The New York State Association of CASAC Professionals has submitted formal public comments to the New York State Office of Addiction Services and Supports regarding proposed amendments to 14 NYCRR Parts 800 and 836. The proposed changes were published in the July 1, 2026, New York State Register.
The Association supports OASAS’s proposal to include Credentialed Prevention Professionals within the definition of a Qualified Health Professional. This change recognizes the evolving education, competency, and responsibilities of credentialed behavioral health professionals while helping providers respond more effectively to workforce shortages and increasing demand for prevention and treatment services.
The Association also used the public comment opportunity to raise a larger workforce issue: whether New York’s current regulatory framework fully reflects the responsibilities already assigned to professionals holding the CASAC Advanced credential.
Today, CASAC Advanced professionals may conduct comprehensive substance use disorder assessments, complete the LOCADTR, determine appropriate levels of care, develop treatment recommendations, supervise clinical staff, and serve as program directors when regulatory qualifications are met. These responsibilities demonstrate how far the substance use counseling profession has evolved and how much clinical trust OASAS has already placed in advanced credentialed professionals.
Although the Association did not request changes to Part 822 through this specific rulemaking, it encouraged OASAS to review whether current admission approval requirements remain aligned with the work CASAC Advanced professionals already perform.
The Association formally requested that OASAS continue modernizing the behavioral health workforce, evaluate how advanced addiction professionals are used across the regulatory system, engage professional associations and other stakeholders in future discussions, and undertake a comprehensive review of the regulatory authority associated with the CASAC Advanced credential.
This public comment reflects the Association’s commitment to ensuring that regulations keep pace with the real responsibilities CASACs carry every day. Stronger recognition of advanced credentials can improve workforce flexibility, support professional advancement, reduce unnecessary barriers, and strengthen access to high-quality care across New York State.
The full public comment is available for download through the NYS CASAC Association
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