Virginia Regulatory Town Hall
Department of Health Professions
Board of Social Work
Regulations Governing the Practice of Social Work [18 VAC 140 ‑ 20]
Action Reduction in CE requirement for supervisors
Stage Fast-Track
Comment Period Ended on 7/24/2019
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7/12/19  8:14 pm
Commenter: Ellen Fink-Samnick EFS Supervision Strategies, LLC

Opposition to reduction in Supervision CE Requirements
I appreciate the opportunity to provide comments regarding the fast-traced regulation to promulgate regulations on the Supervision of a Social Worker, and the requirements for continuing education for Supervisors as recommended by the Virginia Board of Social Work, under the Department of Health Professions. Respectfully, I disagree with this regulation, and for the following reasons:

1. The current 14 hour CE requirement every 5 years is already less than many other states, many that have set the bar at 15, or even 40 hours of CEs. The current timeframe is barely enough to provide clinical supervisors the knowledge they need to ground effective, quality, and appropriate best practice (e.g. foundation of supervision models, application of the current regulations, opportunities for critical thinking discussions to assure full understanding of the content, strategies to assure attention to clinical social work competencies and mandatory responsibilities of the clinical supervisor, record keeping and documentation practices, plus other regulatory guidelines, and the implementation of individual and group supervision processes). Decreasing this necessary content to 12 hours, will not only limit the knowledge provided, but also grossly limit the rigor and high expectations associated with the clinical supervisor's role, and its evidence-based foundation. 
2. The requirement for CEs specific to supervision every 5 years is a necessity for the workforce. The mandatory update assures clinical supervisors are accountable to stay proficient with the fluid and emerging knowledge-base; an effort that ultimately informs and guides their supervision practices. Supervision is an essential and integral part of the training and continuing competencies required for the skillful development of professional social workers. Supervision protects clients, supports practitioners, and ensures that professional standards and quality services are delivered by competent social workers. Why should that be jeopardized?

Removing this particular continuing education update requirement is of paramount concern. Doing so will mean clinical supervisors will no longer have a mandate of professional accountability for their education on supervision best practices. There will be no accountability to industry and demographic shifts that influence how, where, and with whom social workers practice (e.g new population demographics as LGBTQ, legal and ethical use of technology platforms, new scopes of practice as integrated behavioral health, opioid addiction, increased focus on professional liability, new and rapidly expanding treatment interventions).
Removing the CE update requirement will return us to the times where new social workers were victim to supervisors who were uninformed of current best practice for supervisors, engaged in dated interventions, and at time possessed limited knowledge of how the new generation of supervisees learn. These dynamics would lead to ultimate exploitation by supervisors of those they are tasked to supervise. 

3. The fluid change of health and behavioral healthcare mandates clinical supervisors be kept abreast of these changes and how they directly impact supervision processes. Technology alone has greatly altered behavioral healthcare, but the impact to supervision alone has been massive. Social workers not mandated to obtain a 5 year update will have no incentive to keep informed of these industry changes. The Board will revise the regulations to meet the changing times with their best intent (e.g. adding the opportunities for virtual supervision), but supervisors will have no requirement to learn the necessary accompanying models to support these regulations.
Supervisees in social work are vulnerable, in that they don't know what they don't know. Being supervised by clinical supervisors who are not held to a minimum standard for their own learning, puts supervisees in social work, and all consumers of social work services at precarious and unnecessary risk.
4. The CE requirements set a minimum standard of practice expectation for didactic knowledge, theories, and skills that must be possessed by the clinical supervisor. This is a  distinct role from that of clinical social worker. Education to maintain the appropriate level of quality for the role must be obtained. Removing this requirement is antithetical to the requirement's original intent; of assuring a competent, professional, and highly trained clinical social work supervisory workforce. 
5. Changes to this CE requirement will diminish the value of social work compared to other disciplines; a professional standing social workers have fought to attain and must retain. The Board of Social Work greatly leveraged the role of clinical social workers and clinical social work supervisors in 2007 when the supervision regulations were initially instituted. This action spoke volumes to the professional nature of social work practice, especially compared to other professional disciplines (e.g. psychologists, licensed professional counselors, licensed marriage and family therapists)
Licensed clinical social workers continue to provide the majority of behavioral health services across the United States. They are equally held to the highest standards of practice through ongoing, continuing education requirements annually. Why should clinical supervisors be held to a lesser standard? I fear reducing the CE requirements, and removing the ongoing 5 year update requirement would compromise the quality of social workers in the Commonwealth, and the profession.   

Respectfully submitted, 

Ellen Fink-Samnick MSW, ACSW, LCSW, CCM, CRP

Principal, EFS Supervision Strategies, LLC

CommentID: 73526