Individuals holding the credentials of CSAC and/or CSAC-A should not be able to practice independantly of supervision. As a CSAC since 1994, and an LSATP since 2001- I know the discrepancy between the training levels and significant gap in clinical skills needed to provide therapeutic services independantly. The basic education required for the CSAC credential is not comparable to the graduate level education of licensed counselors (allowed independant practice) and requires ongoing supervision.  Even case management services provided by someone with the CSAC credential requires a level of effective clinical skills, which need supervision. Therefore, I am glad to see that the BOC is addressing this issue , which has been an ongoing dispute because there are individuals that are independantly practicing CSAC's in Virginia. I dont know how they became independant but it has occurred and now we have a clearly stated response - which I agree with. There should be no independent practice by anyone with only the CSAC or CSAC-A  without supervision as specified by the governing entity of Virginia. 

I support the regulation that CSACs or CSAC-As should not practice without supervision; however, I believe the regulation should be clear in stating that the supervision can be both direct and indirect.  

The Virginia Association of Community Services Boards (VACSB) agrees with and supports this regulation.

Thank you.