April 28, 2025

Teresa Reynolds, MSW, LCSW

Chairperson

Virginia Board of Social Work
Perimeter Center
9960 Mayland Drive, Suite 300
Henrico Virginia 23233-1463

Re: Petition to amend 18VAC140-20-45 “Require examination for licensure by endorsement if original jurisdiction did not require examination at time of licensure”

Dear Chairperson Reynolds and Distinguished Board Members:

I write to you today on behalf of the Association of Social Work Boards (ASWB) to share our support for the Petition to amend 18VAC140-20-45 (Petition). ASWB is the nonprofit professional association that supports regulatory entities across 64 U.S. and Canadian jurisdictions. ASWB’s mission is to advance safe, competent, and ethical social work practice to protect the public. As part of that mission, ASWB develops and maintains the licensing examinations used to assess a social worker’s readiness to practice safely and ethically. ASWB was formed for this purpose in 1979. The change proposed by the Petition ensures that social work applicants initially licensed outside the state of Virginia are required to demonstrate minimum competence through a uniform assessment tool; this is consistent with Virginia’s requirement for first time license applicants to the state. ASWB respectfully asks the Board of Social Work to consider how the regulations cited in the petition can be strengthened to best serve the Board’s crucial public protection mandate.

ASWB firmly opposes any effort to bypass the examination requirement for licensure in Virginia. The examination serves as a critical safeguard—ensuring that individuals entering the profession possess the foundational knowledge necessary to serve the public effectively, ethically, and safely. The language flagged in the Petition to amend 18VAC140-20-45 reflects the regulatory landscape during a time when exams were first being adopted across U.S. jurisdictions in the 1990s. However, exams have since become a cornerstone of professional licensing qualification standards; exams are nearly universally required across U.S. jurisdictions. The Interstate Social Work Licensing Compact reinforces examination as necessary for practitioner access to a multistate license.

Professional licensure decisions are generally grounded in three pillars: education, experience, and examination. Of these, only the licensing exam provides a standardized, continuously vetted, and objective measure of entry-level competence. Bypassing this requirement would compromise both the integrity of the licensure process and the principle of public accountability that is core to our profession.

 Exempting applicants from the examination requirement undermines public trust in the title “licensed social worker.” It also creates regulatory inconsistencies between social workers initially licensed in Virginia and those obtaining additional licensure in the state, which has impacts that need to be carefully considered. Most importantly, it reduces public protection standards. Virginians, particularly the most vulnerable receiving social work services, deserve assurance that the professionals supporting them have demonstrated the competence necessary to provide safe and ethical care.

Last year Virginia adopted the Interstate Social Work Licensure Compact. The Compact requires social workers to take and pass the qualifying national exam that corresponds to the category of multistate license sought. Therefore, licensing applicants without an exam sets up a bifurcated licensing system in the state where social workers are licensed under two different standards. This will create differences among social workers with the same “licensed” title, and raises concerns such as:

• Public Confusion: Virginians deserve clarity and consistency regarding what it means to be a “licensed social worker.” Divergent licensure standards can create uncertainty for individuals seeking services, potentially diminishing trust in the profession.
• Professional Disadvantage: Social workers licensed without having passed the national examination may face unintended limitations. Their qualifications could be challenged in legal settings where expert testimony is required. Additionally, agencies such as the Veterans Health Administration require passage of the exam for social workers to advance beyond entry-level positions, creating inequities among professionals with the same title.
• Administrative Burden: A dual-standard licensing system adds complexity and cost for the regulatory body responsible for oversight, straining resources and creating inefficiencies.

Recently, changes to licensing exam requirements by a few states has consequences that merit consideration. State license by endorsement provisions that do not expressly require examination inadvertently provide an opportunity for out-of-state licensees to skirt the same standards upheld by initial licensees to the state. ASWB respectfully requests that the Board consider the petition before you. The examination is a critical component of public protection, regulatory accountability, and professional standards. Licensing authorities are called on to be responsive to changing regulatory landscapes. Please consider how the Board may further strengthen Virginia’s social work regulations.

Thank you for your attention to this matter and for your continued commitment to public protection.

Respectfully submitted,

Cara Sanner

Director of Regulatory Services

Association of Social Work Boards

 ASWB is a nonprofit association whose members comprise the 64 social work licensing authorities from the United States and Canada. ASWB is recognized under section 501(c)(3) of the Internal Revenue Code as an entity that provides programs and services to social work regulatory boards in promoting uniformity and lessening burdens on state governments.