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Program Statement 5330.11 at a glance

FieldValue
Program Statement5330.11, CN-1
SubjectPsychology Treatment Programs
Effective / current edition dateChange Notice CN-1 signed April 25, 2016, with a printed RULES EFFECTIVE DATE of May 26, 2016. The underlying Program Statement P5330.11 is dated March 16, 2009 (rules effective 3/16/2009)
Change noticeCN-1 — amends the March 16, 2009 Program Statement; it rewrites the § 550.53 and § 550.56 regulatory text carried in the manual
Supersedes / rescindsP5330.10, Inmate Drug Abuse Programs Manual (10/9/97)
Governing statute18 U.S.C. § 3621(e) (residential substance abuse treatment and the early-release incentive); 18 U.S.C. § 3624(f) (mandatory functional literacy) — the two statutes the Program Statement lists in its own reference block
Governing regulation (28 C.F.R.)Part 550, subpart F — §§ 550.50, 550.51, 550.52, 550.53, 550.54, 550.55, 550.56, 550.57
Related BP formsBP-A0748, Agreement to Participate in the Bureau of Prisons Non-Residential Drug Abuse Treatment; BP-A0749, Agreement to Participate in the Bureau of Prisons Residential Drug Abuse Treatment Program. Neither is posted publicly by the Bureau; both are named in the Program Statement text
Official PDFProgram Statement 5330.11, CN-1 (bop.gov)

Checked against the BOP policy set · 2026-09-06.

Program Statement 5330.11 is the Bureau of Prisons’ operating manual for every psychology treatment program it runs, from the twelve-hour drug education course up to the 500-hour Residential Drug Abuse Program. It tells staff who qualifies for each program, how a substance use disorder gets documented and diagnosed, how long each program runs, and what an incarcerated person can earn for finishing.

This page covers what the drug programs are and how a person gets into them. The separate § 3621(e) sentence reduction — who may receive up to twelve months off, and the seven categories the Director has excluded — lives on our page on RDAP early release procedures under 18 U.S.C. § 3621(e) (PS 5331.02). If you want the practical, day-to-day picture of what life in an RDAP unit looks like, start with the Residential Drug Abuse Program; if you are trying to work out where RDAP fits in a strategy to shorten a sentence already imposed, see RDAP and federal prison early release.

The rule itself: the four drug abuse programs, the RDAP admission criteria, and the incentives

Three discrete rule sets in this Program Statement are worth reproducing exactly, because they are what actually decides whether a person gets into treatment: the structure of the four programs, the admission criteria for RDAP, and the incentives listed at 28 C.F.R. § 550.54. Everything below is quoted from the Program Statement and from the current regulation, with the page anchor for each.

The four drug abuse programs and what each one requires

The Bureau describes this as a “multi-pronged treatment delivery system” running from education through community aftercare. The Program Statement sets out five stages:

ProgramRegulationWho it is forDuration and completion standard
Drug Abuse Education Course (DRUG ED)28 C.F.R. § 550.51“available to all sentenced inmates at every institution”; required for people who meet the § 550.51(b)(1) criteria“attendance of 12 to 15 hours, participation during sessions and successfully completing the course with 70% correct answers on the test”; “at least three chances to pass the final course exam”
Non-Residential Drug Abuse Program (NR DAP)28 C.F.R. § 550.52people waiting for RDAP; people who do not meet RDAP admission criteria; referrals; judicial recommendations; those detoxed on arrival; those found guilty of an alcohol or drug incident report“conducted 90 to 120 minutes a week for a minimum of 12 weeks and a maximum of 24 weeks”
RDAP — unit-based component28 C.F.R. § 550.53volunteers with “a diagnosable and verifiable substance use disorder” who can complete all three components“a minimum of 500 contact hours; i.e., face to face contact between treatment staff and inmate participants, over no less than 9 months of half-day programming”; “The RDAP has a duration of 9 to 12 months”; the regulation sets a floor of “at least six months”
RDAP — follow-up treatment28 C.F.R. § 550.53(a)(2)people who finished the unit-based component and returned to general population“An inmate must remain in Follow-Up Treatment (FOL PART) for 12 months or until he/she is transferred to a RRC”; groups “no less than 60 minutes”
RDAP — community treatment (TDAT / CTS)28 C.F.R. § 550.56people transferred to a Residential Reentry Center or home confinement“Ordinarily, inmates who participate in the TDAT must receive no less than a 120-day placement in an RRC”; refusal or failure means “they fail the RDAP and are disqualified for any additional incentives”

Source: PS 5330.11 at pp. 17–24, 30, 38–39; 28 C.F.R. §§ 550.51–550.53, 550.56.

Read the last row twice. The community component is not an optional coda. Under § 550.56(a), “For inmates to successfully complete all components of RDAP, they must participate in CTS,” and the Program Statement adds that the Warden “on the basis of his or her discretion, may find an inmate ineligible for participation in a community-based program.” A person who never reaches a halfway house never finishes RDAP, no matter how well the unit-based nine months went.

RDAP admission criteria — 28 C.F.R. § 550.53(b), quoted in full

This is the four-item list that decides admission. The first three are the regulation; the fourth is the Bureau’s implementing instruction.

#Criterion as writtenWhere it comes from
1“Inmates must have a verifiable substance use disorder.”28 C.F.R. § 550.53(b)(1), reproduced at PS 5330.11 p. 24
2“Inmates must sign an agreement acknowledging program responsibility.”28 C.F.R. § 550.53(b)(2), reproduced at PS 5330.11 p. 24
3“When beginning the program, the inmate must be able to complete all three components described in paragraph (a) of this section. This includes the critical RRC or home confinement transfer to participate in the TDAT.”28 C.F.R. § 550.53(b)(3) plus the Bureau’s added sentence, PS 5330.11 p. 24
4“Ordinarily, have 24 months or more remaining on their sentence.”Implementing instruction, PS 5330.11 p. 25

Source: PS 5330.11 at pp. 24–25; 28 C.F.R. § 550.53.

Two numbers in this Program Statement are frequently swapped by people repeating them second-hand, and they mean completely different things. Twenty-four months is about time left to serve: staff screen for “sufficient time remaining on the inmate’s sentence, ordinarily 24 months,” and interviews “will be conducted based on the inmate’s proximity to release, ordinarily no less than 24 months from release” (PS 5330.11 at pp. 27, 29). Twelve months is about the documentation window: the collateral records the Bureau will accept must show a substance use disorder “within the 12-month period before the inmate’s arrest on his or her current offense” (PS 5330.11 at p. 28).

What the Bureau will accept as verification of a substance use disorder

The Program Statement gives a closed list of examples of collateral documentation, then a warning about what will not count:

  • “Documentation to support a substance use disorder within the 12-month period before the inmate’s arrest on his or her current offense.”
  • “Documentation from a probation officer, parole officer, social service professional, etc., who has information that verifies the inmate’s problem with substance(s) within the 12-month period before the inmate’s arrest on his or her current offense.”
  • “Documentation from a substance abuse treatment provider or medical provider who diagnosed and treated the inmate for a substance abuse disorder within the 12-month period before the inmate’s arrest on his or her current offense.”
  • “Multiple convictions (two or more) for Driving Under the Influence (DUI) or Driving While Intoxicated (DWI) in the 5 years prior to his or her most recent arrest.”
  • “NOTE: Recreational, social, or occasional use of alcohol and/or other drugs that does not rise to the level of excessive or abusive drinking does not provide the required verification of a substance use disorder. Any verifying documentation of alcohol or other drug use must indicate problematic use; i.e., consistent with the American Psychiatric Association’s Diagnostic and Statistical Manual of Mental Health Disorders (DSM) criteria.”

Source: PS 5330.11 at p. 28.

If nothing in the Presentence Investigation Report or the Central File verifies a disorder, the Program Statement directs the Drug Abuse Treatment Specialist to meet with the person and read out six options — volunteering for the non-residential program, or obtaining documentation from a prior treatment provider, a probation or parole officer or social services professional, a medical examination for physical proof, or verification of a Bureau detoxification. On the paperwork route the manual is emphatic and easy to get wrong: “Documentation must be sent to, and received by, the drug abuse treatment staff in the institution. It is not to be sent to you for you to provide to the drug abuse treatment staff” (PS 5330.11 at pp. 28–29).

Even complete documentation does not settle it. The Drug Abuse Program Coordinator conducts a personal clinical interview and applies DSM criteria, and the Program Statement states plainly that “the DAPC may find the inmate does not have a diagnosis, even if there is substantiating documentation,” and separately may find that a person “cannot fully engage in treatment and does not qualify for the program, even if there is substantiating documentation” (PS 5330.11 at p. 30). That is a clinical judgment call vested in one staff member, and it is the single most common place a strong-looking application dies.

The incentives — 28 C.F.R. § 550.54, reproduced verbatim

ParagraphText of the regulation
(a)“An inmate may receive incentives for his or her satisfactory participation in the RDAP. Institutions may offer the basic incentives described in paragraph (a)(1) of this section. Bureau-authorized institutions may also offer enhanced incentives as described in paragraph (a)(2) of this section.”
(a)(1)(i)“Limited financial awards, based upon the inmate’s achievement/completion of program phases.”
(a)(1)(ii)“Consideration for the maximum period of time in a community-based treatment program, if the inmate is otherwise eligible.”
(a)(1)(iii)“Local institution incentives such as preferred living quarters or special recognition privileges.”
(a)(1)(iv)“Early release, if eligible under § 550.55.”
(a)(2)(i)“Tangible achievement awards as permitted by the Warden and allowed by the regulations governing personal property (see 28 CFR part 553).”
(a)(2)(ii)“Photographs of treatment ceremonies may be sent to the inmate’s family.”
(a)(2)(iii)“Formal consideration for a nearer release transfer for medium and low security inmates.”
(b)“An inmate must meet his/her financial program responsibility obligations (see 28 CFR part 545) and GED responsibilities (see 28 CFR part 544) before being able to receive an incentive for his/her RDAP participation.”
(c)“If an inmate withdraws from or is otherwise removed from RDAP, that inmate may lose incentives he/she previously achieved.”

Source: 28 C.F.R. § 550.54, reproduced at PS 5330.11 at pp. 35–36. The section runs (a) through (c); there is no paragraph (d) or (e).

The Program Statement puts dollar figures on the financial awards that the regulation leaves blank. For RDAP: “An inmate may earn a financial award to offset time lost from work. The amount of this award is $40 for each phase of treatment. However, a financial award may be reduced by the treatment team based upon the inmate’s participation and progress. A financial award is never to be increased” (PS 5330.11 at pp. 36–37). For the non-residential program: “When the participant successfully completes a NR DAP program, he or she may be awarded $30. This award will be pro-rated based on the inmate’s participation, but may never be adjusted higher” (PS 5330.11 at p. 23).

Paragraph (b) is the one that quietly disqualifies people. Falling out of compliance with the Inmate Financial Responsibility Program or with GED and literacy requirements does not get a person thrown out of treatment — it blocks the incentives that make finishing treatment worth the nine months.

What the psychology treatment programs mean for you

If you are the person inside: apply in writing and keep a copy

Apply in writing and keep a copy. Under 28 C.F.R. § 550.53(c), “Inmates may apply for the RDAP by submitting requests to a staff member (ordinarily, a member of the unit team or the Drug Abuse Program Coordinator),” and the Program Statement adds that you “may also apply for the program by submitting an Inmate Request to Staff form to the DAPC” (PS 5330.11 at p. 28). That is the BP-A0148 cop-out, and a dated copy of it is the only proof you will ever have of when you asked.

Do the documentation work before the interview, not after. If your Presentence Investigation Report is thin on substance use, the Program Statement’s six-option script is your roadmap: a treatment provider’s records “written at the time services were provided,” a probation officer’s letter, a medical examination, or verification of detox on intake. All of it goes directly to institution treatment staff, never through you.

Understand what refusing costs. Under § 550.53(h), a person who refuses, withdraws or is removed from RDAP “are not eligible for: (i) A furlough (other than possibly an emergency furlough); (ii) Performance pay above maintenance pay level, bonus pay, or vacation pay; and/or (iii) A Federal Prison Industries work program assignment (unless the Warden makes an exception on the basis of work program labor needs),” and “Refusal, withdrawal, and/or expulsion will be a factor to consider in determining length of community confinement.” The same consequences attach to refusing the drug education course under § 550.51(e), except that “The Warden may make exceptions to the provisions of this section for good cause.”

If you are a family member: finding the verifying documents

The documents that decide this are civilian documents, and they are usually in your hands, not your loved one’s. Old treatment discharge summaries, detox records, a letter from a probation officer, DUI dispositions — these are the collateral verification the Program Statement asks for. Get them, and send them to the Drug Abuse Program Coordinator at the institution directly. Do not mail them to your loved one to hand in; the Program Statement expressly forbids that route.

Set expectations about time. RDAP is not a short program: 500 contact hours over at least nine months of half-day treatment, then up to twelve months of follow-up in general population, then community treatment. The Bureau screens people in when they are ordinarily within twenty-four months of release, which means a long sentence often involves years of waiting before anything happens.

Do not describe your loved one’s history as recreational use in any document, letter or phone call that could end up in a file. The Program Statement states in terms that use which “does not rise to the level of excessive or abusive drinking does not provide the required verification of a substance use disorder.”

If you are counsel: psychology treatment

The leverage point is the sentencing record, and it comes before the Bureau ever sees the case. A judicial recommendation for drug programming is one of the four § 550.51(b)(1) triggers for the education course, and a Presentence Investigation Report that documents a DSM-consistent pattern of use in the twelve months before arrest is the difference between a clean referral and a “no verifying documentation” meeting. Objections to a PSR that understates substance use history are cheap at sentencing and expensive to fix afterward.

Watch the third admission criterion. A detainer, a deportation posture, or anything else that forecloses Residential Reentry Center placement makes a client “DAP UNQUALIFIED” under the Program Statement’s own worked example, because the community component becomes impossible (PS 5330.11 at p. 25). The manual also notes that if RRC status later changes — “e.g., a detainer lodged” — a person already participating “may remain in treatment,” and that a person found unqualified because of RRC ineligibility “is responsible for notifying the drug abuse treatment staff if there is a change in the inmate’s RRC status for reconsideration.”

Program complaints route through the administrative remedy system. 28 C.F.R. § 550.57 provides that “Inmates may seek formal review of complaints regarding the operation of the drug abuse treatment program by using administrative remedy procedures in 28 CFR part 542.” That is the exhaustion path, and it has short deadlines — see the section below.

What changed in the PS 5330.11 change notice

The document on bop.gov is a composite: a two-page Change Notice from 2016 bolted onto the front of a Program Statement issued in 2009. Reading only the 2009 body will give you superseded regulatory text, which is exactly the trap the Change Notice exists to close.

The base Program Statement, P5330.11, is dated March 16, 2009, with rules effective the same day. It rescinded P5330.10, the Inmate Drug Abuse Programs Manual of October 9, 1997, and rebuilt the Bureau’s psychology programming around evidence-based practice — adding inmate journaling, structured assessment, and the modified therapeutic community model to RDAP, and standing up the Resolve trauma program for women, BRAVE, the Challenge Program, and the mental health treatment units.

Change Notice CN-1 is signed April 25, 2016 and carries a printed “RULES EFFECTIVE DATE: May 26, 2016.” Those are two different dates for two different things, and the distinction matters when you are arguing about which text governed conduct at a particular time. The Change Notice replaced the regulatory text of § 550.50, § 550.53(a)(1), § 550.53(a)(3), § 550.53(f), § 550.53(g)(3) and § 550.56 that the 2009 manual carried.

The substantive shift in CN-1 is a renaming with consequences. The 2009 body calls the third component “Transitional drug abuse treatment (TDAT)” and titles § 550.56 “Community Transitional Drug Abuse Treatment Program (TDAT).” The Change Notice — and the current regulation — call it Community Treatment Services (CTS), and § 550.56 is now titled “Community Treatment Services (CTS).” The current regulation was amended at 81 FR 24490 (Apr. 26, 2016) and took effect December 29, 2016. Both names still appear in Bureau paperwork and in SENTRY assignments; they describe the same component.

One divergence to know about. The current § 550.53(g)(2) provides that “Ordinarily, inmates must be given at least one formal warning before removal from RDAP. A formal warning is not necessary when the documented lack of compliance with program standards is of such magnitude that an inmate’s continued presence would create an immediate and ongoing problem for staff and other inmates.” That warning requirement lives in the binding regulation. A removal that skipped it, with no documented immediacy, is a regulation-based argument, not merely a policy complaint — and the difference is significant, because a Program Statement is the Bureau’s internal instruction while the regulation in 28 C.F.R. is what binds the agency.

Where people get stuck without verifying documentation

“There is no verifying documentation in your file”

This is the most common dead end, and it is procedural rather than clinical. The Program Statement directs staff to meet with you, tell you there is no verifying documentation, and read out the six ways to fix it. If that meeting never happened, or happened without the options being explained, that is a departure from the Bureau’s own written procedure. Start with an Inmate Request to Staff (BP-A0148) to the Drug Abuse Program Coordinator asking, in writing, what documentation is missing and confirming what has been received. Then work the Administrative Remedy Program: informal resolution first, then a BP-9, which under 28 C.F.R. § 542.14 must be submitted within 20 calendar days of the event; then a BP-10 to the Regional Director within 20 calendar days of the Warden’s signed response, and a BP-11 to the General Counsel within 30 calendar days of the Regional Director’s signed response (28 C.F.R. § 542.15).

The clock ran out before a bed opened

Waiting lists are real and the Bureau does not publish them. Because the twenty-four-month screening window is tied to proximity to release, someone with a long sentence can spend years qualified but unscheduled, and someone with a short sentence can be screened too late to fit 500 hours plus follow-up plus a 120-day community placement into the time left. Ask your unit team in writing for your position on the list and the projected start date, and put the same question to the Drug Abuse Program Coordinator. If the answers do not match, that inconsistency is worth documenting. Where the real problem is the release date itself — a computation error, a missed transfer, a halfway house denial — that is a designation and computation issue and belongs in a consult, not a grievance about the treatment program.

An incident report ended the program

Under § 550.53(g)(3), removal is immediate if the Discipline Hearing Officer finds a person committed a prohibited act involving alcohol, drugs, violence or escape. That makes the underlying disciplinary case the thing that matters, not the treatment appeal. Defend the incident report on its own terms and on the record — because the companion Program Statement provides that if an expelled participant “is later found not guilty by the DHO,” treatment staff meet to decide whether reinstatement is clinically appropriate, and the sentence computation is corrected accordingly.

No halfway house means no completion

Because community treatment is a required component, a Residential Reentry Center denial or a short placement can end RDAP after the hard part is finished. The Program Statement is direct about the threshold: “Bureau experience and drug abuse treatment research demonstrate that successful community treatment cannot be completed in less than 120 days” (PS 5330.11 at p. 37). It also instructs that “Each Warden is strongly encouraged to approve inmates who successfully complete the RDAP for the RRC placement.” A short or denied placement is therefore a halfway house placement problem first. Whether any of this affects a particular release date is a computation question for the Bureau in the first instance, and nobody outside the Bureau can tell you the answer in advance.

PageWhat it covers
The Residential Drug Abuse ProgramHow RDAP actually works day to day — the unit, the schedule, the community
RDAP and federal prison early releaseWhether and how RDAP fits a strategy to shorten a sentence already imposed
Early Release Procedures Under 18 U.S.C. § 3621(e) (PS 5331.02)The up-to-twelve-month reduction, the exclusions, and how the date is set
Categorization of Offenses (PS 5162.06)The list the Bureau’s legal staff use to decide whether an offense precludes early release
Psychology Services Manual (PS 5310.17)Intake screening, counseling, and the wider psychology service
Treatment and Care of Inmates With Mental Illness (PS 5310.16)Mental health care levels and the co-occurring-disorder track
Female Integrated Treatment (PS 5240.01)The integrated treatment model at women’s facilities
Inmate Financial Responsibility Program (PS 5380.08)The FRP compliance that § 550.54(b) makes a precondition of every incentive
Administrative Remedy Program (PS 1330.18)The BP-8 through BP-11 route and its deadlines

Frequently Asked Questions About Psychology Treatment Programs

How long is RDAP?

The Program Statement sets RDAP at “a minimum of 500 contact hours; i.e., face to face contact between treatment staff and inmate participants, over no less than 9 months of half-day programming,” and states that “The RDAP has a duration of 9 to 12 months” (PS 5330.11 at pp. 24, 30). That is only the unit-based component. Follow-up treatment in general population runs for twelve months or until transfer to a halfway house, and community treatment ordinarily requires a placement of no less than 120 days.

Do I have to have a drug charge to get into RDAP?

No. The admission criterion under 28 C.F.R. § 550.53(b)(1) is a “verifiable substance use disorder,” which is a clinical question about your history, not a question about your offense of conviction. Whether the offense matters is a separate question that affects only the § 3621(e) early-release incentive, not admission to treatment — the Program Statement says so directly: “Inmates with a diagnosis of a substance use disorder are qualified for the RDAP whether or not they are eligible for the early release incentive.”

What documents prove a substance use disorder?

The Program Statement lists treatment or medical records diagnosing and treating a substance use disorder within the twelve months before arrest on the current offense, a letter from a probation officer, parole officer or social service professional verifying a substance problem in that same window, and two or more DUI or DWI convictions in the five years before the most recent arrest (PS 5330.11 at p. 28). All of it must be sent directly to institution treatment staff, and it must show problematic use consistent with DSM criteria — records describing recreational or occasional use will not satisfy the requirement.

How much money do you get for completing RDAP?

The Program Statement sets the RDAP achievement award at “$40 for each phase of treatment,” subject to reduction by the treatment team and never to increase, and the non-residential program award at “$30” on successful completion, pro-rated by participation (PS 5330.11 at pp. 23, 36–37). Under 28 C.F.R. § 550.54(b) no incentive is payable unless financial responsibility and GED obligations are met.

What is the difference between RDAP, NRDAP and drug education?

Drug education is a twelve-to-fifteen-hour course with a final exam, available at every institution and required for people who meet the § 550.51(b)(1) criteria. The non-residential program runs 90 to 120 minutes a week for twelve to twenty-four weeks and is voluntary. RDAP is the residential program — 500 hours over at least nine months in a treatment unit “set apart from the general prison population,” followed by follow-up treatment and community treatment. Only RDAP carries the § 3621(e) early-release incentive.

What happens if I get kicked out of RDAP?

Under 28 C.F.R. § 550.53(h), a person who refuses, withdraws or is removed loses eligibility for furloughs other than possibly an emergency furlough, for performance pay above maintenance level and for bonus and vacation pay, and for a Federal Prison Industries assignment unless the Warden makes a labor-needs exception; refusal, withdrawal or expulsion also becomes “a factor to consider in determining length of community confinement.” Section 550.54(c) adds that a person who withdraws or is removed “may lose incentives he/she previously achieved.”

Can I appeal being turned down for RDAP?

Yes, through the Bureau’s administrative remedy system. 28 C.F.R. § 550.57 provides that “Inmates may seek formal review of complaints regarding the operation of the drug abuse treatment program by using administrative remedy procedures in 28 CFR part 542.” That means informal resolution, then a BP-9 within 20 calendar days of the event, a BP-10 within 20 calendar days of the Warden’s response, and a BP-11 within 30 calendar days of the Regional Director’s response.

Is there an RDAP for people with mental health diagnoses too?

Yes. The Program Statement provides that “The Bureau also operates RDAPs for inmates with co-occurring substance use and serious mental health disorders,” with “an additional track for inmates with a co-occurring diagnosis that focuses on understanding one’s disorder, issues with self-medicating and how to manage prescribed medications and medication compliance,” and a staff-to-inmate ratio of one to eight rather than the standard one to twenty-four (PS 5330.11 at p. 25). Referrals go through the Regional Psychology Programs Coordinator.

Applied Insight — Christopher Zoukis, JD, MBA, Managing Director: When we look at an RDAP file, the first thing we read is not the application — it is the Presentence Investigation Report, because that is where the Bureau looks first for verification. The second thing is the SENTRY assignment history, because the codes record when a person was screened, referred, qualified or found unqualified, and by whom. A file that shows a documented DSM-consistent history in the year before arrest, a dated written application, and no barrier to a halfway house transfer is a file that has done everything a person can control. Nothing about that guarantees admission or any particular release date; those remain decisions for the Bureau.

This page is general information about federal prison policy and is not legal advice; whether any of it applies to a particular sentence is a fact question for the Bureau of Prisons in the first instance. Elizabeth Franklin-Best, P.C. is a federal criminal defense and post-conviction practice serving clients nationwide, with offices in Columbia and Mount Pleasant, South Carolina — (843) 620-1100.


Full text of the Program Statement

The Bureau’s own text of Program Statement 5330.11 runs to 64 pages, so we have reproduced it in full on a separate page: Program Statement 5330.11 — Psychology Treatment Programs (full text).

Reviewed for legal accuracy by Elizabeth Franklin-Best, Esq., Principal Attorney·September 2026

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