Giving the difficulties of finding both licensed and certified staff, I am disappointed that CSACs will no longer be considered credential addiction treatment professionals (CATP). Also with the additional responsibilities of a licensed staff, I propose that temporary rate increases become permanent. This may help with recruitment.

Please with the increase membership participation in groups. My major concern and a clarification that needs to be made is the conflict between the proposed DMAS regulation, as it relates to staffing, compared to the "draft" licensure regulations as it relates to 3.5 LOC (residential) staffing; especially, during i.e. midnight shifts.

DMAS: "Staff shall provide 24 hours per day awake supervision on site. The provider's staffing plan must be in compliance with DBHDS staffing plan regulations set forth in 12VAC35-105-590 and12VAC35-46-870. However, the DBHDS draft licensure reads: 12VAC35-107-980--clinically managed high-intensity residential services (ASAM LOC 3.5) staff criteria...offer onsite 24-hour a day clinical staffing by credentialed addiction treatment professionals..... Are saying licensed & certified need to be present on midnight shifts and shifts, usually after 8 pm when "treatment sessions" are not going on. Please note that I advocate for the application of the DMAS version versus the DBHDS licensure version.