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Virginia Society for Clinical Social Work
10106-C Palace Way
Henrico VA 23238
Public Comments pursuant to Executive Order 14 (2010) in regards to 22VAC40-670
Degree Requirements for Social Work Occupational Group
The Virginia Society for Clinical Social Work (VSCSW) offers public comments concerning 22VAC40-670. The Virginia General Assembly passed § 54.1-3709. Unlawful designation as social worker, that is to become effective on July 1, 2013. The regulations in 22VAC40-670 need to be amended and in some sections terminated in order to be in compliance with § 54.1-3709. The statute concerns the use of the title "Social Worker" so it is specifically and directly applicable to the review of 22VAC40-670 as these are the regulations that address degree requirements for "Social Work Occupational Group" in the Department of Social Services.
The definition of "Social Worker" has existed in the Code of Virginia under § 54.1-3700 for the past 36 years. There is no reason why any agency of the Commonwealth of Virginia should have a policy in their hiring practices that allows for the misrepresentation of an employee's credentials. The title social worker is representing that the holder of that title has met the credentialing required by § 54.1-3709 and DSS regulations must be written to be in compliance with the Code of Virginia. The statute states in part:
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
E. That nothing in this act shall be construed as requiring the Department of Social Services, or any other entity, to hire licensed social workers or social workers with 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. (2011, c. 794.)
The format below describes VSCSW public comments:
Conflict In order to be evaluated for vacancies in the Social Work Occupational Group, applicants shall:
1. Possess a minimum of a baccalaureate degree in the human services field; or
VSCSW Comments § 54.1-3709. Requires persons using the title “Social Worker” to either be licensed under the requirements of Chapter 37 of Title 54.1 of the Code of Virginia, Social Work or use 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.
The VSCSW recommends that 22 VAC40-670 needs to be amended to specify that one of those two conditions must be met to use the title “Social Worker.”
Conflict In order to be evaluated for vacancies in the Social Work Occupational Group, applicants shall:
2. Possess a minimum of a baccalaureate degree in any field accompanied by a minimum of two years appropriate and related experience in a human services related area; or
VSCSW Comments § 54.1-3709 does not permit the use of the title “Social Worker” to be used by persons with baccalaureate degrees in fields other than social work or to be used by persons with related experience in a human services related area. § 54.1-3709 requires persons using the title “Social Worker” to either be licensed under the requirements of Chapter 37 of Title 54.1 of the Code of Virginia, Social Work or use 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.
The VSCSW recommends that 22 VAC40-670 needs to terminate this part of the regulation in order to be in compliance with § 54.1-3709
Conflict:
3. To be considered for promotion, persons currently employed in the Social Work Occupational Group by a local agency prior to September 1, 1990, who do not meet the requirements of subdivision 1 or 2 of this section, shall possess four years of appropriate and related experience in a human services area and must have successfully completed all available competency-based training related to the promotional area.
VSCSW Comments § 54.1-3709 requires persons using the title “Social Worker” to either be licensed under the requirements of Chapter 37 of Title 54.1 of the Code of Virginia, Social Work or use 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.
VSCSW Recommendation:
VSCSW Recommends that persons considered for promotion to a positon with the title “social worker” must meet the requirements of § 54.1-3709 in order to be considered for that position.
Conflict
If an individual does not indicate possession of the requirements in subdivision 1, 2, or 3 of this section on the application, he will not be qualified for the position.
Once the applicant has noted the possession of a baccalaureate degree in the human services field on the application or resume, the evaluation process will continue using knowledge, skill, and ability criteria.
VSCSW Comments § 54.1-3709 does not allow for the possession of a baccalaureate degree in the human services to be considered for the use of the title social worker.
VSCSW Recommendation:
The VSCSW recommends that this section of the regulations be amended to require compliance with § 54.1-3709
Conflict
Individuals employed in the Social Work Occupational Group prior to September 1, 1990, who do not meet the requirements of subdivision 1, 2, or 3 of this section, will be retained in their current occupational title or any lesser occupational title without having to meet the above requirements. This includes the same occupational title in another local agency.
These individuals will be required to meet the requirements of subdivision 1, 2, or 3 of this section for application to any higher occupational title other than their current occupational title
VSCSW Comments: § 54.1-3709 does not allow for application to any higher occupational title that would include the title social worker unless the applicant meets the requirements of the statute.
VSCSW Recommendation:
The VSCSW recommends that this section of the regulations needs to be amended to require compliance with § 54.1-3709
Statutory Authority:
The VSCSW notes that Statutory Authority authorizing the recommended changes in these regulations appears in §§ 63.2-217 and 63.2-219 of the Code of Virginia.
Submitted by: Joseph G. Lynch LCSW Virginia Society for Clinical Social Work 110 Newman Avenue Harrisonburg, Virginia 22801 (540) 434-2800 Extn #13 lynchj@newmanavenue.com
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As a member of the National Association of Social Workers, Virginia Chapter, and the Virginia Society for Clinical Social work, I urge that you support this executive order, so that the title, “social worker,” may be used only by a person with a social work degree.
Please correct this executive order to indicate that only those with a social work degree may use the title of social worker. The order will then be in compliance with 54.1-3709. Social Work training is necessary for persons providing social work services as a protection of the public.
As a charter member of the Virginia Sociary of Clinical Social Work, I request that “persons using the title of “Social Worker” must be either licensed under the requirements of Chapter 37 of Title 54.1…or use clarifying initials that signify re-ceiving a baccalaureate or master’s degree in Social work from an accredited school of social work or program approved by the Council on Social Work Education, or a doctorate in social work. It is extremely important that the title of “Social Worker” clearly exclude any other training, experience, or education in order to pro-tect our profession and title, and that the regulations must be amended to require compliance with 54.1-3709 in all aspects.
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.