The requirements to become a certified clinical supervisor in Virginia are quite strict and frankly discouraging for those of us with many decades of experience in the field.  We do not need to require yet another round of 14 training hours every 5 years.  I have been supervising social workers since 1978 and do not need more than a refresher of 2-3 CEUs on any new legal, ethical or best practices developments in the field.  Please limit renewal requirements to 2 CEUs per renewal period (every 5 years).

I am a social work educator and clinical social worker in private practice.  I have nearly 4 decades of supervisory experience with students, post Master's employees and licensed therapists. I fully understand the need for social work to provide qualified supervisors to assure that the knowledge, skills and ethics of the profession are carefully taught and modeled. This is crucial for the protection of the public.

That said, a licensed professional who has had the requisite 14 hour training program should be fully qualified to provide supervision with an update every 5 years if there are significant regulatory or procedural changes. A professional's continuing education with its current requirements for ethics training are considered adequate for practice which also should include supervision.

I am a more recent Licensed Clinical Social Worker, as of 2010, and support the proposed limitation to supervision renewal.  It is already challenging for new MSW graduates to find proper employers and supervisors to become licensed.  The current regulations will only make this more difficult, thus our state will have a depletion of LCSWs. 

Additionally, the 14-hour regulations discourage someone like me to seek supervisor certification.  I currently work full-time in a hospital and part-time at a private practice in order to survive financially.  The current regulation is costly and time-consuming, which causes me to re-consider my goal of supervising in the future.  In order to obtain and sustain adequate professionals, I strongly support the proposed regulation to reduce the number of CEU hours for supervision re-certification.   

Regarding the proposed rule change for 14 hours of education needed every 5 years in order to remain a supervisor in good standing in Virginia: I do not see how this can be necessary. As clinicians our greatest asset is furthering our education and knowledge so we can pass that on to new people in our profession. If we are not good communicators or educators that will become known in the community and licensees will not come to us for help. Forcing us to review the regulations and rules will not help with knowledge about how to treat and diagnose clients. Please give us the common courtesy of assuming that we are being responsible toward the rules and regs of Virginia so our supervisees will be well taken care of and actually gain licensure. Please do not treat us as if we are children who cannot follow the rules and regs in the statutes. We can. We do everyday. I do not force a data entry person to take the same course on data entry over and over again. I don't force a lawyer to retake the bar on rules and regs over and over. Give us the same dignity as we give these folks. Let us learn something new to add to our knowledge base, to pass on. Thank yu for your attention to my letter.

I believe that the 14 hours of CE every 5 years is a needed requirement. Since the 14 hours can be used toward licensure renewal, I don't believe that it creates a burden. If anything, it allows the supervisor to become familiar with any updates on Regulations or changes in supervision requirements.

NASW-VA is pleased to have the opportunity to provide comments on the Petition for Rulemaking to amend 18VAC140-20-50, regarding continuing education requirements for supervisors.

The Petition for Rulemaking proposes an initial requirement of 18 hours of supervision training and then two to three continuing education units for renewal.

Regulations currently state the following:

The supervisor shall have received professional training in supervision, consisting of a three credit-hour graduate course in supervision or at least 14 hours of continuing education offered by a provider approved under 18VAC140-20-105. The graduate course or hours of continuing education in supervision shall be obtained by a supervisor within five years immediately preceding registration of supervision.

The NASW-VA believes that an initial requirement of at least 14 hours of supervision training is important and adequate.  We support this requirement, as a minimal amount needed for a professional to develop necessary skills and understanding of this important role. Although we agree with the petitioner on portions of their comments, NASW-VA believes that there should be a minimum of seven hours of training per renewal cycle. As a leader in the area of Supervision, NASW-VA has trained hundreds of Supervisors to perform this role for upcoming professionals and understands the importance of it for both the supervisor and supervisee. There is a large amount of information that necessitates more than two to three contact hours per renewal. We believe that it is vital to have ongoing and consistent professional development particularly when one is training to become a licensed professional. NASW-VA believes that similar to a certification process, the Supervision Requirement should be renewed on a three-year cycle with seven hours of training required. By utilizing this model, we can help ensure that the latest practices in behavioral health are passed on to our future professionals. 

We agree with the petitioner that requiring this many hours every five years can be burdensome to obtain. Therefore, we believe our proposed requirement for at least seven hours of continuing education units every three years is a much more reasonable requirement that will still ensure supervisors are adequately trained and updated on best practices.

Thank you for the opportunity to comment on this matter. 

As an LCSW with over 40 years of experience in the Social Work field (Va. License #332), I support the Petition submitted by Carol Gauzens,LCSW for Limited Renewal Requirements for those Certified to provide Clinical Social Work Supervision.pe over this text and enter your comments here. You are limited to approximately 3000 words.