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