As a new MSW student, I am distressed at the proposal to eliminate the 5 year continuing education requirement for supervisors. Absent this requirement, it will be possible that a supervisor could go an entire career – thirty years or more! – without updating their supervisor training. Thirty years ago, I did not yet own my first computer.  Twenty years ago, I did not yet own my first cell phone. Ten years ago, same-sex marriage seemed an impossible dream and the practice of self-filming conflict situations with cell phones was unheard of. Even today, our understanding of trauma and how to create safe space for clients is evolving at lightning speed. These are but just a few examples of changes in our society that have had a profound impact on the way that social work is practiced. I cannot imagine how a supervisor could bring current best practices to his or her supervisees without regular, extensive updates.

When I get my degree in 2021, I want to know that the supervisor I am working toward licensing under is giving me the very best, most current guidance possible – for the simple reason that I want to be able to give the best possible care to the people I serve. If you eliminate this requirement, it will be easy for supervisors to forego continuing education because they are too busy, because they don’t realize things have changed, or because they simply don’t think it is important. Beyond that, it seems likely that some social service agencies will not support or pay for continuing education for their supervisors – even those who want updated training – if they are not required to do so by law.

For the sake of those of us coming into the field of social work now and in the future – as well as all of the people we will serve throughout our careers – please withdraw this proposal.

Thank you for your consideration.

It is my understanding the Virginia Board of Social Work has proposed changes in the regulations which govern the practice and supervision of Social Work licensees in the Commonwealth of Virginia:

1.) Reduce the training hours necessary to be a Social Worker Supervisor from 14 to 12,

2.) Eliminate the need for any follow up training . . . ever.

The Virginia Chapter of the National Association of Social Workers opposed this proposal:

1.) Social Work supervision must be current, reflective of issues developing in the field. It is not a static field.

2.) Quality of Supervision requires routine 'refresher' courses. To eliminate this expectation sets practitioners up for failure and the clients they serve for harm.

Social Workers have struggled to achieve parity with other behavioral health professions. This regulation undermines that effort.

Thank You!

Social work is a unique field in that it is a dynamic one, with its members being lifelong learners committed to staying up to date on the newest research, guidelines, and professional opinions. The field also relies heavily on its qualified supervisors to act as mentors and guides to those entering the profession, ensuring that students not only receive a quality classroom education, but that they engage in their required field practicums and supervised experience with opportunities to be challenged on their ideas and exposed to new situations that they may encounter in their roles as social workers. 

As a recent MSW graduate currently applying for supervision, I place great importance on my supervisor being knowledgeable, experienced, and bringing her own training back to me for meaningful discussion and learning opportunities. The proposed reduction in CEU requirements for supervisors directly violates the NASW Code of Ethics value of competence, which blatantly states that social workers are to "continually strive to increase their professional knowledge and skills and to apply them in practice". Social workers have fought long and hard for recognition and credibility in the behavioral sciences field, and eliminating requirements for supervisors to attend continuing education workshops and training undermines the hard work of our predecessors, especially as it remains a requirement in other behavioral health fields such as nursing and psychology. 

It is my hope that the Virginia Board of Social Work will take the Code of Ethics which we have all agreed to follow in account when discussing this urgent matter. Social workers have an important place in our society, and the profession continues to grow because of our commitment to being well-informed and passionate. 

The proposed regulatory changes to reduce continuing education requirements for supervisors would constitute a "lowering of the bar" for the profession, the care of clients, and the skills of clinicians. Supervisors are responsible for the highest level of clinical training prior to independent practice, and our clinicians deserve competency. To reduce supervisors' CEU hours and then excuse them from further organized learning seems inherently, professionally careless.

The practice of social work is reflective of our changing neighborhoods, cultures, and world, and as such, should accurately reflect those changes. To permit any supervisor to opt out of staying current in the field is putting our clients at risk due to competency issues.

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.

The National Association of Social Workers (NASW) the largest professional association for Social Workers and the Association of Social Work Boards (ASWB) (the association of Social Work Boards in the United States and Canada) developed the Best Practices Standards in Social Work Supervision to support and strengthen supervision for professional social workers. The standards provide a framework that promotes uniformity and serves as a resource for issues related to supervision in the social work supervisory community.
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.

Supervision is an essential and integral part of the training and continuing competencies required for a skillful development of professional social workers. Supervision protects clients, supports practitioners, and ensures that professional standards and quality services are delivered by competent social workers. 

The NASW Code of Ethics and the ASWB Model Social Work Practice Act serve as foundation documents in the development of the supervision standards. These standards support the practice of social workers in various work settings and articulate the importance of a collective professional understanding of supervision within the social work community as well as citing the NASW Code of Ethics as guidelines and standards for practice.
The questionable position that the Virginia Board of Social Work has taken to remove the 5-year requirement for continuing competency/education appears to defy standards of practice and logic. In addition, to lower the requirement from 14 hours to 12 contact hours is arbitrary and capricious at best.

Social Work is recognized among other behavioral health science practitioners with the legal right to practice independently, to bill services performed, to respond in legal situations with “privilege” as afforded to physicians, nurse practitioners and other providers of mental health, psychiatric and behavioral health services. 

As strongly supported and stringently required in professional training for psychiatrists, psychologists, nurses and social workers, best supervision practices and current evidence-based practices are requisite for competence in professional practice. The social work profession prides itself on being the largest behavioral health provider in the world and continuing development and training is of utmost importance for a competent, up-to-date workforce.  

The definition of supervision is to “oversee”, therefore, by eliminating the training requirement every 5 years for a supervisor and lowering the required contact hours from 14 to 12 hours, the Board of Social Work is suggesting that it does not value updated and current evidence-based required training for its “teachers” to bring a new workforce into the Commonwealth with sound practice and ongoing development. These proposed recommendations to change the rules/regulations by eliminating 2 contact hours of the initial training and abolishing the 5-year refresher training for Supervisors creates a risk for the social work profession and the public. 

Many supervisors across the behavioral health space and health arena work diligently to remain informed and current in theoretical, practice and research-based knowledge, however as with all professionals’ others do not. The supervisors who do not seek peer reviews and professional venues for updating professional knowledge and new research based content because of cost, inconvenience, the absence of motivation, or simply, ease in continuing supervision without additional effort, are those that will likely struggle with professional competency and so will their supervisees.  

In fact, when the original education and training requirements of the social work profession were reviewed and developed in 2006 by the Board of Social Work they recognized the direct correlation between a supervisors’ practice knowledge and ethical and disciplinary cases with supervisees.  

It should be duly noted that supervisees who had supervisors with limited training on ethics, evidence-based practices and other practice related standards contributed to in an increase of disciplinary cases brought forth by the consumer.  

The Board during this time, had the wisdom and foresight to take a visionary position in instituting a requirement for all social work supervisors approved to supervise practitioners seeking licensure in Virginia. At that time, the Board sought to ensure and sustain the growing recognition and respect of the social work profession with its specific service arenas commensurate with other health and behavioral health professions. In its infinite wisdom, the Board realized that competent education and training and competent, enriched supervisory practices would ensure this outcome. This outcome would also be in the best interest of the consumer, as a result of a more educated and informed supervisor. 

Social workers provide much needed services to an array of clients in practice settings, including but not limited to aging, healthcare, behavioral health, school social work, and many more. And, with multi-level licensing recently signed into Law in Virginia, the profession is poised to grow thus increasing the workforce and access to behavioral health services.  

Without strict training requirements, the workforce will increase, but with professionals who have a lower standard of competency, potentially resulting in harm to the clients served. It is imperative that the workforce providing behavioral health and case management services, be competent with continuing development in offering the citizens of the Commonwealth’s well qualified, professional workforce, whose main goal is to protect the public from harm. In order to help accomplish this goal, it is vital that our Regulators understand that continuing competency is one of many professional requirements, particularly when teaching new practitioners.  

After reviewing the ASWB data regarding Supervision Requirements for Social Workers, it is noted that Virginia is one of only a couple of states that has such a low initial hourly training requirement for supervisors. In fact, most states require at least 15 hours of initial training and some like Texas require a 40-hour course be taken to be board approved. Many states require the licensee who has the supervisor designation to get 3 CEU’s every license renewal period. This helps to ensure that the workforce is always up to date with best practices. Approximately 70% of states do require 3 or more hours of Continuing Education per license renewal period.   

Lowering these requirements will not ensure the 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.   

There are many vehicles to obtaining Supervision training in the Commonwealth that meet the requirement for supervision. A diverse array of organizations offers supervision training with enough diversity in its content to meet the core foundational elements while not being redundant. These organizations include but are not limited to professional associations, for profit and nonprofit businesses.  

The National Association of Social Workers, Virginia Chapter is hopeful that the Virginia Board of Social Work will reverse the decision to promulgate regulations and not change the standard for Supervisors in Social Work. 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,

National Association of Social Workers, Virginia Chapter

I am a Commonwealth of Virginia Licensed Clinical Social Worker and I am currently eligible to provide clinical supervision in VA. I  am writing in opposition to the proposed reduction in ongoing continuing education requirements for supervisors.  Social work is a constantly changing field, and the thought of supervisors being able to go virtually an entire career without having to engage in continuing education related to supervision and still be providing supervision is mind blowing to me.  It is not in line with the values of other mental health professions and could have serious consequences on the quality of supervision that is received, thereby reducing the overall clinical skill level of newly licensed clinicians. Social workers have worked long and hard to be recognized as the highly qualified mental health professionals that they are. A reduction in the overall training required to be a supervisor as well as the reduction in required ongoing continuing education requirements would have a negative impact on these efforts.

I am opposed to the Board’s proposal to weaken the training requirements for Social Work Supervisors as put forth in the action: “Reduction of CE requirement for supervisors,” and urge that it be withdrawn. I feel strongly that reducing the required hours, eliminating the 5 year timeframe for training prior to initial registration, and eliminating the 5 year continuing education requirement for Social Work Supervisors would undermine the quality of supervision for countless new practitioners.  This would be a detriment to a supervisee’s education and practice, and would put the people they serve at risk. As professionals we are continually expanding our knowledge base and working with a more diverse and complex population.  The proposed changes to the Supervisor training requirements will undermine the profession in Virginia, and would be a disservice to supervisees and their clients.

Donilee Alexander-Goldsmith, MSW, LCSW

Greetings,

I am deeply concerned about the Board’s proposal to weaken the training requirements for Social Work Supervisors as outlined in “Reduction of CE requirement for supervisors.” I implore you to reconsider this action. Reducing the required hours, eliminating the five-year timeframe for training prior to initial registration, and eliminating the five year continuing education requirement for Social Work Supervisors would undermine the quality of supervision for countless new practitioners, not only harming their professional education and robbing them of needed capability, but putting the people they serve at risk.

Social Work is a highly dynamic field; the knowledge base of the profession is continually expanding, and the population it serves becoming more complex. Some examples of changes in the last five years alone include:

· Greater awareness and understanding of the breadth and prominence of issues facing the LBGTQ+ community;

· New best practices with regard to sensitivities and trauma around issues of race, gender, and sexuality, as well as the ubiquity of sexual harassment and assault;

· Better understanding of the myriad and often hidden ways that white supremacy and white privilege impact minority populations;

· A rise in gun ownership and gun violence, posing increased physical risk to clients (through both violence and suicide) and social workers, as well as causing increased anxiety and trauma in communities overall.

It is imperative that novice social workers have the skills, abilities to bring evidence based practices and insights to the challenging, and dynamic issues they encounter on a daily basis. Their ability to navigate complex issues and mitigate harm in the midst of real-life situations depends largely on the knowledge and understanding of their supervisor and the quality of guidance they receive. Without a current continuing education requirement, a significant portion of supervisors will fall behind in the field and their supervisees will carry their outdated understandings forward.

The Social Work profession has tirelessly advocated for its rightful and now recognized position among other behavioral health science professions. As is stringently required in professional training for psychiatrists, psychologists, nurses and social workers in jurisdictions across the country, best supervision practices and current evidence-based knowledge are requisite for competence in professional practice. There is ample, high quality and advanced supervisor training available (with new training developed as need the need arise) to ensure that no supervisor will need retake coursework merely to meet the requirement.

The proposed changes to the Supervisor training requirements will undermine the profession in Virginia, hurting supervisees and their clients. I ask that you please support the social work profession in our state by withdrawing this proposal.

Warm regards,

Debbie L. Cadet, PhD, MSW

I am writing to express my concerns about the Board’s proposal to weaken the training requirements for Social Work Supervisors as outlined in “Reduction of CE requirement for supervisors”.   Reducing the required hours, eliminating the five-year time-frame for training prior to initial registration, along with eliminating the five-year continuing education requirement for Social Work Supervisors would undermine the quality that systems are moving to across the healthcare profession.  The health-care model is heavily focused on patient centered care and Quality Initiatives; however, this proposal reinforces the number of new practitioners only harming the individual’s professional education, but most of all it is putting the population they serve at risk.  

Social Work is a highly dynamic field; the knowledge base of the profession is continually expanding, and the population it serves becoming more complex. Some examples of changes in the last five years alone include:

• Greater awareness and understanding of the breadth and prominence of issues facing the LBGTQ+ community;
• New best practices with regard to sensitivities and trauma around issues of race, gender, and sexuality, as well as the ubiquity of sexual harassment and assault;
• Better understanding of the myriad and often hidden ways that white supremacy and white privilege impact minority populations;
• A rise in gun ownership and gun violence, posing increased physical risk to clients (through both violence and suicide) and social workers, as well as causing increased anxiety and trauma in communities overall.

It is essential that new social workers bring the most current practices and insights to the challenging dynamics they face daily. Their ability to navigate complex issues and mitigate harm in the midst of real-life situations depends to a large extent on the knowledge and understanding of their supervisor and the quality of guidance they receive. Without a continuing education requirement that is current, a significant subset of supervisors will fall behind the field and their outdated understandings will be carried forward by their supervisees, as well as future social workers.  Raising the requirement for ethics training will not be sufficient, as the changing social work landscape extends far beyond questions of ethics.  

Social Work has fought long and hard to be respected and recognized among other behavioral health science professions.  As is stringently required in professional training for psychiatrists, psychologists, nurses and social workers in jurisdictions across the country, best supervision practices and current evidence-based knowledge are requisite for competence in professional practice.   The proposed changes to the Supervisor training requirements will undermine the profession in Virginia, hurting supervisees and their clients; which puts more liability on the supervisor.  Please support social work in our state by withdrawing this proposal.

Rahikya Wilson, MSW, LCSW, LICSW

I would like to express my concerns against the proposed change to the current educational requirements for clinical supervision.   Quite frankly, reducing the required hours, eliminating the initial 5-year professional experience, and removing the 5-year continuing education requirement for Social Work Supervisors would undermine the quality of supervision and potentially harm the people that we serve.

According to Tebes, et al., (2010), “training in supervisory competencies is essential to effective clinical practices and helps address the current national crisis in the behavioral health workforce”.  In an ever-changing landscape, it is imperative that social work supervisors have the ongoing education and skills to train the next generation of social workers to address the multi-faceted and complex issues in the communities that they serve.

According to the current regulations,

          "Supervision" means a professional relationship between a supervisor and supervisee             in which the supervisor directs, monitors and evaluates the supervisee's social work               practice while promoting development of the supervisee's knowledge, skills and                   abilities to provide social work services in an ethical and competent manner. 

How can professionalism, ethics and competence be demonstrated without adequate ongoing training?  By regulation, social workers are required to receive continuing education in order to maintain their license which means that they have met the “minimum standard of care”.  Continuing education for supervisors not only demonstrates a minimum standard but ensures supervisors receive ongoing education in supervision guidelines, techniques, and ethics.  Clinical supervision is the capstone activity that connects theory to practice and is viewed as the signature pedagogy of mental health professionals (Dollarhide & Granello, 2016; Barnett et al., 2007).

The proposed changes to the supervisor education requirements will undermine the profession, hinder supervisees and negatively impact the clients that we service.  Therefore, I urge you to withdraw this proposal, and instead offer continued support of the professionals that provide an invaluable service in our profession.

Respectfully,

I am alarmed at the Board’s proposal to weaken the training requirements for Social Work Supervisors as put forth in the action: “Reduction of CE requirement for supervisors,” and urge that it be withdrawn. Reducing the required hours, eliminating the 5 year timeframe for training prior to initial registration, and eliminating the 5 year continuing education requirement for Social Work Supervisors would undermine the quality of supervision for countless new practitioners, not only harming their professional education and robbing them of needed capability, but putting the people they serve at risk. 

Social Work is a highly dynamic field; the knowledge base of the profession is continually expanding, and the population it serves becoming more complex. Some examples of changes in the last five years alone include:

• Greater awareness and understanding of the breadth and prominence of issues facing the LBGTQ+ community;

• New best practices with regard to sensitivities and trauma around issues of race, gender, and sexuality, as well as the ubiquity of sexual harassment and assault;

• Better understanding of the myriad and often hidden ways that white supremacy and white privilege impact minority populations;

• A rise in gun ownership and gun violence, posing increased physical risk to clients (through both violence and suicide) and social workers, as well as causing increased anxiety and trauma in communities overall.

It is essential that new social workers be able bring the most current practices and insights to the challenging dynamics they face today. Their ability to navigate complex issues and mitigate harm in the midst of real-life situations depends to a large extent on the knowledge and understanding of their supervisor and the quality of guidance they receive. Without a continuing education requirement that is current, a significant subset of supervisors will fall behind the field and their outdated understandings will be carried forward by their supervisees. A likely outcome is a rise in troubled supervisor-supervisee relationships, greater incidence of poorly performing social workers, and an increase in disciplinary actions. Raising the requirement for ethics training will not be sufficient, as the changing social work landscape extends far beyond questions of ethics.

Social Work has fought long and hard for its rightful and now recognized position among other behavioral health science professions. As is stringently required in professional training for psychiatrists, psychologists, nurses and social workers in jurisdictions across the country, best supervision practices and current evidence-based knowledge are requisite for competence in professional practice. There is ample, high quality and advanced supervisor training available (with new training developed as needs arise) to ensure that no supervisor need “repeat” coursework merely to meet the requirement. 

The proposed changes to the Supervisor training requirements will undermine the profession in Virginia, hurting supervisees and their clients. Please support social work in our state by withdrawing this proposal.

I would like to supplement my earlier comments to explicitly object to using the Fast Track process for this measure. As evidenced by the number of people opposing the proposal (including and especially NASWVA), there is significant concern about potential negative impact to the profession and the thousands of people who rely on social work services. It is deserving of the full and careful consideration of the regular regulatory action process.

Thank you so much for your consideration.

The National assocition of Social Workers in opposed to fast tracking these regulatory considerations for changes and strongly supports moving through the regulatory process that offers more time to consider such a change in regulations under the board of Social Work.  With opposing comments regarding the regulations under this section, the assocition believes it is necessary to stop the fast tracking process at this time for more review and a longer comment period.

I oppose the Board’s proposal to weaken the training requirements for Social Work Supervisors as put forth in the action: “Reduction of CE requirement for supervisors,” and urge that it be withdrawn. Reducing the required hours, eliminating the 5 year timeframe for training prior to initial registration, and eliminating the 5 year continuing education requirement for Social Work Supervisors would undermine the quality of supervision for countless new practitioners, not only harming their professional education and robbing them of needed capability, but putting the people they serve at risk. Social Work is a highly dynamic field; the knowledge base of the profession is continually expanding, and the population it serves is becoming more complex.

It is essential that new social workers be able bring the most current practices and insights to the challenging dynamics they face today. Without a continuing education requirement that is current, a significant subset of supervisors will fall behind the field and their outdated understandings will be carried forward by their supervisees. As is stringently required in professional training for psychiatrists, psychologists, nurses and social workers in jurisdictions across the country, best supervision practices and current evidence-based knowledge are requisite for competence in professional practice.

The proposed changes to the Supervisor training requirements will undermine the profession in Virginia, hurting supervisees and their clients. Please support social work in our state by withdrawing this proposal.

Finally, I oppose the fast tracking process. This proposed regulatory change and initiative is a controversial proposal with the potential for some very real negative impact. Thus it should be subject to a full and thorough review process.

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 am currently under clinical supervision and I find it valuable that the person that I am receiving training from is invested in the continuing education requirements set forth by the board. Knowing that she is invested in the changes and advancements of the profession help to make the experience valuable. Social work is an everchanging practice and the CEU’S help in keeping practitioners up to date.  as practice evolves it is important to hold fast to the foundation  of  practice and to assist in solidity of our profession . reducing the

Without strict training requirements, the workforce will increase, but with professionals who have a lower standard of competency, potentially resulting in harm to the clients served. It is imperative that the workforce providing behavioral health and case management services, be competent with continuing development in offering the citizens of the Commonwealth’s well qualified, professional workforce, whose main goal is to protect the public from harm. In order to help accomplish this goal, it is vital that our Regulators understand that continuing competency is one of many professional requirements, particularly when teaching new practitioners

Lowering these requirements will not ensure the 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.

This proposed regulatory change is controversial and has significant potential for negative impact. It should be subject to a full and thorough review process.

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

It has recently come to my attention that there is a proposed Fast Track legislation (18VAC140-20-Less Restrictive Rule on Supervision) that would decease the number of hours of training required for a Social Work Supervisor to offer supervision to another social worker. 

I can't imagine why decreasing the amount of training would even be considered.  In this fast changing world, I want my physicians and mental health providers to have as much training as possible to keep up with current practice issues.  With all the mental health problems in Virginia, and around the world, social workers need to be kept as up-to-date through training as possible. 

Therefore, I am opposing the fast tracking process and it should be returned to the Board of Social Work for more consideration and time under the normal regulatory process.  This regulatory change is a controversial proposal with the potential for negative impact, so it should be subject to a full and thorough review process. 

Respectfully submitted, 

Ellen Fink-Samnick MSW, ACSW, LCSW, CCM, CRP

Principal, EFS Supervision Strategies, LLC

For addition to my previous comment

Any changes to the foundational and legal underpinning of the clinical social work supervision approach in the Commonwealth should receive a thorough evaluation of the impact on all stakeholders; clinical social work supervisors, supervisees in social work, employing organizations, and consumers of social work services. A regulatory change of this magnitude is not without consequences to all of these entities. For this reason alone, the regulations should be appropriately vetted by the industry, and not be fast-tracked.

I am writing in opposition to the proposed change that would reduce the training requirements, and eliminate ongoing continuing education requirements, for social work supervisors. This proposal lowers a threshold for qualification that is already less than that of clinical social work supervisors in other states, as well as other mental health practitioners in Virginia. For instance, some states (like Minnesota, where I used to practice) require that clinical supervisors have 30 hours of formal supervision training before they begin supervising aspiring clinical social workers. Additionally, a more stringent training requirement is currently in place for Virginia's Marriage and Family Therapists and Licensed Professional Counselors, whose supervisors are required to have 20 hours in supervision-related continuing education before accepting supervisees.

Second, the proposal to eliminate the ongoing continuing education requirement for clinical social work supervisors in incongruent with best practices in social work supervision, as set forth by the National Association of Social Workers and the Association of Social Work Boards in 2013. These best practices include recommendations that social work supervisors not only complete a minimum number of hours in supervision-related coursework or continuing education, but that they regularly complete a minimum number of hours in continuing education to maintain their supervision credentials.

I do not support any regulatory change that weakens, instead of strengthens, the standards by which clinical social work supervisors are deemed qualified. Furthermore, I am troubled that these changes have not been subjected to a full and thorough review. Any change that has the potential to increase risk to social work practitioners (in this case, supervisees) as well as clients should not be fast-tracked for approval, but instead be evaluated via a full regulatory process.

Thank you for your time and consideration.

In addition to my previous comment about my opposition to the proposed changes as a whole, I would like to add that I am particularly opposed to the "Fast Tracking" of this proposal.  The regulatory change and initiative has the potential for negative impact on our profession and the people we serve, and as such should be subject to a full and thorough review process.

thank you

I am writing to respectfully but strongly express my opposition to fast-tracking the proposed regulatory change that would abolish the current requirement for clinical supervisors to take a five-year refresher training course as is included in the current policy for clinical supervisors supervising MSW graduates for the LCSW credential.

Because I have been in academic systems for most of my career and have provided training, supervision, clinical practice and consultation for most of my career as a licensed clinical social worker and professor, I believe that I am in a position to identify and attest to the extreme risk that reducing requirements for ongoing professional competency standards for supervisors poses for the training of our future licensed professionals and, thus, for the overall risk to the profession itself.

A proposed regulatory change initiative of the magnitude of abolishing required ongoing supervision training and reducing initial training hours will clearly be controversial in many ways and have a huge potential for negative impact for licensed professionals and for the social work profession itself.  Fast-tracking seems to be a process that bypasses the opportunity and rights for the majority of licensees to have ample time to consider the full impact of this proposed change and to provide substantive comment as is the opportunity that occurs in the usual review process. 

Because of the negative impact that perceptions of reduced consideration or the seeming absence of consideration by the Board for the participation of the many social work supervisors who strongly support the opportunity for Board support of continued training and competence, fast-tracking of the proposed change without appropriate opportunity for a full and thorough review process is likely to be quite controversial and, importantly, bring about issues of trust with the Board itself. Such an uncomfortable conversation seems to be occurring among the supervisors who have currently connected with me about the proposed fast-track action. Communicated perspectives have suggested that the Board or certain members may have an ulterior motive and that this fast" action, which is so important to the consideration of the well-being of the many licensees who look to the Board with respect and trust, is a violation of trust.

A significant proposed regulatory change should be subject to a full and thorough review process by those who wish to comment and not one that is quickly moved through a rapid process that will likely hinder equal access for review by the majority of licensees!

It is for these reasons that I am respectfully urging the Board to please, seriously consider this request to remove this proposal from the fast-tracking process for the many licensees who truly respect the Board and a Board supported pathway to continued training and competence.

Sincerely,

E. Delores Dungee-Anderson

E. Delores Dungee-Anderson, Ph.D., LCSW, BCD, CTST

     Elizabeth Dungee-Anderson, PhD, LCSW, BCD, CTST

                                                                JKT Associates, LLC

                                                           1901 Huguenot Rd, Ste 303

                                                   North Chesterfield, VA 23235-4311

To: VIRGINIA Board of Social Work

ATTENTION:

Elaine Yeatts, Senior Policy Analyst

Jaime Hoyle, Executive Director, Virginia Board of Social Work

I am writing in opposition to three positions that the Board has currently identified for which it proposes legislative changes. The first of the three proposals is to abolish the legislated LCSW Supervisor 5-year training updates; the second is to reduce the hours for the initial LCSW Supervisor training requirement, and the third is to fast-track this proposed legislation as opposed to subjecting it to the full regulatory review process.

As is posted on the Virginia Department of Health Professions public website, the mission of all of the Professional Regulatory Boards which includes the Board of Social Work provides the following statement:

“The mission of the Department of Health Professions is to ensure safe and competent patient care by licensing health professionals, enforcing standards of practice, and providing information to health care practitioners and the public”.

 My opposition to the proposals is two-fold. First, it seems that the Board is taking a very questionable and risky stance in proposing to remove the current 5-year requirement for approved social work supervisors to renew/update their supervision training and, also proposing to shorten the original number of supervision training hours required for eligibility for approval as a supervisor for LCSW eligibility. Respectfully, these proposals appear to defy any possible logic if you, our SW Board, are “governing” us and you are truly supporting the mission of the Board to promulgate legislation that actually supports safe and competent care for consumers of our services!  Social Work has fought long and very hard for its rightful and now recognized position among other behavioral health science professions. Over the years, the slow recognition of our rights as a profession has included all of the following: Licensure as clinical social work practitioners with the legal right to practice independently, to bill for services performed, to respond in legal situations with “privilege” as afforded to physicians, attorneys and other providers of mental health, psychiatric and behavioral health services, and most importantly, title protection.

As the Board is clearly aware, it is now unlawful in Virginia for persons not formally trained/educated with a social work degree to identify as a social worker and for organizations at all levels to hire a non-social worker for a position advertised as a social work position. As is strongly supported and stringently required in professional training for psychiatrists, psychologists, nurses and, currently, social workers, best supervision practices and current evidence-based knowledge are requisite tools for competence in professional practice.  Is there any profession that does not require updated knowledge and training for its “teachers” in the professions who educate, supervise and “train” the newly emerging professionals?  If the definition of supervision means “to oversee”, would the social work profession, having experienced a strenuous journey to become a legislatively recognized and valued profession, now elect to take a stance which suggests that it does not value updated and current evidence-based required training/education for its supervisor “teachers on an “every five years” basis?

The recommendation of the current Virginia Social work Board to abolish the 5-year updating of the supervision requirement for clinical social work supervisors creates a great risk for the social work profession. Many supervisors across all professions work diligently to remain informed and current in theoretical, practice and research-based knowledge, however, as with all professions, others do not. The supervisors who do not seek peer-reviewed and professional venues for updating of professional knowledge and new research-based content because of cost, inconvenience, or the absence of motivation, or simply, ease in continuing supervision without additional effort,  are those that will likely struggle with professional currency and yet continue to supervise.  And, understandably, their supervisees also may struggle with professional competency.

As the Board is also aware, the education and training requirements of the social work profession were reviewed by an earlier Board of Social Work that had the wisdom and foresight to take a visionary stance in instituting a requirement for all clinical social work supervisors to be approved to supervise practitioners seeking eligibility for clinical licensure. That Board sought to ensure and sustain the growing recognition and respect of the social work profession with its specific service arenas commensurate with other recognized health and behavioral health professions. In its infinite wisdom, the earlier Board realized that competent education and training and competent enlightened and enriched supervisory practices would help to ensure this outcome and support competent supervision - but more importantly, the Board obviously recognized that by regulating those that “oversee” professional licensure training and competency, it was also very strongly attending to its fiduciary responsibility and mission, e.g., “to ensure safe and competent patient care by licensing health professionals, enforcing standards of practice, and providing information to health care practitioners and the public”

Consequently, it cannot become the heritage of social work supervision that the current Board of Social Work does not require updated supervision and has also downgraded the hours required based on inconvenience to practitioners – and that it “fast-tracks” such a proposal to seemingly try to rush it through! What profession works hard to make competent training and practice “easier” if it also wants to remain respected and commensurate in its areas of practice with its peer professions and if it takes seriously its mission, which again is “to ensure safe and competent patient care by licensing health professionals, enforcing standards of practice, and providing information to health care practitioners and the public”?

These are troubling issues that appear to go against professional and public trust in our professional regulatory agency. Respectfully, and as an LCSW practitioner, trainer and supervisor, for many years, please reconsider your proposals for the support of the practitioners who currently have faith in your regulatory oversight and faith in you as Board members who volunteer your time and energy for the cause of our professional standards.

Sincerely,

Elizabeth Dungee-Anderson

 Elizabeth Dungee-Anderson, PhD, LCSW, BCD, CTST

I strongly oppose the Fast Tracking process for the Reduction of Supervision CEU.  Reducing the required hours, eliminating the five-year time frame for training prior to initial registration along with eliminating the five-year CEU requirements for Social Work Supervisors would undermine the credibility of the social work profession.  Supervision is the most significant gatekeeping mechanism in place that ensures that professional standards and quality of services are delivered by competent social workers.  Therefore, supervision provided by trained and competent supervisors who stay abreast of the vastly changing dynamics in today's society, especially the healthcare system is an essential and integral  part of the training and requirement for the development of  skillful professional social workers.

The proposed regulatory change and initiative is a controversial proposal with the potential for some very deleterious repercussions. I highly recommend that this Fast Tracking Process for the Reduction of Supervision CEU be revisited for broader feedback from those whom this change would impact immensely.  

I am strongly opposed to any reduction in the current continuing education requirements for supervision in Virginia. The process of supervision and continuing professional education are both critical for high quality clinical social work practice. If either of these elements are weakened it could cause harm to the public as well as the social work profession which heavily relies on training and supervision to uphold ethical principals.

Making the decision to become a clinical supervisor is a tremendous responsibility and reducing the training requirements may encourage practitioners to enter a supervisory role underprepared for the challenges that can arise. Based on my experiences in supervision training, the continuing education courses have not been redundant and have provided dyadic feedback between participants. These trainings have provided information about emerging risks, lessons learned, and best practices in supervision.

Clinical supervision is more than an administrative task and should be held to high standards. Supervision is not only used for new practitioners but also experienced professionals that need to be able to trust the judgement of their supervisor. 14 hours of supervision training every five years seems to be a reasonable request for such an important role.