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Virginia Regulatory Town Hall
Department of Health Professions
Board of Counseling
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4/17/19  10:54 am
Commenter: Addiction Recovery Systems (ARS)

Concern with Clarifying Information Paragraph

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.”