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What is a Care, Counseling and Treatment Agreement (CCT)?

The Illinois Department of Financial and Professional Regulation (IDFPR) is the regulatory agency tasked with the licensure and discipline of individuals working in a broad range of professions. When a complaint is filed against an individual working in a regulated profession, it is IDFPR who investigates the validity of the complaint and, when warranted, issues one or more disciplinary actions against the licensee. These actions may include a formal reprimand, probation, suspension or revocation of a license, and more.

Not all of the actions taken by IDFPR are strictly disciplinary. There are four non-disciplinary actions the Department may choose to take in certain situations. One of these is called an Agreement for Care, Counseling & Treatment (CCT). A CCT is a confidential, non-public agreement between a licensee and the Department. It is a “written schedule of organized treatment care, counseling, activities, or education satisfactory to the Board” (ilga.gov). CCTs are intended to help an impaired licensee retain employment while also ensuring that he or she can practice with reasonable skill, safety, and competence.

Under a CCT, a licensee must seek out and complete an approved treatment program for alcohol or substance abuse. In addition to being confidential, a CCT agreement also allows a licensee to continue to practice his or her trade as long as the terms of the agreement are being followed.

Not all licensees are eligible for a CCT agreement. Several specific conditions must be met before the Department will consider a CCT. For example, to be eligible for a CCT agreement, a licensee must self-report his or her alcohol or substance abuse problem, as well as any adverse actions taken against the licensee by his or her employer. 

In the field of nursing, licensees must complete a Nursing Self-Report Form. This form requires the nursing licensee to report any adverse actions taken against him or her by entities including another licensing jurisdiction from any U.S. state or another country, a peer review body, a healthcare institution, a professional nursing association, government agencies, law enforcement agencies, or a court. The licensee must also report any past surrender of a license or his or her membership in a nursing staff or professional association. Licensed nurses must also report addiction or chemical dependence on any illicit or illegal drugs, including testing positive on any drug tests.

In this way, eligibility for a CCT and preventing the loss of a professional license depends entirely upon a licensee’s proactive steps to address personal issues that may impair his or her ability to safely and competently practice a profession. For the best possible outcome, licensees should also consult an experienced administrative law attorney to help them negotiate effectively with IDFPR and save themselves from more public forms of disciplinary action.

The information in this blog post is provided for informational purposes only and is not intended to be legal advice. You should not make a decision whether or not to contact an attorney based upon the information in this blog post. No attorney-client relationship is formed nor should any such relationship be implied. If you require legal advice, please consult with an attorney licensed to practice in your jurisdiction.

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