Public Comments regarding 22VAC40-675; Personnel Policies for Local Departments of Social Services

NASW-VA is pleased to have the opportunity to provide our comments on the review of 22VAC40-675 Personnel Policies for Local Departments of Social Services under Executive Order 14 (2010) and §§ 2.2-4007.1 and 2.2-4017 of the Code of Virginia.

This periodic review of the regulations is a clear opportunity to amend 22VAC40-675 to comply with the new law regarding the job title of Social Worker. The Virginia General Assembly passed HB 2037 (Peace) in 2011 and it is set to become law July 1, 2013. The Code of Virginia now reads:

§ 54.1-3709

A. It shall be unlawful for any person not licensed under this chapter to use the title "Social Worker" in writing or in advertising in connection with his practice unless he simultaneously uses clarifying initials that signify receiving a baccalaureate or master's degree in social work from an accredited social work school or program approved by the Council on Social Work Education or a doctorate in social work.

As of July 1, 2013, the regulations in their current form will violate § 54.1-3709. The NASW-VA recommends that this section be amended to comply will the law by removing any reference to the previously used terms “Social Work” or “Social Worker” to describe general job categories or job titles. These titles should now only be used in conjunction with an employee who has the appropriate social work eduction as designated in § 54.1-3709.

It is important that the DSS regulations addressing personnel policies for local agencies accurately reflect the current law, starting July 1, 2013.

We suggest the following proposed changes for 22VAC40-675-60 specifically:

“Approved occupational titles may only include “Social Worker” if the assigned employee holds a baccalaureate or master’s degree in social work from an accredited social work school or program approved by the Council on Social Work Education or doctorate in social work.”

We thank you for your consideration of this important matter.