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Proposed Change to DC Social Work Licensing Law
The following change to the District of Columbia Social Work licensing law has
been proposed by the DC Board of Social Work:
Amend paragraph (b) to read as follows:
A licensed independent social worker (“L.I.S.W.”) may perform any function described as the practice of social work in this chapter (including diagnosis and treatment of psychosocial problems) in an autonomous, self-regulated fashion, in an agency setting or independently, and may direct other persons in the performance of these functions subject to the limitation that the practice of psychotherapy, performed solely by the licensed independent social worker, shall be under the supervision of a licensed independent clinical social worker licensed in #3-1208.04.
GWSCSW reacts to the proposal
The proposed amendment was published in the DC Register this fall and included,
with the proposed changes to the licensing laws of other health professions in
the District, in an omnibus bill (Bill #16-772) titled the Health Occupations
Revision Act of 1985 Amendment Act of 2006.
GWSCSW members were alerted to the proposed change in late October, on the
GWSCSW listserve, and on-line questions and discussion ensued. The DC
Legislative Committee also consulted with members of the Maryland, Virginia, and
DC social work boards, and with Laura Groshong, legislative consultant to the
Clinical Social Work Association.
At a public hearing on November 13, called by the Councilman David Catania’s
Committee on Health, GWSCSW testified in opposition to the proposed change.
Margot Aronson and Larry Goldes represented GWSCSW. Joyce Higashi, executive
director of the NASW DC-Metro chapter, also testified in opposition to the
proposed amendment.
The Society will keep members informed about the outcome through the GWSCSW
listserve.
The testimony presented to the District of Columbia Council’s Committee on
Health by GWSCSW follows.
Testimony before the DC Council Committee on Health
The Greater Washington Society for Clinical Social Work (GWSCSW) opposes the
amendment to the social work licensing law proposed in the Health Occupations
Revision Act of 1985 Amendment Act of 2006.
The proposed amendment:
- Puts the public at risk by allowing unqualified social workers to diagnose and treat mental health clients.
- Disregards the training required to be able to diagnose and treat mental health clients.
- Mistakenly makes comparable two levels of social work licensing that are very different.
- Is being put forth without having been vetted in the social work community.
GWSCSW represents more than 500 licensed clinical
social workers practicing in mental health clinics, family service agencies,
psychiatric hospitals, medical facilities, and private practice in the
metropolitan area. GWSCSW is an affiliate of the national Clinical Social Work
Association.
Our Society has great respect for the Board of Social Work; we recognize the
Herculean job the members of the Board perform in our behalf. We have no doubt
that the amendment at issue has been proposed in good faith.
At the same time, we fear that the proposed change, which would result in a
dramatic expansion of the Licensed Independent Social Worker (LISW) scope of
practice, puts the public at risk of diagnosis and treatment by well-intended
but unqualified social workers.
It is useful to keep in mind that there are three Master’s level categories of
licensed social workers in the District. They are:
-
Licensed Graduate Social Worker (LGSW), who operates
under supervision;
-
Licensed Independent Social Worker (LISW), who may
operate independently, with the exception of diagnosis or treatment (including
psychotherapy) of psychosocial problems; and
- Licensed Independent Clinical Social Worker (LICSW), whose scope of independent practice includes diagnosis and treatment of psychosocial problems (including psychotherapy) and the supervision of LGSWs doing psychotherapy.
LICSWs practice diagnosis and psychotherapy, but
only after having, in the words of the law, “satisfactorily completed the
examination process at the independent clinical level, and [having] at least
3,000 hours of post-master's or postdoctoral experience participating in the
diagnosis and treatment of individuals, families, and groups with psychosocial
problems, under the supervision of a licensed independent clinical social worker
over a period of not less than 2 years or more than 4 years.”
The proposed change in the law would authorize the LISW to
-
“perform any function described as the practice of
social work…(including diagnosis and treatment of psychosocial problems) in an
autonomous, self-regulated fashion, in an agency setting or independently, and
may direct other persons in the performance of these functions…
- “subject to the limitation that the practice of psychotherapy, performed solely by the licensed independent social worker, shall be under the supervision of a licensed independent clinical social worker….”
It has been argued that as the current law permits
an LGSW to practice psychotherapy under the supervision of an LICSW, the same
privilege should also apply to an LISW. There are two flaws in that argument.
First, the proposed amendment goes much further, authorizing LISWs to diagnose
and treat clients without any supervision by an LICSW, so long as any
“psychotherapy” is practiced under such supervision.
The second flaw is that the circumstances of the LGSW and the LISW are
different: the LGSW is widely recognized as a beginner, whereas the LISW carries
autonomous authority. This raises a potential issue of consumer protection:
individuals seeking treatment from an LISW would likely be misled about the
licensee’s clinical qualifications.
It has also been argued that there are not enough licensed clinical social
workers to treat the critical mental health needs of the District’s citizens.
Yet surely this problem is not solved by lowering the qualifications for
clinical practice.
The requirements for the privilege of making diagnoses must continue to be
rigorous, as the stakes are so high. Diagnosis directs treatment; diagnosis is
used to determine level and kind of services; diagnosis is relied upon in court
proceedings; diagnosis makes a permanent record, forever following the client in
employment records and permanent insurance files. LGSWs are not authorized to
diagnose, and LISWs ought not to be granted such authority without being
clinically qualified.
We feel strongly that it is premature to make statutory changes before there has
been discussion involving the social work community. We must define the problem
to be solved, and find a remedy that has, at its core, the safety and welfare of
our citizens.
Our Greater Washington Society for Clinical Social Work - and the National
Association of Social Work joining us here in opposition to the proposed
amendment - offer our assistance to the Council Committee and to the Board in
the review of problems of the current legislation and the crafting of a clear
and responsive legislative solution.
Diana Seasonwein, President
Larry Goldes, Chair, DC Committee
Margot Aronson, Chair, Legislation and Advocacy Committee.
For GSCSW Legislative
Information contact:
GWSCSW
5028 Wisconsin Avenue NW, Suite 404
Washington DC 20016
Phone 202 537 0007
Fax 202 364-0435
Email GWSCSW@gmail.com
Website http://www.gwscsw.org