Comments on: Clarifying Information
The scope of practice for CSACs includes substance abuse counseling with individuals and
groups. The Code of Virginia § 54.1-3507.1 indicates that CSACs are “qualified to be
responsible for client care of persons with a primary diagnosis of substance abuse or
dependence.” Providing counseling to persons with a dual diagnosis is outside the scope of
practice for CSACs. As such, CSACs cannot provide counseling to persons with a dual
diagnosis.

The above Clarification Information states that "CSACs cannot provide counseling to persons with a dual
diagnosis."  This is somewhat confusing, since most patients with a "primary diagnosis of substance abuse or dependence," if properly assessed, will also have some type cooccuring disorder.  I agree that the CSAC must stay within his/her area of competency of providing appropriate care interventions to persons with a primary diagnosis of substance abuse or dependence, but this will often time occur with a person who is "with a dual diagnosis."  If a clarification note is necessary, perhaps it be better to state something like "When counseling or providing other related substance use services to individuals with a primary diagnosis of substance abuse or dependency, if the person with the primary diagnosis of substance abuse or dependency is also dually diagnosed, the CSAC is not permitted to address those clinical areas that are within the individuals dual diagnosis." 

It would appear that the term "dual diagnosis" is an outdated term and may be replaced with "cooccuring disorder" as a term.  Also, it appears that moving from "substance abuse or dependency" to "use disorder" is a more current term.

Thank you for the opportunity to provide feedback on this this important process of providing clarification to scopes of practice.

Stephen Shearer

LADC, CADC, Certified Clinical Supervisor, Certified Employ Assistance Professional, Certified Professional in Healthcare Quality, Certified Joint Commission Professioinal.