The National Association of Social Workers of Virginia (NASWVA) respects and supports the importance of assuring a minimum standard of clinical competence for social workers. This standard protects consumers by mandating all clinical social workers have the appropriate level of education and corresponding knowledge base to intervene effectively.

            While the Guidance Document validates the significance of this standard, potential impact for the workforce is not without concern, thus, having the potential to create a shortage of professionals, and resulting in consumer protection issues.  The following points are offered for consideration:

1.   The potential to negatively impact candidates from advanced standing programs is at issue.  The current verbiage yields potential adverse implications for communities that may already be in need of competent social work professionals by limiting access to practice at the clinical level of the profession for those with BSW degrees. The document recommends a prescribed curriculum by requiring specific coursework and hours in the “advanced” year of graduate school, resulting in the disqualification of those who may have the appropriate coursework, but in the first year of the Masters Program.

2.      NASWVA values the collaborative efforts and accountability by all entities with Regulatory and Professional oversight for Social Work. These entities assure that the ethics, values and practice foundation are adhered to. However, NASWVA is concerned that the Guidance Document and the potential recommendations contained therein are so specific that,

3.      It will eliminate degreed professionals from obtaining the clinical license (LCSW).  An example of such is the mandated Ethics requirement.  Professional Ethics have been infused into the curriculum of all universities accredited by The Council on Social Work Education (CSWE).  According to the Association of Social Work Boards (ASWB), there are a limited number of Schools of Social Work requiring a specific course in Ethics.  Therefore, if this recommendation becomes regulation, a majority of applicants would not be deemed eligible for the Clinical License in Virginia.

            NASWVA acknowledges and appreciates that the Board’s impetus is to protect the public. However, mandating specific coursework and schedules for completion is too limiting and should not be a matter of regulation.  CSWE is deeply committed to ensuring that accredited Schools of Social Work offer curriculum which prepares graduates to meet the highest standards of professional competence in delivery of services to consumers. 

            We therefore propose that Board of Social Work not enact the proposed regulations as written in the above recommendations.

Respecfully Submitted,

NASWVA