I am submitting comment to strongly encourage that CSAC's continue to be considered CATP's.  The "Board of Counseling Scopes of Practice for Persons Regulated by the Board to provide Substance Abuse Treatment" states that CSAC/CSAC-Supervisees are able to conduct pieces of the assessment and treatment planning in various levels of care and these individuals specialize in SUD treatment. As a provider, this would significantly impact our ability to provide the necessary services for the population by individuals who are fully qualified, impact our ability to grow and expand services in process, and this would cause significant barriers in access to the care that is so desperately needed. 

I ask that you please consider CSAC/CSAC-Supervisees as CATP's. 

Thank you!