The National Association of Social Workers

The Office of Professional Regulation, in the Office of the Secretary of State, issued a policy clarification in mid-May on the rostering requirements for non-licensed practitioners. This clarification produced a number of concerns and questions among NASW-VT members and others which we have addressed with OPR.

Here is a summary and a short section of Frequently Asked Questions (FAQs). One key issue seems to revolve around whether what you are doing is psychotherapy, which is not actually defined in the law. Another key issue is whether your hours of supervision to date will count toward licensure if you have not been on the roster. In both cases, the OPR is urging all those who are working toward a license in social work to register for the roster, which costs $100. The thrust behind this effort is not punitive, but focuses on the need to protect consumers. OPR has recently posted a deadline for getting on the roster without penalty of September 1, 2008.

The Purpose of the Roster
The State of Vermont created the roster with two goals in mind. First, is to assure that those who are providing psychotherapy or in supervised practice toward licensure as clinical social workers comply with educational background and training disclosure requirements. Second, the requirement assures that the public is protected against unprofessional conduct through regulation by the state. Individuals who have completed their academic preparation, such as a Master of Social Work degree, and who have not yet qualified for a clinical social work license in Vermont are permitted to practice while they prepare for licensure if they are on the roster.
If you have questions not answered by this summary, please contact Dianne LaFaille at OPR at 802-828-2390 or dlafaill@sec.vt.state.us or call the Chapter office at (toll-free) 888-260-7398.
To find details and appropriate forms for registering for the roster, go to http://vtprofessionals.org/opr1/social_workers/ and look at the lower right corner.

Policy Regarding Entry on the Roster of Nonlicensed and Nonceritified Psychotherapists

Vermont Statutes define a �psychotherapist who is nonlicensed and noncertified� to mean �...a person who practices psychotherapy and is neither a licensed psychologist, clinical social worker or mental health counselor, nor a certified marriage and family therapist or a psychoanalyst.� 26 V.S.A. � 4082(3). � 4083 of title 26 provides: �Prohibitions; penalties (a) No person shall practice psychotherapy unless the person is entered on the roster of psychotherapists who are nonlicensed and noncertified.�

The policy of the Office of Professional Regulation interprets the statutes to require that persons practicing psychotherapy, including persons in Vermont engaged in supervised practice toward licensure as social workers, clinical mental health counselors, and marriage and family therapists must be entered on the roster.

May 12, 2008 /s/

Christopher D. Winter, Director

Office of Professional Regulation

QUESTIONS	ANSWERS
1. If I have been working toward licensure as an LICSW but have not been on the roster, will the supervision hours I have accumulated toward licensure be lost?	No. But you should get on the roster BY September 1, 2008 to ensure no penalty is applied.
2. If I am employed by AHS do I have to be on the roster?	No, not if you are a direct employee.
3. I have an individual services contract with AHS do provide services. Do I have to be on the roster?	No. If you have an individual services contract directly with AHS you are exempt from the roster requirement.
4. I am employee of an agency that has a contract with AHS to provide services. Do I have to be on the roster?	Yes.
5. I have an individual services contract with a mental health agency that holds a contract with AHS? Do I have to be rostered?	Yes.
6. If I do not consider my work �psychotherapy,� do I have to be on the roster while I am working toward licensure?	If you are working toward licensure, you are advised to be on the roster. Vermont has only one level of licensure for professional social workers, which is a clinical license (other states have several types of licenses for social workers, including but not limited to clinical licenses).