CSAC no longer a CATP – we already have multiple positions for which we are unable to hire. If the CSAC and CSAC supervisees are no longer able to provide substance use disorder counseling and psychoeducational services within the scope of their practice, this has potential to significantly limit access to care in our region.
CSAC cannot complete ASAM assmt or ISP for several service levels - same comment as above
Peers must be certified and registered with the Board-- we have several open peer positions despite active recruitment efforts. Medicaid reimbursement for peer services and requirements surrounding their clinical work results in the inability for peer billing to sustain a peer position. This results in low salaries for peers. Increasing individual peer paperwork requirements is likely to result in even greater difficulty in recruitment of individuals to these positions.
Requiring psychiatrist/physician to consult and include name on many service authorizations. – we have many clients waiting to receive psychiatric services. If the psychiatrists time is diverted to consult and become involved in service authorizations, this has the potential to significantly impact access to care of clients. In addition, ancillary staff would need to be hired to coordinate this administrative burden, which will likely result in decreased availability of other clinical staff such as nurses for clinical care.
