I am not in support of the added requirements for re-activating an inactive license.  It is not unusual for a parent to want to take off some time from practicing after having a child in order to be a stay at home parent for a period of time when a child is young.  It makes sense for someone to be able to drop their status and fees to inactive status during this period of time.  The new requirements to work in an exempt practice for time or needing to re-register for Board approved supervision for a period of time prior to being able to bring their license back to active status would be difficult to meet.  Many practitioners would want to resume private practice or as a position in a for-profit company, which they would not be able to immediately do under the proposed regulations.

Positions in exempt practice settings are 1) unclear which employers would qualify, and which positions would count towards the experience requirements; 2) limited in availability; 3) may pay at lower salaries, limiting someone from resuming a similar pay upon resuming work after a period of time off.  The other option of practicing as a resident presents similar challenges, as there are limited positions available for practice as a resident, different than someone with an active license; employers would likely not want to hire if someone only needs the 360 hours and then may move to a different position with their active license again; positions are a different pay level than as a license, requiring someone to take a pay drop from where they stopped working with an active license as well as additional expense of paying for a licensure supervisor for that time period, if one is not available at the place of employment (creating additional burden on employers to provide for someone who has been licensed in VA before), and additional delay of waiting to start employment (depending on the position) of waiting until the Board approves the position as the Board is continuing to have delays of 3+ months in reviewing and approving applications for registering superivision, required before starting the job duties.  Thus this requirement would also add additional burden to the Board of requiring more people to go through this registering supervision process.  The requirement also limits positions that people can resume employment in, since the Board requires 15 Social Work clinical hours per week while under registration, and to have a caseload rather than only assessments, which also limits how someone can resume employment.

Requirements to allow inactive status up to a maximum of five years and to show documentation of CEU's during that time are already in place to ensure that LCSW's are not resuming employment after breaks of too long of length or without staying current on training during that time. 

It appears with the proposed regulations that an LCSW could avoid the requirements of exempt practice or registered supervised practice by keeping the LCSW license active during a period of not practicing rather than entering "inactive status", but if someone is entering that status due to taking a break from work, which could be for raising a young child or due to illness, it is more of a challenge to continue the higher active status fees while not working, such that the reduced rate for Inactive status is more appropriate.

I have not heard of complaints of people choosing to see a provider who resumed practice from inactive status to prompt this proposal, but if there was rationale for the proposal based on concerns the Board has seen, I would recommend an alternative instead that allowed someone to resume their LCSW license at the full level with current requirements in place, but perhaps some alternative for supervision such as requiring supervision or consultation for the first 3 months or 360 hours, but still being able to resume as an LCSW in any practice setting so that their employment options were not limited, and not requiring the supervision to be registered in advance at this time where the Board is delayed in their reviews, or requirements for the positions or direct hours required, so that they could perhaps resume in a supervisory, director, assessor, professor, or part-time position that they may be seeking or may have last been working in.

Thank you for consideration of this comment in your review.  I may be contacted at the email address provided if requested for additional information.