues. We strongly believe that these families deserve to have options for their children. With our licensing and accreditation, 70 percent of our families are able to receive some third party (insurance) reimbursement for their treatment, which is a critical factor for most of our clients. Taxpayer dollars are not used to run our program.

Our program was mentioned in the Government Accountability Office's testimony due to the tragic loss of life of one of our participants (Refer to GAO-08-146T - Case 8). Even with licensing, accreditation and regulation, incidents can happen as our program has learned to our great sorrow. With all of the information before them, the investigating authorities came to the conclusion that this young woman's demise was not the result of abuse and neglect. (Her dehydration was later found to be caused by the use of a prescription drug for which no FDA warnings existed at the time of her treatment with us.) It is unfortunate that not all the details were brought forth in the GAO's testimony regarding this incident. We also suffered the unrelated loss of a participant that died from a falling tree limb and a client who died of natural causes while sleeping. In all of these cases, we reached out to the authorities, asking for them to thoroughly examine and review these incidents. And, in each case, neither abuse nor neglect was found.

We firmly believe that well-crafted and thoughtful regulation can raise the bar for outdoor therapy programs and other privately funded therapeutic programs. These programs offer effective approaches to treatment for families. At Catherine Freer, we have invested heavily in outcome research to verify that our treatment is helping families. Following is some of the data gleaned from multiple studies:

Long-Term Outcome Research Program
A study by the Outdoor Behavioral Healthcare Industry Council (OBHIC) and the University of Idaho Wilderness Research Center of 850 parents and adolescent participants indicates that clients entered wilderness programs with about the same level of dysfunction as adolescent patients entering psychiatric hospitals. At graduation their average scores were slightly above the normal adolescent range. Another phase of this study suggests that a large majority are doing well 24-months after treatment. More than 80 percent of parents and over 90 percent of graduates contacted believed that their wilderness treatment experience was effective two years after the process. (Enclosed please find detailed information on the research and a summary of other research from 1999-2006.)

" Catherine Freer Customer Satisfaction/Outcome Study
This study found that 90 percent of parents said they would recommend the Catherine Freer program to others. The average satisfaction score for their children being treated with dignity and respect was 2.84 on a three-point scale. On a four-point scale (one indicating an "extremely serious problem" and four indicating "not a problem"), parents rated their children on 13 behavior items with an average pre-program score of 1.81, a one-month post-program score of 3.38, and a one-year post-program score of 3.45.

As this research clearly indicates, outdoor therapy is a proven solution for troubled youth. Our industry is helping serve families in need and deserves attention and regulation, not censure. Presently there are 102 outdoor behavioral healthcare programs. Ninety percent of these programs are licensed by state agencies, and more than 60 percent are nationally accredited by the Joint Commission or the Council on Accreditation (Russell, K. C. [2007], Adolescent Substance Use Treatment: Service Delivery, Research on Effectiveness, and Emerging Treatment Alternatives. Director, Outdoor Behavioral Research Cooperative, College of Education and Human Development, University of Minnesota.) We believe that the risks to adolescents participating in a licensed and accredited private therapeutic wilderness program are not significantly different from the risks to adolescents in the general population. Unfortunately, there are some programs that are not licensed and have created both service quality and risk problems for some families and their children.

Understanding the importance of regulation, we strongly advocated that Oregon develop regulatory rules for outdoor therapy programs operating within the state. We had the honor of consulting on legislation and participated actively in helping craft the regulations. Oregon created a good process, with clear assignment to Child Welfare for both writing and enforcing the regulations, while including both program stakeholders and outside parties as consulting participants. We believe the result could serve as a national model for regulation of outdoor therapeutic youth programs.

From our experience, some of the issues that should be addressed through regulation include management issues, following the JCAHO model: how policies are created, monitored and enforced; outside oversight on those processes; and how incident reports are analyzed and then utilized to alter policies and to provide staff training. In addition, intake procedures, medication management, and staff qualifications and training should be considered in the regulation process.

We humbly request to join you at the table to help create regulations that would protect families, while at the same time preserving viable options for children in need. We also ask that there be a serviceable level of appropriations allocated to fund this regulation and abuse and neglect prevention. We would be happy to discuss approaches to regulation creation with you and your staff and be helpful in the future in any way that we can.