From Board Insights, Episode 1, featuring Catrice Opichka, Director of CARE Programs, CRDTS
When a board orders remediation, the most common structure is a fixed curriculum. A set of courses, a hours requirement, a completion deadline. The licensee moves through the sequence, submits proof of completion, and the board closes the case.
That structure has the advantage of being clean. It is easy to order, easy to verify, and easy to defend procedurally. Every licensee ordered into the same program is treated the same way.
But the structure also has a cost that does not show up on the completion record. A licensee who needed very little of the curriculum sat through it anyway. A licensee who needed far more than the curriculum provided finished it and was documented as remediated. The remediation served one of them well and the other barely at all, and nothing in the file surfaces the difference.
The Boot Camp Problem
Catrice Opichka has a direct way of describing the default model:
“The easy route when it comes to remediation is just put them into a number of courses, and you have the standardized coursework. What we do that is different is everything that we do, we use a pre-assessment to guide the education.”
The word she uses for the standardized model is boot camp. Everyone runs the same track. The structure assumes the problem is roughly the same across licensees, or at least that the same response will work well enough across a wide range of cases. In her experience running remediation across multiple professions, that assumption rarely holds.
What Pre-Assessment Changes
The alternative is not a longer or more intensive curriculum. It is a sequencing change. Assess first, then design the remediation around what the assessment surfaced.
Opichka describes how her team applies the principle:
The operating logic is straightforward. Remediation time is a finite resource. Every hour spent on something the licensee already demonstrates competence in is an hour not spent on the area that actually needs work. A standardized program treats every licensee as if every hour is equally useful to them. An assessment-guided program allocates hours based on evidence.
This has a secondary effect that matters for boards. When a licensee completes remediation that was targeted at their actual gaps, the completion documentation means something specific – that the identified issue was addressed. When a licensee completes standardized remediation, the completion documentation means something more limited – that the licensee sat through the prescribed program. Both are compliance events. Only one is evidence of change.
The Defensibility Angle
Boards frequently face questions about why a particular remediation plan was chosen, particularly when a case involves public exposure or when a licensee re-offends after completion. Standardized remediation is defensible on procedural grounds – it is the same program every licensee gets. But procedural consistency is not the same as individualized fit, and when a case draws scrutiny, the question is often not “did the board apply its standard process” but “was the standard process adequate for this licensee.”
A remediation plan designed around pre-assessment results answers that second question on the record. The plan reflects a documented understanding of what this licensee’s specific gaps were. The remediation components map to those gaps. If the remediation did not work, the file shows what was attempted and why. If it did work, the file shows the same.
Where Assessment Fits
CRDTS structures its CARE program around this sequence. Ethics is assessed first. The assessment result shapes what the remediation emphasizes, and what it skips. The result is a program that spends its time on the licensee in front of it, not on the average licensee across cases.
For boards, the practical implication is smaller than it sounds. Ordering the assessment before the remediation is a sequencing change in the consent order. What changes is where the assessment output lands in the design of the remediation program that follows.
About Board Insights
Board Insights is a recurring conversation series from EBAS featuring practitioners working in regulatory enforcement, remediation, and licensee oversight. Each episode explores practical questions boards face and the patterns that experienced professionals see across cases.
Watch the full episode with Catrice Opichka
