Board of Registration of Social Workers Policy

Enacted July 18, 2006

POLICY BULLETIN REGARDING ITS INTERPRETATION OF THE PHRASE "ELIGIBLE FOR LICENSURE" AS USED IN THE BOARD'S REGULATIONS ADDRESSING THE SCOPE OF PROFESSIONAL PRACTICE OF SUPERVISION PROVIDED TO LICENSED CERTIFIED SOCIAL WORKERS FOUND AT 258 CMR 12.02(5), LICENSED SOCIAL WORKERS FOUND AT 258 CMR 12.03(1), 258 CMR 12.03(2) AND 258 CMR 12.03(3), AND LICENSED SOCIAL WORK ASSOCIATES FOUND AT 258 CMR 12.04

The Board of Registration of Social Workers voted today to adopt the following policy guidelines and interpretation of its regulations as identified above.

Policy No. 06-05

Purpose:

To provide guidance to licensed certified social workers, licensed social workers, and licensed social work associates regarding who may provide supervision to them, and to provide guidance to licensed clinical social workers, licensed certified social workers and licensed social workers regarding who they may supervise.

Policy:

The Board of Registration of Social Workers requires in its regulations that licensed certified social workers, licensed social workers and licensed social work associates may provide certain services within the scope of their professional practice as long as they do so under the clinical supervision, supervision or administrative supervision, as the case may be, of a licensed independent clinical social worker, a licensed certified social worker, or licensed social workers. It is also possible under the Board's regulations to provide certain specified supervision if the social worker providing the supervision eligible for licensure as a licensed independent clinical social worker, a licensed certified social worker, or a licensed social worker.

The Board has interpreted the phrase "eligible for licensure" to mean an individual who has applied for and has been approved by the Board, having met specified education and experience requirements, to take the examination for licensure at either the licensed independent clinical social worker, licensed certified social worker, or licensed social worker level, but either has not yet taken or has taken and not yet received the results of that examination.

Because the Board had not previously provided its interpretation of that phrase, and because as a result certain applicants for licensure were supervised by persons who were not "eligible for licensure" as the Board has defined that phrase in this policy, and to avoid imposing any unnecessary hardship on persons who were supervised by persons who were not eligible for licensure, the Board has decided that its interpretation of "eligible for licensure" will take effect on August 1, 2006. Any applicant for licensure supervised by a

person who was not appropriately licensed to provide that supervision as required by the regulations at 258 CMR 12.00 will have their application reviewed on a case by case basis. In reviewing those applications, the Board will make a determination whether the supervisor would have been "eligible for licensure" at the level necessary to provide supervision had they submitted an application for licensure at that level.

Discussion:

Under G.L. c. 13, §84, the Board is authorized to "examine and pass upon applicants for license to practice social work in the commonwealth." In addition, under the same provision, the Board has the power to" promulgate rules and regulations." The Board has promulgated regulations at 258 CMR 12.00 relating to the limitations on the scope of professional practice imposed on certain levels of licensees. In so doing, the Board has stated in its regulations that supervision of various types, clinical, administrative or general, may only be performed by individuals possessing certain levels of social work licensure or who were eligible for that level of licensure. The Board did not, however, define specifically what was meant by the phrase "eligible for licensure" The Board's intention, by this policy, is to provide its interpretation of that phrase for application on a prospective basis, and to address problems raised by applicants who may have received supervision from someone who was not qualified to provide that supervision under the Board's interpretation of the phrase "eligible for licensure."