I am an LCSW in Virginia who also provides supervision towards MSWs seeking to obtain their LCSW.  I am NOT in favor of any additional gatekeeping to the profession in the form of testing which is both costly and time consuming at the outset.  Furthermore, the recent ASWB report dated 8/5/22 on the pass rates for examination are deeply concerning although they confirm what many of our colleagues have been telling us for years.  It is time to listen, evaluate the report findings, address the racial/ethnic disparities, AND open the door to conversation about alternative paths outside of testing.  As a profession the NASW values and ethical principles require that we challenge social injustice AND respect inherent dignity and worth of people.  I believe that we as a profession have run afoul of those principles when we develop and continue practices which are shown to be harmful to others.  I believe that we have an opportunity to change course and a moral and ethical obligation to our profession to do so.  Increasing testing as a method to 'screen in/out' social work graduates to levels of practice within the profession is ill-advised.

Requiring this credential/certification would create an additional barrier for supervisees. We need more LCSWs to grow our profession as many of us are experiencing LMHP workforce shortages.

Given the data report released by the ASWB on August 5, 2022 the public and regulatory boards across the country now have access to incredibly concerning information. The ASWB data report revealed the vast disparities in pass rates of the clinical and master's level exams across racial groups. In Virginia, white test taker take and pass the LMSW and LCSW exams at rates double to Black test takers. There is confirmed testing bias laced within the ASWB examination process and this petition will only further restrict access to licensure for Black and Brown folks in the Commonwealth. I do not support this petition! 

Given the data report released by the ASWB on August 5, 2022 I do not support this move. The ASWB data report proved what many of us in the field suspected.  There are large disparities in pass rates of the clinical and master's level exams across racial groups.

In Virginia specifically, white test takers pass the LMSW and LCSW exams at rates double to Black test takers. There is confirmed testing bias laced within the ASWB examination process and until this is addressed and corrected, a measure such as this should not even be considered. I do not support this petition! 

As someone who is currently in the process of supervision and has personally experienced the barriers and difficulty in getting to this point I absolutely do not support  this. The current results from ASWB shows a pass rate of 45% for black individuals and 84% for white. There is clear testing bias in these results and this petition only presents additional barriers for black and brown people. 

I do not support this petition.

Data from the 2022 ASWB Exam Pass Rate Analysis confirms that the ASWB exams are deeply flawed, biased exams that serve as massive roadblocks to clinical licensure that disproportionally impact Black, Latine/Hispanic, and Indigenous test-takers. Our code of ethics calls us to challenge social injustice, to promote the well being of our clients, to stand for integrity, and to bolster the well being of our communities in general. This petition – and putting more barriers in place toward clinical licensure, particularly for clinicians who are Black, Latine/Hispanic, or Indigenous, - flies in the face of our ethical obligations as social workers and does harm by preventing our communities and clients from having access to a diverse field of qualified clinical social workers.

Again, I do not support this petition and urge the VA Board of Social work to examine the inequities inherent in the social work licensure requirements.

As an LCSW in Virginia, I do not support this petition. This will only increase the level of gate keeping and racial and economic disparities within the profession. The recent release of the data from ASWB shows clear bias in testing protocols that must be addressed. Our code of ethics calls on us to eliminate such barriers, not implement more of them. I do not support this petition. 

This proposed regulatory change will only further limit access for social workers who have completed their MSW from obtaining their certification as LCSW. We must remove barriers not erect them. Now more then ever we need paths for the committed and competent social change agents to serve and empower our most vulnerable. I do not support. 

We have a difficult enough time getting licensed folks to fill jobs.  The Board should not make it any harder to get a license. 

I do not support this change in licensure requirement in Virginia. The process for licensure is already complex and lacks limited support for those who are seeking licensure.  The supervision process makes it difficult for those who are at the MSW level afford not only a college education yet the cost of registering and paying weekly for supervision.  I often receive multiple request for clinical supervision as there is also a limited number of LCSW's who can provide quality supervision.  I think the focus should be on how we can best support and uplift those who want to and are already engaged in social work practice.  

I do not support 

This is unnecessary gatekeeping that will disproportionately impact our BIPOC colleagues. 

This is another classist money grab to gatekeep social work. This goes directly against the core values of social work. This should not be disguised as a quality improvement/control method. It’s morally wrong to continue to put expenses and barriers in the way of social workers who want to support others. Social work is SUPPOSED to be about removing barriers, not creating them. I do not support this 

I am in favor of this petition #371 as it would make Virginia consistent with 80% of the other US states regarding Social Work regulations.

I am in favor of petition #371 as it would make Virginia Social Work regulations consistent with the Virginia Board of Counseling regulations; and, the Virginia Behavioral Science Boards should maintain parity on this issue.

I am also in favor with this petition in that is should allow Virginia to participate in the Interstate compact for Social Work. This would aid Virginia Social Workers to have portability with their licenses. 

During the pandemic the mental health system was stressed. As Maryland, North Carolina, Tennessee, West Virginia, Kentucky, and Washington DC are contiguous to Virginia, passage would allow Virginia Social Workers to cross those boundaries more easily.

I do not support!

I support the proposal to require a supervisee working toward becoming a licensed clinical social worker to obtain licensure as a licensed master's social worker while obtaining required experience under supervision.  

When dealing with mental health and well-being of the public, I believe it is of the upmost importance for social worker professionals to have licensure to practice as they interact with their clients.  

I am writing in strong support of requiring persons desiring licensure as an LCSW to have passed the ASWB master's exam as well as meet the requirements for the Commonwealth of Virginia's LMSW prior to being allowed to collect supervision and clinical hours.  

This would bring Virginia in line with the majority of jurisdictions in the US.  As it stands now, other than graduating from an MSW program, there are no safeguards in place to verify that a supervisee in clinical social work commands basic social work knowledge, skills, or abilities.  ASWB exam passage would demonstrate such knowledge.

Respectfully,

Brian Rink

I support the petition for all of the reasons below. When I was the Chair of the Board, the idea of licensing at the MSW level, was well vetted by the regulatory committee and full board. It passed to the governors office but never made to to the GA. ASWB strongly supported moving forward with it. This action will actually make the LCSW professional role even stronger in the eyes of funding sources. 

I support the petition for rule making #371 and appreciate how essential it is in two respects: 1) to facilitate interstate portability of licensure (through parallel regulations among states), so needed when practice is done increasingly online between clients and practitioners living in different states, and 2) ensuring that social workers at all levels of their post-degree practice demonstrate the knowledge required for safe, competent and ethical practice. I am deeply concerned by the ASWB's findings of disparities in the pass rate of the ASWB exam.  I agree with the CSWA's recommendations (Sept. 2022) that the identified issues with the ASWB exam be addressed fully and forthwith, including the corrective actions announced by the ASWB.  My support for petition 371 and its dual importance - to the Interstate Compact and our profession's ongoing obligation for accountability - is based on a perspective that spans 29 years of experience as an LCSW in both the public and private sectors. I do appreciate the Board of Social Work's consideration of public comment in this matter. 

I support licensure for supervisees in clinical social work replacing registration.

I am in favor of the petition #371 because it will make Virginia regulations consistant with 80% of the other US
states social work regulations.

I support Petition #371

For consistency across the Virginia Behavioral Sciences Board and

For parallel regulations among states

Changes in the ASWB exam and licensing supervisees in clinical social work will ensure safe, competent, and ethical practice for all post-degree practitioners.

I support proposition 371 for a variety of reason of which foremost is helping to strengthen the professionalism of social work through the requirement that a supervisee receive a masters license while uder supervision when working towards the required experience towards an LCSW .  

I support this initiative to help facilitate greater access to mental health care. 

Thank you,

Matt Levine, LCSW

I am in favor petition #371. I support this change in regulatory rules for the following reasons: it will make Virginia regulations consistent with 80% of the US states; it will help Virginia participate in the Interstate Compact for Social Work licensure. (This will aid social workers in having portability in our mobile workforce. I am an example- I have been licensed in Virginia since 1978 as an LCSW; I retired and moved to Maryland in January of 2020. I cannot practice in MD.) I am in favor of this rule change as it will make Virginia social work regulations consistent with the Virginia Board of Counseling regulations. Finally, I support this petition to make mental health care  delivery amongst the contiguous states (MD, NC, TN, KY, WVA, and Washington, DC) to Virginia less of an obstacle and to allow LCSW's the ability to easily cross state boundaries. Thank you for your consideration.

  Wayne A. Martin, LCSW.  Member of the Virginia Board of Social Work (7/2004-6/2012);    Chair of the Virginia Board of Social Work (7/2010-4/2012)

I am writing to lend support in favor of the passage of Petition 371 because it will help bring Virginia standards and procedures into alignment with other states and their regulations; and this will help to further the ultimate  employment of the Social Work Compact to ease the ability of Virginia licensed Social Workers to transport their skills across state lines, in particular with states we border.

It is vital that social work supervisees become licensed as LMSWs as they complete their hours under supervision. Doing so ensures public safety and the integrity of the field of Clinical Social Work.

Sincerely, Stephen M Szopa, LCSW

I am in favor of the petition for rule-making #371, because it will make Virginia regulations consistent with the social work regulations in 80% of the other US states, as well as with the Virgina Board of Counseling regulations. 

Of significant import, this petition will help Virginia to participate in the Interstate Compact for Social Work, facilitating portability of the license Virginia social workers hold.  During the Pandemic, the mental health service delivery system was stressed, and continuity of care was too often disrupted, due in no small part to the difficulty for licensed Clinical Social Workers to easily cross state boundaries. 

I am in favor of the petition for rule-making #371.  It will help Virginia participate in the Interstate Compact for Social Work.  This helps Social Workers to have the portability of their license.  

I support Petition 371. It will establish parity with other professions in Virginia. It will also improve access to qualified behavioral health services by helping Virginia participate in the Interstate Compact.

Dan Campbell

I support this petition for three reasons (in brief):.

1. Social Work is the only mental health profession in Virginia that does not license supervisees.  The LPC holds a Resident License.  Social Work must be brought into parity with the Virginia Behavioral Health Boards.
2. 80% of States and DC require licensure for supervisees in clinical social work.  Virginia must meet the prevailing professional standard rather that remain in the low 20%.
3. The Department of Defense is leading the movement to develop an interstate compact which will facilitate multistate practice among member states.  Licensing the supervisee in Clinical Social Work will increase portability when that time comes and meet the prevailing standard (80% licensure for supervisees in clinical social work).

Dolores S. Paulson, PhD, LCSW Past Member of the Virginia Board of Social Work

Past Member of the Board of Social Work

Past Chair of the Virginia Board of Social Work

I am in favor of this petition because it will make Virginia regulations consistent with 80% of the other US states with social work regulations.  This petition and changes it advocates for will help Virginia to participate in the Interstate Compact for Social Work.  This will enhance LCSW portability.  As someone from Roanoke with family down in the Bristol VA/Tenn area , I have direct knowledge of the importance of portability  ( particularly in the underserved areas of SW Virginia and contingent states ie Tennesse and West VA and mountains of NC, ) 

I am in favor of the petition for rule-making #371.

NASW Virginia representing over 3,000 socialworkers supports this petition.  We have supported the boards previous efforts to create this level of licensing.  Social Work is the only mental health profession in Virginia that does not license supervisees. Social Work must be brought into parity with all other Behavioral Health Boards. This will also align the Commonwealth with 80 percent of the states including the District of Columbia, that require licensure for Supervisees in Social Work.

This will also position Virginia to join the interstate compact effort that is being lead by the Department of Defense.

The result of this petition will bring clarity to the various levels and scopes of practice for both the public and the emerging workforce.

I support this regulation change.  It brings Virginia in line with many other states and facilitates our participation in a multistate Compact.  It also enhances the Boards mandate to protect the public.

I am in favor of the petition #371 because it will make Virginia regulations consistant with 80% of the other US
states social work regulations.

I strongly support  petition #371. The VSCSW has submitted a well thought out position on this important question

While I support the petition because it is widely the standard in other states and does provide oversight for protection of the public, the exam not only adds yet another cost to new professionals. The exam does not require the social worker to demonstrate an awareness of and ability to effectively work with structural inequities among races, classes, sexual orientations and other influences which impact the persons with whom we work. The exam rather disregards difference, something we as social workers pride ourselves on honoring. 

This  problem goes back to training both in the classroom and the field. While this is an issue for CSWE, the difficulty students have with this exam suggests that we have a great deal of work to do not only with the exam but in our education of all social work students. 

I support this petition

I support this proposal. As a former Virginia Social Work Board member who previously worked on this issue in the Regulatory Subcommittee, I am convinced that the change, if adopted, will result in an improved quality of client care, bring the Board into parity with other Virginia Behavioral Health Boards, and increase the portability of supervisory arrangements across state jurisdictions.

I am writing to support this proposed change in the Commonwealth of Virginia's rule to require licensure for recent graduates who are in supervision working toward the LCSW in order to protect the public and ensure the integrity of the social work profession. This requirement that an LMSW license be obtained prior to earning supervised hours towards a Clinical license will bring our state in line with 80% of the states that already require this and will highlight differences in standards the LMSWs are held to vs Qualified Mental Health Professional (QMHPs).  Also of great importance is that by doing so, it provides protection for the public and for supervisors, who, at present, assume risk for the supervisee under their own licenses. 

Thank you, Katharine Z Rossier, LCSW

I am in favor of Petition #371 because it will help Virginia participate in the Interstate Compact for Social Work. This helps Social Workers to have portability of their license. 

I am in support of petition #371 because it will help Virginia to participate in the Interstate Compact for Social Work.  This helps Social Workers have portability of their license.  

I am in favor of this petition #371 for the following reasons:

1) petition would make Virginia consistent with 80% of the other US states regarding Social Work regulations.

2) petition would make Virginia Social Work regulations consistent with the Virginia Board of Counseling regulations; and, the Virginia Behavioral Science Boards should maintain parity on this issue.

3) petition should should allow Virginia to participate in the Interstate compact for Social Work. This would aid Virginia Social Workers to have portability of licensure.

Thank you for the opportunity to review and add support.

Kathleen Struble, LCSW

I am in favor of the petition #371 because it will make Virginia regulations consistent with 80% of US states social work regulations and will help social workers have portability of their license. 

I support this regulation change. This would bring Virginia in line with 80% of US states and would facilitate VA's participation in a multistate compact. This change would also enhance the Board's mandate to protect the public.  

Sincerely,

Christine Alam, LCSW

80% of social work nation wide has adopted a similar rule in order to protect the public.  The MSW graduate is a social worker, and therefore, the public have a right to expect  certain levels of skill and competence and feel secure in that knowledge.  Some people object to this change on the basis of the ASWB exam, which has been shown to be biased against people of color.  I see these as equal but separate issues, and because I know that the exam is being examined and will be changed, I support the rule change on its own.

We represent Clinical Social Workers from Northern Virginia, in addition to DC and Maryland. The proposal that VA change its rule to require licensure for recent graduates who are in supervision working toward the LCSW will help protect the public and ensure the integrity of the social work profession. The requirements for obtaining an LMSW license prior to earning supervised hours towards a Clinical license will be in line with 80% of the states that already require this. It also provides protection for the public and for supervisors, who, at present, assume risk for the supervisee under their own licenses.

The petition will make Virginia social work regulations consistent with the Virgina Board of Counseling regulations. The Virginia Behavioral Science Boards should maintain parity on this issue. 

Additionally, it will help Virginia to participate in the Interstate Compact for Social Work. This helps Social Workers to have portability of their license. 

For all these reasons, we urge that the petition be approved.

I support this petition because 1) it seeks to better provide clients, who are increasingly mobile by necessity, continuity of care across state lines (via the compact); 2) it puts us on par with the regulatory expectations of supervisees in counseling working towards their LPC; 3) it expands greater protections of the public in a time where more and more new social workers are needed in our communities to respond to and assist clients with challenging and difficult situations requiring clinical services; and, 4) it expresses our social work values of integrity and competence. These are all important.

Yet... also important... if our processes and tools used to confer licensure are unfair or biased - racially or otherwise - we as social workers have failed to uphold our social work values of social justice and the dignity and worth of the human person. There are significant questions right now about racial bias in standardized exams, the cost of clinical supervision, lack of access to effect exam preparation, what schools of social work sometimes teach versus what regulators might test, and perhaps other barriers. While some solutions appear underway, greater transparency is needed, many questions remain, and reform seems essential.

Our professional community could be so more united and stronger with better faith and trust in our licensure processes. We are social workers... helping solving problems is what we do. We can solve this.

I again support this petition, but there is more work to be done.

With highest respect to all who contributed in this town hall, Christopher Jenkins, LCSW