I would like to tack on one more question to your post, if I may. I agree with you that it is not clear in the course whether counselling is mandatory or the "ability to refer for counselling" is mandatory. Do the DEA Inspectors check to see if we are referring for counselling, or are they only checking on patient count and Rx history? I would tend to think that it is none of their business, but I have heard of them asking all sorts of irrelavent things in other posts.
I am relatively new at this (and not a Psychiatrist), but I insist on a minimum of attending meetings, NA or AA. I do not require proof, but tell them that I reserve the right to randomly require proof. That keeps them somewhat honest. I offer references for professional counselling, Psych or PhD, but find that few patients want to pay for it.
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