I support the petition.  Generally speaking, a regulation should be reasonable and should serve the public interest.  As currently written, the Virginia Board of Social Work's licensure regulations fail on both counts.  First, the regulations unreasonably prevent qualified licensed clinical social workers from other jurisdictions from obtaining their licenses in Virginia.  As the petition states, if a licensed clinical social worker stops practicing for 24 or more months in the 5 years before seeking licensure in Virginia, the regulation bars the social worker from obtaining a license in Virginia without regard for the reason why the social worker stopped practicing, and without regard to the professional experience that the social worker may have developed over the course of his or her career.

Second, Virginia's citizens are not well served by the Board's regulation.  Specifically, because the Board's "checklist" approach to reviewing licensure applicants excludes well qualified licensed clinical social workers, Virginia's citizens lose the benefit of the applicants' expertise and the support that their assistance would provide.

I urge the Board to take action to correct its regulations as quickly as possible.