One previous comment shows a misunderstanding of my goal for this petition and I am writing this to be sure the Board of Counseling does not misunderstand my goal as well.

I am attempting to differentiate between a CSAC working within a group practice, addictions program, or substance abuse treatment program/company under clinical supervision (from a licensed clinician: LPC, LMFT, LSATP) and a CSAC who is working in their own private practice (i.e. their own rented space, billing and accepting payment independently, without a supervisor on-site).  My petition is an attempt to not change the first, but to confirm that the latter is not allowed under Virginia law and to confirm that it states so in the CSAC regulations, which currently do not.  And also, that the latter not be allowed even if the CSAC is under ANY supervision from ANY licensed supervisor.

I did not suggest LCSWs be allowed to supervise CSACs because they are currently not allowed to supervise any licensure candidate.

I understand that pre-certification supervision of a supervisee can be by a LSATP or LPC/LMFT with specific SA qualifications, but my petition is to address supervision AFTER certification and to clarify that a CSAC cannot have a private practice EVEN IF under supervision, regardless of who provides it.  And the regulations are not clear on that.

I believe the use of the term “Certified Clinical Supervisor” is confusing because there is no “Certification” in Virginia to supervise.  Also, suggesting that a CSAC be supervised by someone with a national certification is confusing as well, since Virginia does not recognize pre-certification supervision from a nationally certified SA counselor as acceptable supervision.

Additionally, my petition’s intent is not to advocate for “only” LPCs and LMFTs to supervise CSACs working within a practice.  That is a misunderstanding. I was comparing the requirements for supervision of LPC/LMFT residents to CSACs (already certified) and did not mention LSATPs because LSATPs are not allowed to supervise LPC/LMFT residents. CSACs should be supervised by licensed individuals (including LSATPs).

But again, my petition is specifically meant to add what is stated in Virginia law to the CSAC regulations and the CSAC Handbook: that a CSAC shall “not engage in independent or autonomous practice” and to add the following “regardless of supervision status.”  Since Virginia law and the regulations do not state “regardless of supervision status” it is conceivable a CSAC could misinterpret the law and believe they are allowed to have a private practice if under off-site supervision.  My petition is an attempt to close the gap of possible misinterpretation.