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