I am writing in opposition to the proposed change that would reduce the training requirements, and eliminate ongoing continuing education requirements, for social work supervisors. This proposal lowers a threshold for qualification that is already less than that of clinical social work supervisors in other states, as well as other mental health practitioners in Virginia. For instance, some states (like Minnesota, where I used to practice) require that clinical supervisors have 30 hours of formal supervision training before they begin supervising aspiring clinical social workers. Additionally, a more stringent training requirement is currently in place for Virginia's Marriage and Family Therapists and Licensed Professional Counselors, whose supervisors are required to have 20 hours in supervision-related continuing education before accepting supervisees.

Second, the proposal to eliminate the ongoing continuing education requirement for clinical social work supervisors in incongruent with best practices in social work supervision, as set forth by the National Association of Social Workers and the Association of Social Work Boards in 2013. These best practices include recommendations that social work supervisors not only complete a minimum number of hours in supervision-related coursework or continuing education, but that they regularly complete a minimum number of hours in continuing education to maintain their supervision credentials.

I do not support any regulatory change that weakens, instead of strengthens, the standards by which clinical social work supervisors are deemed qualified. Furthermore, I am troubled that these changes have not been subjected to a full and thorough review. Any change that has the potential to increase risk to social work practitioners (in this case, supervisees) as well as clients should not be fast-tracked for approval, but instead be evaluated via a full regulatory process.

Thank you for your time and consideration.