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. We understand that the Department of Social Services is required to change the job titles of “Social Worker” in order to comply with the new law:

§ 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.

In the proposed regulations, “Social Worker” has been changed to “Family Services Specialist” throughout 22VAC40-670. We support this change in job titles. However, we believe an error was made when changing the section on degree requirements. The proposed regulations now read:

"Human services field" means the field of social work family services and related degrees, including counseling, gerontology, guidance and counseling, family and child development, psychology, sociology, or other related degrees determined by the Division of Human Resource Management Resources based on the similarity of the curriculum and course content. It is the applicant's responsibility to provide information with the application if the applicant wishes the course content and curriculum to be so evaluated.

This section now completely eliminates the Social Work degree as an acceptable degree for those in the “Human services field.” We believe this was not the intention of the proposed regulations, as many employees with the Department of Social Services have Social Work degrees. We propose the following change to amend this error:

"Human services field" means the field of social work family services and related degrees, including social work, counseling, gerontology, guidance and counseling, family and child development, psychology, sociology, or other related degrees determined by the Division of Human Resource Management Resources based on the similarity of the curriculum and course content. It is the applicant's responsibility to provide information with the application if the applicant wishes the course content and curriculum to be so evaluated.

We thank you for your consideration of this important matter.