It is our intention to reiterate what has been stated by other providers regarding the limitations placed on CSAC/CSAC-Supervisee scope of practice.

It is with extreme concern that we strongly suggest the Department rethinks its plan to remove the CSAC as a CATP in our ARTS programs and requiring only  Licensed individuals or individuals under supervision for licensure. We have been effectively employing Bachelors and Masters level CSACs in primary roles, performing ISPs , multidimensional assessments, etc. - many are individuals in recovery, individuals from diverse backgrounds with years of experience , who should not be replaced with individuals just completing a Master’s degree. Our CSACS’s work under the supervision of licensed supervisors and we believe that should be  feasible going forward. They could work in the same capacity as a Masters level individual under supervision for licensure. The consequence for this change will likely create an equity staffing issue and possible termination of long term, quality  employees who are not licensed or currently license eligible. These qualified, experienced staff members would then be replaced with novice, Master's level clinicians who are not as competent to work with our population. Thus, this change would cause a reduction in the quality of services and likely a dramatic reduction in the number of patients able to be served.