I would recommend the following change/addition:  "CSAC's may practice in public or private agency settings only under the supervision of a Virginia licensed  LPC, LCSW, clinical psychologist, psychiatrist, or addictionologist." 

I agree and support this petition. More oversight is needed and this is an incremental step in the right direction. 

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.

I agree with the petitioner, Sharon Watson, that there should be better clarification and regulatory oversight regarding the supervision of those certified substance abuse counselors who are not licensed, nor working toward licensure, to practice independently.

I fully support the petition.  Well defined regulations and regulatory oversight regarding supervision and practice of certified substance abuse counselors (CSAC) who are not licensed, nor working toward licensure, to practice independently is absolutely necessary.  The law is vague and has the potential to put clients’ welfare in harm’s way by CSAC’s practicing independently, by misinterpreting “unless under supervision”.  The law clearly states that residents in counseling may not practice independently until they are fully licensed.  The regulations need to be just as clear with CSACs.

Protecting the public from harm during the provision of counseling services is of top priority. Independent practice should be limited to clinicians who have completed a licensure process. Absolute clarity on this is essential. Thank you.

Residents in Counseling have to work arduously toward licensure and allowing independent CSACs to work and receive payment does not seem equitable to Master's level Clinical Mental Health master's students working toward their many hours. Thank you for your consideration.  

I have never heard of a person with an CSAC practicing independently during my 28 years  as an addiction professional in Virginia; every addiction professional with the CSAC that I know or have known always worked under the supervision of a Certified Clinical Supervisor or licensed professional, such as myself.  I think that if you find a CSAC practicing independently when VA. Code states otherwise - that you as a certified or licensed professional should fulfill your ethical duty and report it for investigation instead of trying to restrict CSAC supervision to just those with the LPC, LCSW and LMFT! It  appalls me when someone wants to restrict and/or advocate for "only" their credentials being able to provide a service related to the treatment of individuals with addictive disorders, while leaving out the LSATP. Why is the LSATP not mentioned in this petition, when we are the ones with the specialty training and allowed to supervise CSACs folks in private and public settings for certification? We completed those 60 hours graduate school and everything else for licensure, too whereas LPC’s have one course requirement on SUD and LCSW's have no formal training. 

While, addiction professionals with the CSAC only should be supervised when practicing in public and private settings, I am not in support of this petition to restrict CSAC supervision to practice only under LPC, LCSW and LMFT's  because they should NOT have a monopoly - when Virginia has LSATP's with specialization in SUD and Co-occurring disorders that are the current approved providers of supervision for certification.  I think the petition should read .....can only practice in public and private entities under the supervision of an LSATP, a Certified Clinical Supervision with an CSAC and/or a national SUD credential  or an LPC with an SUD credential.

I am in support of the petition.   The regulation could be misinterpreted and therefore needs to be clarified, for the benefit of both the CSAC and the clients they will be serving.  

In support of this petition

I agree that CSAC's should not be allowed to practice independently as they do not have the same level of education, training, and supervision as licensed mental health professionals.  

It needs to be clearly stated that CSAC's are not allowed to practice independently. Why would the rules be so vastly different for them compared to other mental health practitioners?  It is not in the best interest of the people who are seeking the services of a CSAC to allow for a lack of training and competence in the field.  The public deserves better and the law should be clear.

I support this petition

I  fully support the Petition and suggestions to bring more clarity to the regulation to protect the public by preventing "certified" and not fully qualified counselors to practice independently.  

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.