Not allowing a CSAC to be considered a CATP: We are already struggling with staff shortage due to not being able to find qualified applicants that are licensed and/or licensed eligible that have the SU component experience in our area. Taking away the ability of a CSAC to provider SU services would hinder our services greatly.

Requiring a psychiatrist/physician to consult and be included on PAs could delay authorizations as well as individuals receiving treatment/services. We are already having difficulty with our psychiatrists being available.