As well-intended as the Guidance Document purports to be, the requirements as set forth  do not appear to accurately reflect the content of what was discussed during the January 10^th, 2008 meeting with the representatives of social work education programs, and Board Representatives, including Ms. Dolores Paulsen, who was given the task of overseeing its development.1. The first paragraph of the Guidance Document “An applicant with a non-clinical concentration must complete remedial graduate level academic coursework and field placement to meet all requirements for a clinical course of study” appears to not only create a “new” education requirement but to also override  Social Work Regulation 18VAC140-20-50 Section 2: “The applicant shall provide documentation of having completed specialized experience, course work or training acceptable to the board as equivalent to a clinical course of study.”If this is the intent, then this will have serious consequences for social work education and practice in the Commonwealth if people must know at the beginning of their education that they want to be clinical social workers. It is not feasible to think, that a social work graduate who had a “non-clinical” concentration, would need to essentially return to school for another graduate degree, if they have been able to work in direct services at some point during their social work career due to their education and training in an accredited MSW program in the first place. If one receives an accredited MSW degree, there is no going back to do remedial course work and field. Additional course work would be acceptable; however, field requirements are impossible to meet because no one could be admitted to a program just to do field work.Foundation year coursework provides the graduate level training needed for any social worker with a degree from an accredited program to work in the direct service arena. A graduate’s supervised professional work experience and professional continuing education should demonstrate whether or not they are prepared to sit for a clinical examination at the time of their application. Again, if the intent of the Guidance Document was to override this section of the current licensing regulation for social work, it appears the Board may have opened itself to a contestable “restraint of trade” issue.2. Paragraph 3 of Guidance Document 140-6, which begins with “The Advanced Year course requirements for a clinical course of study include a minimum of…” requires that all of the course work outlined below actually be completed in the Advanced Year itself.  This eliminates anyone with a BSW degree to attend a social work program as an Advanced Standing student, and fundamentally changes the education curriculum as set forth by the Council on Social Work Education (CSWE). The 6 credit hours of Explanatory Theory is universally encompassed in Human Behavior and the Social Environment (HBSE) courses taken during the Foundation year of a social work program in accordance with the Educational Policy and Accreditation Standards (EPAS) of the Council on Social Work Education. Advanced Standing students are given graduate level credit for Foundation year course work in many social work programs precisely because the BSW degree falls under the accreditation process of the CSWE EPAS. This was clearly stated in the January 10^th meeting by all of the representatives of social work education programs.3. It was made very clear as well during this meeting that it is impossible to teach in an accredited social work program if content on ethics and values is not integrated into Foundation year and Concentration year coursework. Requiring a one Credit course in Ethics is unnecessary for students in an accredited social work program; however, it certainly seems appropriate for this to be a requirement of MSW graduates within a particular scope of social work practice. Adding credits to an already 60 plus credit accredited degree program adds a financial burden for all to students to pay extra tuition, spend extra time in the program, and creates a resource burden for schools in hiring additional faculty or restructuring current faculty workloads.

4. Again, it appears course work in Diversity Issues, Social Justice, etc. are to be completed during the Advanced Year of study. Many of these courses are taken in the Foundation year or content in these areas is infused throughout the curriculum during both years. Not all social work education programs configure course content in a cookie cutter style fashion. If the purpose of higher education institutions is to address the local and regional labor market and human services needs, then the structure of a social work education curriculum in the Northern Virginia region should look different than that of a program in the Blue Ridge area. However, what is very apparent across the country is that Foundation year content is consistently taught in all programs because all programs must meet the national accreditation standards of the CSWE. The Social Work Board should have appropriate persons who can evaluate transcripts with an unbiased view of curriculum structure, and who understand current EPAS.The current EPAS from the CSWE states:EPAS supports academic excellence by establishing thresholds for professional competence. It permits programs to use traditional and emerging models of curriculum design by balancing requirements that promote comparability across programs with a level of flexibility that encourages programs to differentiate.EPAS describes four features of an integrated curriculum design: (1) program mission and goals; (2) explicit curriculum; (3) implicit curriculum; and (4) assessment. The Educational Policy and Accreditation Standards are conceptually linked. Education Policy describes each curriculum feature. Accreditation Standards are derived from Educational Policy and specify the requirements used to maintain an accredited social work program at the baccalaureate or master’s level (CSWE, 2008, p.1).5. The CSWE requires a minimum of 900 hours of field experience for a two year MSW program. The Guidance Document is requiring 600 hours in the second year. This requirement exceeds accreditation standards and is an unnecessary regulation of students in an educational setting. An applicant cannot sit for the LCSW exam in Virginia without completing two years of full time post-Master’s work experience. An applicant from any social work school in Virginia or any state in the U.S. will have completed a minimum of 900 hours of field work, and often times, many more hours because the minimum 900 hours is an accreditation standard. It would be beyond the scope of the Board to dictate the configuration of practicum learning. Some schools have 600 hours in the Advanced Year with a concurrent course work requirement. Others have advanced course work completed prior to placing students in a solid “block placement” where they are immersed in field. How to structure learning is the purview of education institutions. An MSW degree prepares one to begin work experience. Supervised work experience prepares one to sit for the appropriate licensing examination.6. In the next to last paragraph “Supervised Field Placement in direct practice integrated with the Advance Direct Practice Clinical Course of Study course work” appears to prohibit block field placements. This will be an impossible requirement to meet since many social work programs offer Block Placements because of their sound educational value as affirmed by the EPAS of the CSWE.7. The CSWE requires a Field Instructor of students hold an MSW degree from an accredited program and have two years post-MSW experience. The Guidance Document requires three years and this requirement will make it more difficult to place students in agencies that do not have staff that meet this requirement, especially smaller non-profits which serve as a safety net for the some of our most vulnerable populations.

8. This Guidance Document for Clinical Social Work appears to disproportionately place extreme educational requirements on social work that are not so required in other regulations, for example, Psychology (18 VAC 125-20-10) which were just revised as of March 19, 2008. The NOIRA Background Document on Clinical Course of Study describes the Board’s intent to have the education curriculum for graduate level social work students be similar to the curriculum prescribed by the Board of Counseling for Licensed Professional Counselors (LPC) in an effort to have these requirements be similar between the two boards (see attached). To propose the educational requirements between the two disciplines be similar seems to be a misguided effort for the protection of the public if the requirements of the nationally accredited discipline, i.e. social work, reflect the curriculum of the non-accredited discipline, counseling.Social Work Regulatory Boards across the country are looking at the Pass-Fail rates of graduates from various schools who take the LCSW exam developed and distributed by the ASWB, a proprietary entity. This trend is, at a national level, comparing apples to oranges. Social Work education programs teach the “gold standard” of practice while the licensing exams evaluate “minimum competency standards.”  There is meaningful debate in every educational institution and within every social work professional organization regarding the validity of the ASWB exams and what they actually evaluate. Social Work Boards would be expected to participate in this debate before adopting a method of evaluation that may not relate to the Boards’ mission of consumer protection.It is recognized that a social worker’s inability to pass the LCSW exam means they will not be licensed as an independent clinical social worker. The logic of a failure to pass a social work exam relating to the coursework taken two or twenty years previously is flawed. Were this flawed logic applied elsewhere, we would expect malpractice complaints or criminal charges levied against licensed physicians or accountants to prompt the Licensing Boards for those professions to attempt to regulate the schools that educated them. Complaints and ethics breaches of licensed clinical social workers, practitioners who passed the LCSW exam, do not justify the regulation of social work education.Guidance Document 140-6 supersedes the EPAS of the CSWE and as such we cannot support this proposal becoming part of the licensing regulations for clinical social work. We are prepared to work with the Board in this effort.Alternative Recommendations for the Guidance Document:1.  We would like to reiterate that the Social Work Board should have appropriate persons who can evaluate transcripts with an unbiased view of curriculum structure, and who understand current CSWE EPAS.2. Fundamentally, an accredited MSW degree should be accepted by the Board as the basic step in evaluating an application for clinical licensure. This is, in fact, the only education requirement set forth in the ASWB Model Law. The Model Law refers to the basic MSW degree as preparation of social workers with specialized training to practice under supervision for the appropriate level of licensure. Any accredited BSW and MSW degree prepares one to practice in Direct Services regardless of what Concentration was studied.3. The Board should accept as part of a CSWE accredited degree that the NASW Code of Ethics in its entirety is the foundation of all coursework for the degree. Ethical decision making and the use of the Code as the “gold standard” is the guide in this process for all of social work practice. “Clinical Ethics” is not a separate area of focus in Social Work Education, though it may be in other unaccredited professional degree programs.4. Irrespective of Foundation year or Concentration year, LCSW applicants with an accredited MSW degree should be able to demonstrate to the Board that either during their academic program (pre-MSW), or as a professional continuing education (post-MSW) program, they have had graduate level course credit in the following:a. Understanding Psychopathology and the Use of the DSM-IV-TRb. Understanding the role of Neurobiology and Psychopharmacolgyc. The application of Diagnosis (Assessment), Planning, Treatment (Intervention) and Evaluation techniques in working with individuals, families and groupsd. Human Behavior and the Social Environmente. Advanced Researchf. A minimum of 450 hours in a Clinical Concentration year Practicum prior to completing the MSW degree, or 3 years of supervised professional work experience post-MSW if the applicant graduated with a non-Clinical Concentration.g. The type of experience in a Clinical Practicum or place of employment should determine whether or not such experience is clinical, and not the actual agency setting where the work may or may not have been completed.We look forward to the Board’s response to our concerns.

 Miriam Raskin, PhD, Chair

Mary Kiernan-Stern, LCSW, Director, MSW Field Education Program

Department of Social work

George Mason University

mrakin@gmu.edu and mkierna1@gmu.edu

 

Diane M. Hodge, Chair

Deneen Evans, MSW, Director, MSW Field Education Program

Department of Social Work

Radford University

dmhodge@radford.edu and devans18@radford.edu