Virginia Regulatory Town Hall
Health and Human Resources
Department of Health Professions
Board of Counseling
Petition 327
Petition Information
Petition Title Clarity on independent practice by certified substance abuse counselors
Date Filed 7/9/2020    [Transmittal Sheet]
Petitioner Sharon Watson 
Petitioner's Request

To amend regulations to specify that CSACs cannot engage in independent or autonomous practice regardless of supervision and that such practice may be grounds for disciplinary action.

Agency's Plan

In accordance with Virginia law, the petition will be filed with the Register of Regulations and published on August 3, 2020 with comment requested until September 2, 2020.  It will also be placed on the Virginia Regulatory Townhall and available for comments to be posted electronically.


At its first meeting following the close of comment, which is scheduled for November 6, 2020, the Board will consider the request to amend regulations and all comment received in support or opposition.  The petitioner will be informed of the board’s response and any action it approves.


Comment Period Began 8/3/2020    Ended 9/2/2020
Virginia Register Announcement Submitted on 7/9/2020
The Virginia Register of Regulations
Published on: 8/3/2020     Volume: 36  Issue: 25
Agency Decision Take no action [Transmittal Sheet]    
Response Date 11/6/2020
Decision Publication Date Published on: 12/7/2020     Volume: 37  Issue: 8
Agency Decision Summary

The Board decided not to initiate rulemaking but did refer the issue of practice by certified substance abuse counselors to the Regulation Committee for development of guidance to clarify the law and regulation.

Contact Information
Name / Title: Jaime Hoyle  / Executive Director
Address: 9960 Mayland Drive
Suite 300
Richmond, 23233
Email Address:
Telephone: (804)367-4406    FAX: (804)527-4435    TDD: ()-