I am the petitioner and I would like to clarify my petition. Virginia law states that a CSAC shall “not engage in independent or autonomous practice.”  However, the law also states “Such counselor shall also be clinically supervised or directed by a licensed substance abuse treatment practitioner, or any other mental health professional licensed by the Department…”  A CSAC may misinterpret this to mean a CSAC is to “not engage in independent or autonomous practice” but can if “under appropriate supervision or direction” and are “clinically supervised or directed.” I made this petition because the current CSAC regulations do not clearly state that a CSAC shall “not engage in independent or autonomous practice” and because it appears there are CSACs currently practicing independently in Virginia. I have also asked to add “regardless of supervision status except if supervision is for the purpose of seeking licensure in Virginia.”

The previous comment suggesting CSACs be allowed to practice independently under supervision undermines the entire distinction between certification and licensure. Licensure residents must undergo rigorous requirements: graduate degree; supervision (which must be from an LPC or LMFT who has had 20 hours of Clinical Supervision Training); 3,400 work hours; 200 hours (1-4 hours per 40 hours of work); and are not allowed to take direct payment from clients. So, to suggest that a CSAC be allowed to practice under supervision that is not defined in any way seems inappropriate. Also, why would it be acceptable for a CSAC to “be supervised by a…LCSW, clinical psychologist, psychiatrist, or addictionologist” when that is not allowed for LPC or LMFT residents? LCSWs are regulated under a different Board and the term addictionologist is misleading because no substance abuse national certification allows CSACs to practice independently in Virginia.

The issue of independent practice and practicing under supervision for CSACs is mixing apples and oranges. This petition is not about whether or not a CSAC is capable of working with clients even if under supervision, it’s about knowing and following Virginia law as it’s currently written. It’s also important to know the limitations of practice for both CSACs and LSATPs so I recommend reading the Board of Counseling Guidance Document 115-11 from January of this year.