The Board of Registration of Social Workers ("the Board") voted at its meeting on January 25, 2011 to adopt the following Policy Guideline. This policy guideline is intended as a recommended protocol for the profession to follow. The guideline set forth below does not have the full force and effect of law, as would a Massachusetts General Law or a Board rule or regulation. However, the Board uses policy guidelines as an internal management tool in formulating decisions that relate to issues in the practice of social work.

Policy No. 11-01

Purpose :

Pursuant to MGL c. 112 §131 "[a]ny individual desiring to obtain a license as an independent clinical social worker … shall furnish evidence satisfactory to the board that he is licensed under this section as a certified social worker; has had three years of full-time experience in the field of clinical social work, or the equivalent in part-time experience which is acceptable to the board, at least two of which are subsequent to receiving the master's degree in social work …"(emphasis added)

258 CMR 9.03 (3) further states that an applicant for licensure as a LICSW must, among other requirements, provide the Board with "[s]atisfactory written or electronic documentation that he or she has provided at least 3500 hours of clinical social work services in accordance with the requirements of 258 CMR 12.02(1) or 258 CMR 12.02(2) over a period of not less than two years from the date on which he or she received the graduate degree in social work required by 258 CMR 9.03(1)" (emphasis added)

The purpose of this policy statement is to provide guidance and/or clarification to applicants for licensure as LICSWs regarding the experience requirement for licensure as a LICSW.

Policy :

Applicants for licensure as LICSWs must provide satisfactory documentation to the Board that the 3500 hours of experience in clinical social work services as an LCSW required of 258 CMR 9.03 (3) was obtained over a period of not less than two years after becoming licensed as a LCSW and/or in compliance with the exemptions detailed in 256 CMR 9.02 (1) ). This policy shall be in effect for all applicants for licensure as a LICSW who have graduated from their MSW program after August 31, 2011.

Discussion :

1. It has come to the attention of the Board that there has been some confusion among applicants for licensure as LICSWs regarding the experience necessary to comply with the requirements for licensure. Specifically, the Board noticed that there were individuals who applied for licensure as LICSWs who submitted documentation to the Board that they provided clinical social work services, as described in the scope of practice of an LCSW, without first obtaining an LCSW license or without falling into the exemption clauses.

2. Such experience obtained without an LCSW disqualifies the experience, as it is not in compliance with 258 CMR 9.03 (3) . In order to qualify for the LICSW, clinical social work services may only be performed in accordance with these requirements, by an LCSW as reflected in 258 CMR 12.00. Such services may also be performed by other licensed individuals specifically authorized to do so by law and/or individuals exempt from licensure under 256 CMR 9.02.

3. As such, the practice of clinical social work without the requisite license and/or legal authority to provide such services shall constitute unlicensed practice in violation of M.G.L. c. 112 § 133.

4. Therefore, the Board will not issue LICSW licenses to applicants who submit documentation of unlicensed clinical social work services to meet the experience requirement for licensure as LICSWs.