11 comments
I am an L.C.S.W. My son is an LPC. I have watched and mentored him through his graduate program, supervision, and studying for the LPC exam. I am intimately familiar with what is required to become eligible to take the LPC exam. I have hosted grad students in various programs working towards earning a degree that would enable them to pursue the LPC credential. There are at least 3 grad degrees that can lead to the LPC as opposed to one MSW degree for the LCSW. At one time I could provide at least a year of supervision for those seeking the LPC. I am opposed to the petition unless the Board of Counseling approves LCSWs to provide supervision to those seeking the LPC credential. I take offense to the Board of Counseling excluding LCSWs from providing supervision to those seeking the LPC credential as I take offense to the petition that seeks to allow LPCs to provide supervision to those with an MSW. I intend to submit my own petition asking that LCSWs be allowed to provide supervision towards those seeking the LPC credential.
I want to voice opposition to the Petition for Rulemaking #402 that request an “ Amendment to requirements for supervisors to include licensed professional counselors” The Board of Social Work has made progress over the last 30 years to move toward the goal of LCSW’s who are Board Approved Supervisors being the sole providers of supervision for those seeking the LCSW license. There are over 800 Board Approved Supervisors and a supervisee in social work may arrange for virtual supervision from any of those 800+ supervisors. There no longer exist a claim of a lack of available supervisors based on geography. Any supervisee can now find a LCSW Board Approved Supervisor so I am opposed to this petition.
Thank you for the opportunity to comment on the Petition for Rule Making and proposal to allow licensed professional counselors to supervise social workers under the jurisdiction of the Virginia Board of Social Work. This rule is ill-advised and potentially detrimental to the integrity and efficacy of social work practice. There are several compelling reasons why this rule should be vehemently opposed:
Divergent Educational Backgrounds: Licensed counselors and social workers undergo vastly different educational trajectories. While social work education emphasizes a comprehensive understanding of social justice, human rights, and systemic oppression, counseling programs typically focus on individual mental health and therapeutic interventions. These distinct educational backgrounds do not adequately prepare counselors to supervise social workers, as they lack the necessary knowledge and skills related to macro-level social work practice and clinical practice.
Incompatibility of Ethical Codes: Social workers adhere to a distinct Code of Ethics established by the National Association of Social Workers (NASW), which emphasizes principles such as social justice, cultural competence, and advocacy. Conversely, licensed counselors adhere to ethical guidelines set forth by organizations like the American Counseling Association (ACA) or the American Psychological Association (APA), which may prioritize different values and priorities. Allowing counselors to supervise social workers may create ethical conflicts and undermine the integrity of social work practice.
Differences in Scope of Practice: Social workers and counselors serve distinct roles within the mental health and human services field. Social workers are trained to address a broad range of social issues, including poverty, homelessness, and systemic injustices, while counselors primarily focus on providing therapy and mental health interventions to individuals, couples, or families. The supervision provided by counselors may not adequately address the multifaceted needs of social work clients or prepare social workers to address systemic barriers to well-being.
Risk to Client Welfare: Social work supervision plays a critical role in ensuring the safety and well-being of clients served by social workers. Supervisors are responsible for guiding practitioners in ethical decision-making, professional development, and the application of evidence-based interventions. Allowing counselors to supervise social workers may compromise the quality of supervision and place clients at risk of receiving inadequate or inappropriate services.
Educational Curriculum Disparities: The educational curriculum for social work and counseling programs differs significantly in terms of content, focus, and skill development. Social work education emphasizes a holistic understanding of human behavior within the context of social systems, while counseling programs prioritize clinical assessment, diagnosis, and therapeutic interventions. These differences in educational curriculum may result in gaps in knowledge and skill development that hinder counselors' ability to effectively supervise social workers.
In conclusion, the proposal to allow licensed counselors to supervise social workers is misguided and poses significant risks to the integrity and effectiveness of social work practice. Rather than blurring the lines between distinct professions, efforts should be focused on enhancing collaboration and communication between social workers and counselors while upholding the unique roles and contributions of each profession.
I oppose this ruling and #402. Thank you for giving us our freedom to voice our opinion.
LPCs should not be able to supervise for LCSWs as they have different guiding principals, different course work and different scope of practice. One cannot adquately supervise/train the other.
I want to voice opposition to the Petition for Rulemaking #402 that request an “ Amendment to requirements for supervisors to include licensed professional counselors” The Board of Social Work has made progress over the last 30 years to move toward the goal of LCSW’s who are Board Approved Supervisors being the sole providers of supervision for those seeking the LCSW license. There are over 800 Board Approved Supervisors and a supervisee in social work may arrange for virtual supervision from any of those 800+ supervisors. There no longer exist a claim of a lack of available supervisors based on geography. Any supervisee can now find a LCSW Board Approved Supervisor so I am opposed to this petition.
Divergent Educational Backgrounds: Licensed counselors and social workers undergo vastly different educational trajectories. While social work education emphasizes a comprehensive understanding of social justice, human rights, and systemic oppression, counseling programs typically focus on individual mental health and therapeutic interventions. These distinct educational backgrounds do not adequately prepare counselors to supervise social workers, as they lack the necessary knowledge and skills related to macro-level social work practice and clinical practice.
Incompatibility of Ethical Codes: Social workers adhere to a distinct Code of Ethics established by the National Association of Social Workers (NASW), which emphasizes principles such as social justice, cultural competence, and advocacy. Conversely, licensed counselors adhere to ethical guidelines set forth by organizations like the American Counseling Association (ACA) or the American Psychological Association (APA), which may prioritize different values and priorities. Allowing counselors to supervise social workers may create ethical conflicts and undermine the integrity of social work practice.
Differences in Scope of Practice: Social workers and counselors serve distinct roles within the mental health and human services field. Social workers are trained to address a broad range of social issues, including poverty, homelessness, and systemic injustices, while counselors primarily focus on providing therapy and mental health interventions to individuals, couples, or families. The supervision provided by counselors may not adequately address the multifaceted needs of social work clients or prepare social workers to address systemic barriers to well-being.
Risk to Client Welfare: Social work supervision plays a critical role in ensuring the safety and well-being of clients served by social workers. Supervisors are responsible for guiding practitioners in ethical decision-making, professional development, and the application of evidence-based interventions. Allowing counselors to supervise social workers may compromise the quality of supervision and place clients at risk of receiving inadequate or inappropriate services.
Educational Curriculum Disparities: The educational curriculum for social work and counseling programs differs significantly in terms of content, focus, and skill development. Social work education emphasizes a holistic understanding of human behavior within the context of social systems, while counseling programs prioritize clinical assessment, diagnosis, and therapeutic interventions. These differences in educational curriculum may result in gaps in knowledge and skill development that hinder counselors' ability to effectively supervise social workers.
In conclusion, the proposal to allow licensed counselors to supervise social workers is misguided and poses significant risks to the integrity and effectiveness of social work practice. Rather than blurring the lines between distinct professions, efforts should be focused on enhancing collaboration and communication between social workers and counselors while upholding the unique roles and contributions of each profession.
Due to the significant difference in LPC and LCSW requirements, ethics, and education, I am opposed to the power imbalance inherent in this role and oppose the proposed decision to allow LPCs to provide supervision to license-eligible social workers.
Until 2019, the Board of Counseling allowed LCSWs (and Psychologists) to supervise LPCs towards licensure. I want to say at the beginning of this comment that I also support changing those new rules to allow LCSWs to supervise Residents in Counseling as well. I do not think it unreasonable to ask both Boards to work together to ensure there is a two-way arrangement.
I think that at least part of the supervised hours should be able to come from people in other, closely related, disciplines. Perhaps the Board could decide that only up to half of supervised experience hours could come from an LPC. I also think it could be fair to say that an LPC must have a doctorate in order to supervise Social Workers towards becoming LCSWs. I certainly see no reason that an LPC with a doctorate should not be allowed to supervise some portion of a Social Worker's hours if that Social Worker wants.
To respond to some of the concerns others have here, I would point out that, in terms of codes of ethics, everyone with a license is bound to follow the rules of the licensure Board they are licensed under. Social Workers would have to follow their Board's regulations regardless of who is supervising them. Even within a discipline individuals only have to follow their professional association's Code of Ethics if they are a member of that organization, which many professionals are not - so we already have many professionals in these fields who are not actually bound by their professional organization's code of ethics. This may be unfortunate, but it is already the case. However, they are all bound by state licensure Board regulations, which does not change under this proposed new flexibility in supervision. This rule would not change anything about the regulations that Social Workers in Virginia have to follow, aside from the new option for supervision. Some individuals in this public comment section may make broad claims about risk to the public, but I see no actual evidence of that. I do not think that having LCSWs supervise LPC Residents before 2019 was a risk to the public.
This new rule would increase access to options for supervision. Yes, supervision may be completed online, but many people prefer in-person supervision, and may wish to work at a site that only has an LPC available as a potential supervisor. On-site supervision has numerous advantages, including that your supervisor may know the area, population, or even a specific client's situation. Finally, many individuals in our fields specialize. It is not unreasonable for a Social Worker who is accruing hours towards licensure to want a supervisor who has specific knowledge of a population they are interested in. What are they to do if no approved supervisor Social Workers in their area have knowledge with that population? For example, if one wants to work with individuals with Cluster C personality disorders, it may be hard to find a supervisor with that particular skill set. If an LPC with such a skill set happens to be available, and both parties are willing to agree to that supervision arrangement, why not have some flexibility to allow it?
In summary, I think it would be beneficial to allow LPCs and LCSWs (at the very least those who have doctorates) to supervise each other for a portion of hours towards licensure in each other's disciplines. I believe this is a very moderate compromise that would help a lot of people, share specialized knowledge across disciplines, and increase access to high quality and specialized supervision. Thank you for considering this, and I do hope both Boards can work this out.
Hello,
I am writing in opposition of this petition for change based on the different paths and backgrounds of LPCs and LCSW and the detrimental impacts to the SW field if LPCs are held at a higher esteem than LCSWs stemming from the suggestion that LPCs can supervise MSW supervisees but LCSWs are unable to supervise LPCs. I support collaboration between the fields, but this petition would create an incorrect hierarchy in mental healthcare. It would be terrible for the community and people we serve to disregard the differences between LPCs and LCSWs.
As a supervisee in social work, I would feel concerned about the differences in licensure, education, and requirements between myself in pursuing my LCSW and an LPC supervisor.