Virginia Commonwealth University School of Social Work endorses the recommendation submitted by the NASW Virginia Chapter with regard to the educational requirements for a licensed clinical social worker.  Specifically, that the existing complete regulations in 18VAC140-20-49. A-B be replaced with the following:

A. An applicant for licensure as a clinical social worker shall hold a master's degree in social work with a clinical course of study, as defined in 18VAC140-20-10. B, from a social work program accredited by the Council on Social Work Education; or if educated outside the United States or its territories, has completed an education program deemed equivalent by the Council.

B. An applicant with a master's degree in social work with a non-clinical course of study may satisfy the clinical education requirement by returning to a master's degree program accredited by the Council on Social Work Education in order to complete the clinical course of study educational requirements.

We agree with the rationale stated by NASW Virginia Chapter for this proposed change and further add our request that the Board defer to the national accrediting body in social work education, the Council on Social Work Education, as the body that determines the appropriate content and structure necessary for an advanced clinical practice curriculum.  We believe the Council is in the best position, through its rigorous educational policy development process that includes both faculty members and practitioners, to determine the most adequate educational preparation for advanced clinical social work practitioners. We also believe that the proposed change noted above is wholly sufficient for ensuring the safety of the public at large and the educational formation needed for those seeking licensure.