Adele Natter & Margot Aronson, DC Legislation and Advocacy Co-Chairs
Although the new DC social work licensing period began on August 1st, because of the ongoing COVID pandemic, we still have a lot to think about from the last renewal, including last minute additions to the requirements. We’re also keeping an eye on which regulations have changed and which will be continued through July 31, 2023.
The DC Board of Social Work expects to send out an announcement to all DC social work licensees clarifying final decisions on policies and requirements soon. Meanwhile, we’ve outlined here some highlights for you, with information as of our newsletter deadline:
CE Requirements - both for our last renewal and going forward
A total of 40 CEs are required in the two-year licensing period. Given pandemic conditions, the Board has decided that none need to be live face-to-face through the 2023 renewal.
Do be sure you have all your CEs for 2019-2021 ready to provide the Board in case you are audited. If you realize you are missing something, get it NOW! The penalty will be significantly lighter with your apology for lateness, than it will be if you cannot provide more than, say, 39 CEs, or no Public Health CEs.
Unexpected But Required: post-renewal period CEs due Sept 30
This year in mid-July, as most of us were busy checking and double-checking to see that we had all our CE ducks in a row, the Health Department issued a new requirement. All health workers would need 2 Covid vaccine-related CEs, and they would need to be completed by Sept. 30.
Finding appropriate trainings was a challenge, but not impossible. These two CEs are to be added to your file of CEs for the 2021-2023 renewal, and can be counted toward the Public Health requirement.
Auditing of these two CEs will take place soon. If you haven’t already earned them, get to it right away! Our understanding is that if you are late but can show that you’ve earned them, you will have a fine to pay. If you haven’t earned them when you are audited, you will not be able to practice for a period of time, and pay a more significant fine.
Vaccine Requirement
The same memo that each health licensee received in mid-July also set forth a requirement for all health workers (that includes us) to attest to having been vaccinated, or have a medical or religious exemption on file with the Health Department by September 30th. The attestation or exemption was to be filed on line on the DC Board of Social Work website.
Again, auditing of the vaccine or exemption will take place shortly. If you have not already filed online, do so ASAP, as failure to do so is likely to reap professional consequences.
Telehealth: With video? Audio-only? For supervision? For insurance reimbursement?
To the question of video and audio-only: Telehealth is permitted in DC, with no end date currently. This applies to therapy using video as well as audio-only. This means that DC licensees may practice with clients located in the District using telehealth. As for any clients NOT physically located in the District during your session, you must first check the requirements of the state in which the specific client resides.
Re: Supervision. Supervision can also be conducted virtually, and we anticipate this will continue through the 2021-2023 renewal.
As for insurance coverage, this is not a matter controlled by the Board of Social Work. There is proposed legislation for continuing telehealth coverage circulating at the national level at present, and the US Department of Health and Human Services is considering how to handle telehealth reimbursement for Medicare and Medicaid after the pandemic. As these efforts progress (or fail to progress), we may want to advocate for continued coverage with our District Council’s Health and Human Services Committee and with our Office of the Insurance Commissioner. At present, however, we can only advise that you check with the particular insurance carrier as to whether telehealth sessions will be covered under your client’s insurance.
Supervised Practice Letter
The Board is creating - and clarification is pending - on a policy allowing new MSWs to practice social work under supervision between graduation and sitting for the ASWB exam. This has been a particularly difficult issue during the pandemic, as the wait time can be a number of months. Without the anticipated go-ahead from the Board, unlicensed MSWs cannot perform work in the social work scope of practice without being liable for fines, even if supervised, and indeed, their supervisors, too, would be liable.
The COVID Waiver Expires for Out-of-Jurisdiction Licensees
Social workers with a state license in good standing have been able to practice telehealth under the COVID waiver even though not licensed in DC. The waiver expired on October 31, following lots of warning and information about how to move forward. If you are unlicensed in DC now, you may no longer practice in DC, and yes, that means telehealth. Stop practicing ASAP if you have been doing so without a DC license since Oct 31. Submit an application for a DC license, show that you are licensed in good standing in another state, and complete the criminal background check. 48 hours after a clean background check, a 90-day temporary license will be issued.
Questions or requests for help or clarification should go to dcbosw@dc.gov.
Additional details can be found on the Board website,
https://dchealth.dc.gov/service/social-work-licensing
The next meeting of the DC Board of Social Work will be January 24, beginning at 10 AM. See the Agenda section on the Board’s website for more information about the meeting.
We hope this is helpful, and we look forward to considering other issues of importance to clinical social workers in DC in the near future! Meantime, happy holidays to you.
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