Public Comments for Events Organized by the FTC's Economic Liberty Task Force #00008

Submission Number:
Mary Jo Monahan
Association of Social Work Boards
Initiative Name:
Public Comments for Events Organized by the FTC's Economic Liberty Task Force
The Association of Social Work Boards (ASWB) is the nonprofit organization composed of the social work regulatory boards of all 50 U.S. states, the District of Columbia, the U.S. Virgin Islands, Guam, Northern Mariana Islands, and all 10 Canadian provinces. These boards are responsible for ensuring that clients are protected through regulation, which includes setting standards for social workers to enter practice, issuing licenses, and enforcing practice standards. Social workers practice in hospitals, state and local governments, clinics, correctional facilities, schools, military bases, and in other settings that serve some of the most vulnerable populations. Clients must be assured of safe, competent social work services whether delivered via technology or in person. Social work licensure assures the public that the professionals who provide care or assistance are competent to practice within state boundaries and will interact with clients in an ethical and safe manner. Licensing boards serve the public and practitioners for the purpose of ensuring a competent, ethical, and safe workforce. The boards take this public protection mission seriously by providing recourse to clients if a social worker steps outside the bounds of ethical and safe practice. ASWB applauds the efforts of the FTC as it looks at this complex issue. As the FTC has noted, regulation can seem onerous for some occupations; however, for health care-related professions-including social work-it is a necessity. Currently, social work licensure laws differ dramatically in the U.S. This inconsistency poses significant legislative, regulatory, and administrative barriers to social workers providing services to clients in multiple states or when moving between states. ASWB has been working strategically toward consistency and streamlining licensure processes since 2013. Please see the Mobility Timeline attachment as well as our website dedicated to practice mobility at ASWB members have extensively researched mobility solutions used in other countries and other professions. ASWB's mobility plan will be presented for adoption at the 2017 Delegate Assembly in November. The cornerstone of the plan is ASWB's Model Social Work Practice Act (see attachment). The model act establishes standards of minimal social work competence, methods of fairly and objectively addressing consumer complaints, and means of removing incompetent and/or unethical practitioners from practice. The public is well-served by the implementation of the model act in the laws of individual states. It promotes greater consistency of terminology and regulation across states, resulting in: - increased public understanding of social work, which increases public protection - increased mobility for qualified social workers, which increases access to vital mental health practitioners and services-especially in states that struggle with workforce shortages - increased consistency in legal decisions related to licensure, renewal, discipline and other board activities Mobility is an important workforce issue for social workers licensed in the United States. By using substantially similar terminology and regulation, most states can expedite the licensure process for social workers who meet all criteria for licensure. As the FTC reviews occupational licensing, please take into consideration the fact that one solution will not fit all professions. Mary Jo Monahan, MSW, LCSW ASWB Chief Executive Officer