The proposed guidelines appear to be designed to help emphasize the professional social worker’s need for clinical coursework as a component of their professional education and training.  I support the concept and understand the need for over sight and direction of this.  However, the issue I take regards the lack of options or direction in these guidelines to social workers who are deemed as not meeting these requirements, despite their MSW program and experience.

Accredited MSW programs receive strict oversight and expectations in preparing masters level social workers for practice.  Coursework and field experience are a requirement and consistent according to the Council on Social Work Education.  The proposed guidelines do not appear to take this under consideration and the current practice of turning down the initial registration of licensure supervision based on the type of MSW program the applicant pursued is likely to have profound impact on many social workers who would pursue their clinical licensure in the Commonwealth.  More and more agencies and licensing agencies are requiring individuals and facilities to insure licensure oversight of staff and programs generating an increase in the need for clinical licensure.  Oversight of appropriate training and academics is necessary, but should not be designed with the unintended consequence of delaying that process beyond the 2 year minimum of required licensure supervision.

I would suggest the following:

That the Board allow an applicant to provide professional clinical experience to be combined with their MSW program to be considered in lieu of specific clinical coursework.  Specific guidelines could be developed to address the criteria to be met similar to the requiered CEU's for licensure and;

That when the applicant is registering for their initial clinical supervision, the board would notify the applicant of lacking clinical coursework, but allow the supervision to begin with the understanding that all requirements must be met prior to sitting for licensure exam.  In this way, MSW’s will not be penalized for programs that don’t require clinical coursework, but have the option to pursue the needed coursework, while in their clinical position, under the direction of their clinical supervisor.  This also insures that the Board’s expectations and standards are met.