Public Comments regarding 22VAC40-670; Degree Requirements for Social Work/Social Work Supervision Classification Series

NASW-VA is pleased to have the opportunity to provide our comments on the review of 22VAC40-670 Degree Requirements for Social Work/Social Work Supervision Classification Series under Executive Order 14 (2010) and §§ 2.2-4007.1 and 2.2-4017 of the Code of Virginia.

This periodic review of the regulations is a clear opportunity to amend 22VAC40-670 to comply with the new law regarding the job title of Social Worker. The Virginia General Assembly passed HB 2037 (Peace) in 2011 and it is set to become law July 1, 2013. The Code of Virginia now reads:

§ 54.1-3709

A. It shall be unlawful for any person not licensed under this chapter to use the title "Social Worker" in writing or in advertising in connection with his practice unless he simultaneously uses clarifying initials that signify receiving a baccalaureate or master's degree in social work from an accredited social work school or program approved by the Council on Social Work Education or a doctorate in social work.

As of July 1, 2013, the regulations in their current form will violate § 54.1-3709. The NASW-VA recommends that this section be amended to comply will the law by removing the previously used terms “Social Work” or “Social Worker” to describe general job categories or job titles. These titles should now only be used in conjunction with an employee who has the appropriate social work eduction as designated in § 54.1-3709.

The terms that need to be changed in 22VAC40-670-10 and 22VAC40-670-20 are:

~“Social Work Occupational Group”

~The following occupational titles: "Social Work Supervisor; Social Worker IV; Social Worker III; Social Worker II; Social Worker I; Social Work Manager."

Thank you for your attention to this important matter.