While the VACSB does not have concerns with the proposed new language, some of the code citations referenced in the regulations would benefit from clarification as follows:

§ 54.1-3507.1. Scope of practice, supervision, and qualifications of certified substance abuse counselors.

Paragraph A, romanette i:

• replace the first occurrence of the word “of” with a colon
• in the second occurrence of the phrase “substance abuse treatment,” replace the word “treatment” with “individual and group counseling.”

§ 54.1-3507.2. Scope of practice, supervision, and qualifications of certified substance abuse counseling assistants.

Paragraph A:

• After the word “professionals” at the end of the first sentence, insert a new sentence reading “Certified Substance Abuse Counselor Assistants shall not independently engage in the administration of substance abuse assessment instruments or the development of substance abuse treatment plans.”