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It would appear that the term "dual diagnosis" is an outdated term and may be replaced with "cooccuring disorder" as a term.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.

Agree with the comments/concerns noted by Stephen Shearer related to "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".

As stated many individuals with a substance use disorder diagnosis have a co-occurring diagnosis.  If CSACs cannot provide counseling for those with a dual or co-occurring diagnosis, this presents individuals seeking substance use disorder treatment with fewer options for seeking counseling.  This is a concern and places unnecessary barriers to receiving treatment.

CSACs must stay with his/her competency of providing appropriate interventions related to the individuals' substance abuse disorders.  However, CSACs should not be excluded from providing services to those with a co-occurring diagnosis.   Recommend the clarification to be changed to "CSACs provide individuals with a primary diagnosis of substance use disorder counseling and other related substance use recovery services.  If a person with a primary substance use disorder diagnosis and another co-occurring diagnosis, the CSAC is only permitted to provide services related to the individual's substance abuse disorder diagnosis."

This comment supports the previously noted concerns of Stephen Shearer and Lisa Snider regarding the Board of Counseling’s “Clarifying Information” paragraph, stating, in relevant part, that “[p]roviding 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.”

ARS agrees with Mr. Shearer and Ms. Snider that CSACs must provide appropriate intervention services by staying within his/her area of training and competency, and we believe this understanding is consistent with the language of Virginia Code Section 54.1-3507. The code section identifies what a CSAC must be qualified to do. The only express limitation is that they “shall not engage in independent or autonomous practice.” Respectfully, we believe an additional limitation that prevents CSACs from providing any services to individuals with a co-occurring diagnosis, as outlined in the clarifying note, exceeds the scope and intent of the statute.   

Further, it is well accepted that individuals seeking substance abuse treatment may frequently have a co-occurring diagnosis. We find the Board of Counseling’s current interpretation of Virginia Code Section 54.1-3507 to be inconsistent with the national movement of holistic mental health treatment and have concerns that this interpretation may ultimately have the unintended consequence of discouraging or preventing individuals with a co-occurring diagnosis from receiving necessary treatment.

To the extent a clarifying note is necessary, we request that the Board of Counseling consider the following:

“The Code of Virginia § 54.1-3507.1 indicates that CSACs shall be “qualified to be responsible for client care of persons with a primary diagnosis of substance abuse or treatment.” If the person seeking treatment has a co-occurring diagnosis, the CSAC’s intervention services shall be limited to substance abuse treatment and appropriate referral activities.”