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."