|Action||Reduction in CE requirement for supervisors|
|Comment Period||Ends 7/24/2019|
Opposition to Proposed Regulatory Changes
Elizabeth Dungee-Anderson, PhD, LCSW, BCD, CTST
JKT Associates, LLC
1901 Huguenot Rd, Ste 303
North Chesterfield, VA 23235-4311
To: VIRGINIA Board of Social Work
Elaine Yeatts, Senior Policy Analyst
Jaime Hoyle, Executive Director, Virginia Board of Social Work
I am writing in opposition to three positions that the Board has currently identified for which it proposes legislative changes. The first of the three proposals is to abolish the legislated LCSW Supervisor 5-year training updates; the second is to reduce the hours for the initial LCSW Supervisor training requirement, and the third is to fast-track this proposed legislation as opposed to subjecting it to the full regulatory review process.
As is posted on the Virginia Department of Health Professions public website, the mission of all of the Professional Regulatory Boards which includes the Board of Social Work provides the following statement:
“The mission of the Department of Health Professions is to ensure safe and competent patient care by licensing health professionals, enforcing standards of practice, and providing information to health care practitioners and the public”.
My opposition to the proposals is two-fold. First, it seems that the Board is taking a very questionable and risky stance in proposing to remove the current 5-year requirement for approved social work supervisors to renew/update their supervision training and, also proposing to shorten the original number of supervision training hours required for eligibility for approval as a supervisor for LCSW eligibility. Respectfully, these proposals appear to defy any possible logic if you, our SW Board, are “governing” us and you are truly supporting the mission of the Board to promulgate legislation that actually supports safe and competent care for consumers of our services! Social Work has fought long and very hard for its rightful and now recognized position among other behavioral health science professions. Over the years, the slow recognition of our rights as a profession has included all of the following: Licensure as clinical social work practitioners with the legal right to practice independently, to bill for services performed, to respond in legal situations with “privilege” as afforded to physicians, attorneys and other providers of mental health, psychiatric and behavioral health services, and most importantly, title protection.
As the Board is clearly aware, it is now unlawful in Virginia for persons not formally trained/educated with a social work degree to identify as a social worker and for organizations at all levels to hire a non-social worker for a position advertised as a social work position. As is strongly supported and stringently required in professional training for psychiatrists, psychologists, nurses and, currently, social workers, best supervision practices and current evidence-based knowledge are requisite tools for competence in professional practice. Is there any profession that does not require updated knowledge and training for its “teachers” in the professions who educate, supervise and “train” the newly emerging professionals? If the definition of supervision means “to oversee”, would the social work profession, having experienced a strenuous journey to become a legislatively recognized and valued profession, now elect to take a stance which suggests that it does not value updated and current evidence-based required training/education for its supervisor “teachers on an “every five years” basis?
The recommendation of the current Virginia Social work Board to abolish the 5-year updating of the supervision requirement for clinical social work supervisors creates a great risk for the social work profession. Many supervisors across all professions work diligently to remain informed and current in theoretical, practice and research-based knowledge, however, as with all professions, others do not. The supervisors who do not seek peer-reviewed and professional venues for updating of professional knowledge and new research-based content because of cost, inconvenience, or the absence of motivation, or simply, ease in continuing supervision without additional effort, are those that will likely struggle with professional currency and yet continue to supervise. And, understandably, their supervisees also may struggle with professional competency.
As the Board is also aware, the education and training requirements of the social work profession were reviewed by an earlier Board of Social Work that had the wisdom and foresight to take a visionary stance in instituting a requirement for all clinical social work supervisors to be approved to supervise practitioners seeking eligibility for clinical licensure. That Board sought to ensure and sustain the growing recognition and respect of the social work profession with its specific service arenas commensurate with other recognized health and behavioral health professions. In its infinite wisdom, the earlier Board realized that competent education and training and competent enlightened and enriched supervisory practices would help to ensure this outcome and support competent supervision - but more importantly, the Board obviously recognized that by regulating those that “oversee” professional licensure training and competency, it was also very strongly attending to its fiduciary responsibility and mission, e.g., “to ensure safe and competent patient care by licensing health professionals, enforcing standards of practice, and providing information to health care practitioners and the public”
Consequently, it cannot become the heritage of social work supervision that the current Board of Social Work does not require updated supervision and has also downgraded the hours required based on inconvenience to practitioners – and that it “fast-tracks” such a proposal to seemingly try to rush it through! What profession works hard to make competent training and practice “easier” if it also wants to remain respected and commensurate in its areas of practice with its peer professions and if it takes seriously its mission, which again is “to ensure safe and competent patient care by licensing health professionals, enforcing standards of practice, and providing information to health care practitioners and the public”?
These are troubling issues that appear to go against professional and public trust in our professional regulatory agency. Respectfully, and as an LCSW practitioner, trainer and supervisor, for many years, please reconsider your proposals for the support of the practitioners who currently have faith in your regulatory oversight and faith in you as Board members who volunteer your time and energy for the cause of our professional standards.
Elizabeth Dungee-Anderson, PhD, LCSW, BCD, CTST