Thank you for the opportunity to express comments regarding the Fast-Tracked Regulation to promulgate regulations on the Supervision of a Social Worker, and the requirements for continuing education for Supervisors as recommended by the Virginia Board of Social Work, under the Department of Health Professions.  I am writing to express my deep concern for the consideration of 18-VAC140-20, recommending less restrictive rules and regulations as related to Supervision of those pursuing professional licensure in the field of Social Work.

The knowledge base of the social work profession has expanded, and the population it serves has become much more complex. Therefore, it is important to the professional and the clients served to have assurance that all social workers are equipped with the necessary skills to deliver competent and ethical social work services. It is equally important that all social workers are responsible and accountable to the clients they serve to protect them from harm.

I have been in the position of Clinical Supervisor for the past five years in addition to my daily practice in the field and role as an adjunct professor through the Master of Social Work Program through Virginia Commonwealth University.  Through my various roles, I have seen first hand the increased complexities in the field and firmly believe that the requirement for ongoing and renewed training for supervisors is an absolute necessity.  Social Workers are increasingly being required to take on more intricate roles within the agencies, schools, hospitals and community service settings in which they serve.  Additionally, more and more employers are requiring a clinical license to be considered for positions.  Without proper and ongoing supervision, potential candidates and those pursuing licensure will be less likely to meet the requirements as stated by the Board of Social Work Examiners.  Furthermore, if supervisors are not required to continue to meet the level of continued education that they have been (renewing educational requirements for supervision every 5 years), we will not only have a significant decrease in potential social workers entering the field, but also risk gross neglect with regard to client outcomes and integrity of the professional as a whole.  

Additionally, lowering the requirements for supervisors will not inevitably lower the level of competency of the practitioner. The proposed change of 12 hours for initial supervision training does not ensure that the future supervisor has the necessary skills to oversee those applying for a higher level of licensure. In addition, the elimination of the requirement for additional training every 5 years will result in an inadequate level of training in best practices. Although ongoing professional development can never ensure competency, lowering an educational requirement can result in inadequate supervision methods for supervisees. Supervisors with outdated training will pass this information to their supervisees, which will likely lead to an increase in the number of complaints to the Board. When supervisors are current with state-of-the-art best practices that are gained via ongoing training, they can transmit this knowledge to their supervisees. Lowered requirements can create claims by the public that the Board is not providing appropriate or adequate oversight of this supervisor function. The public will not be protected, and this violates the prime purpose of a licensing board.

As a practitioner and member of The National Association of Social Workers, Virginia Chapter Board, it is my hope and urgent request that the Virginia Board of Social Work will  reverse the decision to promulgate regulations and not change the standard for Supervisors in Social Work.   This regulatory change and initiative is a controversial proposal with the potential for negative impact, so it should be subject to a full and thorough review process.  I urge the Virgnia Board of Social Work to halt the fast tracking process of this proposal so that due diligence can be satisfied.  Indeed, if anything, the Association recommends increasing the continuing competency for supervisors, which will have a positive impact for future clients and the public.

Respectfully Submitted,

Rebekah J. Lowenstein, MSW, LCSW-C, LCSW