The NSCSW continues with its efforts to create a framework for the regulation of clinical social practice.
Following a resolution adopted by the NSCSW membership on May 12, 2022, the NSCSW is committed to further developing policy and standards towards clinical regulation to ensure the public is protected and that clinical social work is strengthened.
The NSCSW is taking a phased approach to the implementation of clinical regulation. The focus during phase one will be on using the NSCSW’s existing legislative framework to bring in clinical regulation related to private practice. It is important to note that phase 1 does not include the implementation of title protection for Registered Clinical Social Worker or the provision of diagnosing. It does include provisions to define the scope of clinical practice more clearly, define the knowledge and competencies required to specialize in clinical practice, and draft new standards of practice specific to clinical social work.
We invite all members, partners and collaborators and the public to review our draft documentation in its current stage of development.
We look forward to hearing your feedback:
- There are consultations scheduled for key stakeholder groups, which you can find listed here.
- You may leave comments on this post below
- NSCSW members and community organizations can reach out directly to Alec Stratford (alec.stratford@nscsw.org) to set up a time for one-on-one consultation
Background: The evolution of clinical social work practice in Nova Scotia
A private practice committee was formed in June 2017 to address issues with the NSCSW private practice by-laws. They recommended at the 2019 AGM that current entry-to-practice requirements including an accredited social work degree and declaration of adherence to Standards of Practice were sufficient, and proposed deregulating private practice while regulating clinical practice.
In January 2021, the NSCSW released a major paper recommending regulation of clinical social work to strengthen the provision of bio-psycho-social models of mental health services in Nova Scotia.
The Clinical Committee was formed, and NSCSW Council gave them the the objectives of developing a proposal for the regulation of clinical social work that provided a scope of practice for clinical social work, and developing regulations, rationale, recommendations and policy regarding successful regulation.
The Clinical Committee proposed changes include:
- deregulating private practice
- seeking amendments to Social Worker Act to update scope of practice
- restricting clinical social work through regulations
- protecting title of Registered Clinical Social Worker
- introducing new Standards of Practice for clinical social work
NSCSW members accepted the proposal to further develop policy for the regulation of clinical social work on May 12, 2022 at the NSCSW’s AGM
Council is committed to creating a framework for the regulation of clinical social practice and pursuing legislative changes to the Social Workers Act to protect the public and strengthen clinical social work.
NSCSW is pursuing a phased approach of working towards clinical regulation:
- Phase 1 is currently focusing on developing criteria and standards of practice via the existing legislative framework to regulate clinical social work for those working in private practice.
- Phase 2 will include evaluating the current performance of the Integrated Governance Model in preparation for a request to government to amend the Social Workers Act.
- Phase 3 will assess the willingness of ministerial representatives to open/revise the Social Workers Act for revisions, involving consultation with relevant stakeholders such as Black/Indigenous practitioners, private practitioners, members of public representing marginalized groups, employers, professions/occupations providing similar services.
I feel that the eligibility criteria to be able to set up a private practice is extreme. The implementation of assessments is not inclusive to private practitioners who are challenged by mental illness and disability affecting their ability to undergo assessments. Furthermore, if an individual completes an MSW, they should not be required to prove that they are worthy of private practice status. If their institution is approved by the NSCSW, there should be trust that they learned how to be a competent clinical social worker in that program. I love the idea of a mentor for the clinical social worker; however, this should not be a requirement prior to establishing a private practice; it should be an offering and requirement in order to remain in private practice. For example: the social worker must participate in x amount of mentor hours per month in order to maintain their private practice status. Making it harder for practitioners to set up a private practice will have negative implications. The major implication being that there will be a shortage of practitioners in comparison to the clients that require therapeutic intervention.
For those already doing clinical social work ie: NSHA Mental Health and Addictions; and those who have either the title Healthcare Social Worker, Social Worker, or Clinical Therapist (as their jobs are to do the exact same thing, provide clinical therapy), will this title / designation be grandfathered in? Can you comment on this process for those already doing this work?
Health Professions Regulatory Bodies exist to protect the public’s interest by ensuring that health and social care practitioners adhere to a set of standards and ethical guidelines. This is done to ensure that clients receive safe and effective care from qualified professionals. It is our belief that access to health and social care services is a basic human right. However, when it comes to healthcare, access must come with appropriate levels of safety and quality assurance. Health Professions Regulatory Bodies play an important role in protecting the public’s interest by setting high standards for healthcare professionals and ensuring that these standards are adhered to.
I agree that Post-secondary educational institutions have rigorous assessment processes in place to ensure that the highest standards of education are maintained. These assessments typically include ongoing evaluation of student performance. This allows the institution to assess a student’s knowledge and identify any areas where they need further guidance or instruction. These new draft policies focus more heavily on what was achieved in education. However, not all Master’s Degrees in Social Work (MSW) focus on a clinical scope. While some MSW degrees may emphasize more general social work practices, others are more focused on a mental health-oriented specialty, such as strategic family therapy. The draft policies sets criteria for having 12 academic credits that align with clinical social work and provide an opportunity for applicants to demonstrate a substantial equivalency to these academic credits
When it comes to the public interest and client safety, clinical supervision is essential. Supervision ensures that all standards and ethics in place are being followed, providing clients with a secure environment where they know their best interests are being looked out for. Supervision can also help identify potential issues or risks quickly, allowing for swift action to be taken when needed.
The new policy allows for applicants seeking to practice privately to receive private practice approval while they complete the necessary supervision requirements. This is intended to ensure that, even before full licensure, these individuals are providing quality services to their clients with appropriate oversight from their supervisors.
Happy to discuss further if you would like to set up a phone call
Jenn Horne
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The requirements feel extreme in comparison to other provinces. The only exception to this being Alberta, where the clinical registry is voluntary and not required for clinical practice. Even with all of the issues and concerns with standardized testing, even the ABSW sounds better than this.
This feels like continued private practice regulation under a different name. Let’s face it most individuals going into private practice are doing so in a clinical capacity. It seems this is simply creating an environment whereby our social workers are going to continue going into private practice in other provinces (either moving or due to the virtual workplace landscape), and thereby more NS clients are being forced to see professionals who do not offer the benefits that the social work lens provides.
Also, are those who are in public positions in clinical therapist/social worker roles also being grandparented in? Otherwise, this feels very unfair and based on assumptions about a lack of capacity or experience to do this work simply because they have not already gone through the private practice application process. How can one say that an individual who has been working in a clinical capacity in a public institution with the same education is less qualified than one who has been in private practice? Both should be grandparented in or neither. Also, what happens if someone is in a clinical role in NSHA or IWK and then has to apply to NSCSW for the clinical designation? Does this put their employment in jeopardy during the application process?
Looking forward to continued conversations on this topic. I greatly appreciate the time and work of the committee to date.
Hi Jen,
it’s important to note that Phase 1 of clinical regulation is focused on private practice. Should the NSCSW gain momentum for legislative change, then the conversation would begin around grandparenting in the public sector. Find more details on the phased approach here https://nscsw.org/clinical-regulation-project-plan/
In terms of this being extreme. Decisions by the NSCSW council and members must be made in the public interest, with a clear focus on public safety. Without regulation, the burden is on the public to ensure their safety when engaging in services provided by a clinical specialized in private practice. A lack of regulation can have serious consequences on the health and well-being of both the social workers and the service user. Without proper regulation and oversight, there is no way for the public to know if they are receiving quality care or not. A lack of regulation in this area would put individuals at risk from someone who may lack the qualifications and/or experience necessary to provide clinical services. Also its important to note that all most jurisdictions in Canada are moving in this direction. To ensure public safety, we must maintain and build regulations and bylaws regarding clinical regulations and generally these include requirements for entry-to-practice, such as a Masters’s degree in Social Work or equivalent, demonstrated course work that aligns with the scope of clinical practice, and a defined period of supervision before entering into private practice, as a minimal standard. Ideally, regulations would create greater safety for both individuals seeking clinical services and those providing them – enabling people to make informed decisions about their healthcare and protecting providers from potential liability issues.
The goal of this new process is to place greater emphasis on education and provide a clearer pathway for social workers to engage in clinical practice in private settings. What is proposed here is aligned with public safety regulations on clinical practice in British Columbia, Alberta, and the United States regarding clinical regulation. Required coursework and supervision are standard here. What is different is we are proposing that we not rely on the ASWB exam, this decision was made because there is little evidence that the exam provides a valid assessment of competence, and the data on pass-fail rates released this summer point to major issues with racial discrimination. In lieu of the exam, careful attention has been placed on the supervision and assessment of core clinical skills and standards of practice to provide guidance and accountability. We hope that members agree that the assessment of skills and standards of practice is an effective way to ensure public safety while eliminating racial injustice facilitated by the exam.
Thank you for your response Alec. I did not realize the rest of the country was heading in this direction, and I also recognize that my response was a bit of a knee jerk reaction to the grandparenting for private and not public sector employees. Thank you for the clarification that this is not part of this phase but will be looked at in the future phase. I do appreciate the responsibility this puts on the college and fully agree that this is less restrictive than the current private practice regulations. I look forward to the meeting to discuss further. I am hoping the hours completed by an SWC who has a supervisor, in addition to their mentor, will count towards the 1800 hours. I believe this to be the case.
Social workers make amazing therapists and I know the College tries to find “right touch regulation” but my concern is that this is too much . We want young people to choose a Master’s in social work as their degree…but there are so many other options if they want to do therapy (such as being licensed with CCC, RCT, MOT, etc… ) We do not want to deter new private practice social workers by making this process too cumbersome.
Hi Jen, the process of Candidacy is very different from clinical supervision. Candidacy is rooted in nurturing and integrating the Code of Ethics and the Standards of Practice. Clinical Supervision is rooted in the assessment and development of clinical skills. The intent here is that they would remain separate. On average jurisdictions in North America with clinical registration require 3500 of supervised practice experience. The 1800 hours is in consideration of Candidacy hours. Also you this new policy would allow you to begin work in private practice while completing those hours.
Hi Pam, thanks for your comments, could you be more specific on what you see as extreme? Remembering that we must regulate in the public’s interest is important. When regulation doesn’t exist the burden of vetting a practitioner falls to the service user. Given our service users are all ready very vulnerable, placing that burden onto them seems to me like a social injustice.
Thanks Alec. I appreciate your response. I guess the difference is that while other professions may require 3500 hours of supervised practice, the practicioners are able to start that supervised clinical practice right away upon registration with their board/college and not after a candidacy period. This sounds different than
the plan here. Am I wrong in understanding that someone cannot engage in clinical practice until their candidacy period is finished? To be clear, I am in no way suggesting candidacy should not also occur as an entry to practice. I just do not understand why this cannot occur concurrently. If more supervised practice is required, can we increase the number of hours, rather than force someone into a non-clinical role until their candidacy is over, when clinical work is their area of experience and interest. Again, maybe I am reading it incorrectly. I see this as pushing more people who seek to work in clinical roles into counselling and other mental health professions and we instead want more social workers in this space. We are so very valuable here.
My concern is that many MSW programs do not provide adequate education that would prepare graduates to engage in private practice. Including one or two courses that are rarely taught by practitioners and are largely theoretical does not suffice. As well, these courses are sometimes electives vs core courses. An additional issue can be a very broad “anti medical” culture among some faculty that perhaps justifies a general lack of attention to clinical knowledge such as being unfamiliar with a variety of treatment models or believing that one brief therapy model applies to everyone for everything. Without specific education in how to conduct assessments, being familiar with a variety of mental health conditions, how to differentiate trauma etc., I think many social workers have graduated from programs that would not adequately prepare them to meet the proposed requirements for private practice. My overall concern is that we are beginning or will begin to see the demise of social work if we are not graduating students with more skills than theory. UNB Saint John campus has begun a degree program for “Allied Health professional” and I believe NB provincial government is looking at these future graduates as social workers. On the other hand, CBU’s new social work program appears to have some excellent courses that would put their grads as practice ready. Perhaps we need to have specific streams within social work schools such as policy, social justice/ community action and a stream with clinical skills taught by a variety of actual practitioners vs academics.