Some of the revisions within the ARTS manual are appreciated and positive; however, there are also some revisions that hinder clients access to care.  It is noted that the "CATP" definition has been revised to omit CSAC/CSAC-Supervisees.  With this revision CSAC/CSAC-Supervisees can no longer complete treatment planning and pieces of the assessment in some of the ASAM Levels of Care such as IOP and PHP.  This language also directly conflicts with the "Board of Counseling Scopes of Practice for Persons Regulated by the Board to provide Substance Abuse Treatment."  This document clearly states that CSAC/CSAC-Supervisees do have the ability to conduct pieces of the assessment and treatment planning.  It is also noted that CSAC/CSAC-Supervisees are able to conduct these pieces in the higher/more intensive ASAM levels of care.  If these revisions go through we will not be able to open individuals into treatment as quick as our CSAC/CSAC-Supervisees can no longer be supportive in this way.  It should also be noted that it is difficult to find licensed and licensed-eligible individuals that are trained and have experience in addiction treatment; whereas, CSAC/CSAC-Supervisees specialize in working with the SUD population.  

I am proposing that the language be revised and clearly define a CSAC/CSAC-Supervisee's ability to conduct pieces of the assessment and treatment planning under the direct supervision of a licensed professional for SUD Treatment in the ASAM levels of care such as IOP and PHP.  

Thank you!