I am a licensed clinical social worker and resident of Richmond, Virginia. I am writing to you to encourage caution, care and curiosity when considering HB 326 (Glass) which seeks to authorize Virginia to become a signatory to the Social Work Licensure Compact. The Social Work Licensure Compact is shortsided legislation that appears sound on the surface however it is deeply flawed. The Social Work Compact as it is written infringes on states’ rights, does not account for fiscal implications, and fails to provide guidance on the oversight, maintenance or regulation of compact licensure. Yes, it is critical that we find ways to address the behavioral health workforce crisis however the Compact has the potential to impact insurance reimbursement, social work wages, and push Virginias out of the job market market. Two helpful scenarios to examine the holes in the Compact are: If a social worker resides in a state outside of Virginia that is a signatory of the Compact providing services to a resident of Virginia that are in violation of the state laws and regulations where does jurisdiction fall? Which state and regulatory board is responsible for handling this violation and sanctioning the social worker that resides out of state who violated Virginia state laws and regulations? As written, the Compact does not provide guidance. State regulatory boards, like the Virginia Board of Social Work, are already understaffed and under-resourced. With an increase in licensed practitioners that reside outside of the state providing services in Virginia, what budgetary implications are not considered in terms of staffing and time that will become necessary in order to monitor, maintain, and provide oversight for compact licensure? As written, the Compact does not provide guidance. There is a reason that 26 states have not introduced legislation to sign on to the Compact there are more questions than the Compact has answered. Other states are proceeding with caution and calling on the Compact to undergo revisions that reflect these and other deeply valid concerns. I urge you to proceed with great caution in considering support for HB 326. We do not have enough information and do not trust that this Compact will not harm Virginians across the Commonwealth.

Please vote yes to support HB326 for Virginia to become a signatory to the Social Work Compact. As a LCSW, this Compact will allow me to practice with clients outside of Virginia. Especially with the enormous growth in virtual therapy, this will significantly increase access to mental health care to residents of all of the states in the compact.

Comments Document

Pyramid Healthcare, Inc. urges you to adopt HB 326 to have Virginia join the Interstate Social Work Licensure Compact. We are an integrated behavioral healthcare system serving Medicaid and commercial clients in 9 states across a continuum of residential and outpatient substance abuse, mental health, autism, and eating disorder treatment services. We employ 3,100 team members across our 80+ active facilities. Our Newport News facility has operated since July 2021 and offers 150 withdrawal management/detox and residential treatment beds for adults. We also offer structured outpatient treatment for adults with substance use and co-occurring disorders. Our New River Valley facility opened in August 2023 and offers residential and partial hospitalization programming for adults throughout the New River Valley. We will soon begin the construction of a 100 bed residential detoxification and rehabilitation treatment facility in King George County. Virginia has already recognized the value of interstate licensure compacts, having previously adopted compacts for audiology and speech-language pathologists, counselors, EMS personnel, nurses, occupational therapists, psychologists, and physical therapists. Missouri has already adopted the Social Work Compact and legislation is currently pending in 23 other states. The Compact is supported by the Council of State Governments, the Department of Defense, and the Association of Social Work Boards, as well as numerous other organizations who helped develop the SW Compact. The Compact is an interstate occupational licensure compact that allows social workers with bachelor’s degrees, master’s degrees, and clinical licenses to provide services to clients in all other Compact states instead of having to file duplicate license applications in each state in which they practice. Each Compact state extends licensure reciprocity to the other states in the Compact. In order to be eligible, a social worker must first already be eligible for or hold a social work license in their primary state of residence and meet other criteria. After the social worker’s eligibility is determined, they receive a multistate license and may begin working in any Compact member state. There are over 500,000 licensed social workers across the country and we employ many social workers across our counseling, operations, clinical, quality, compliance, and utilization review teams, among other functions. The Compact will streamline the licensing process while reducing administrative burden and allowing social workers to quickly resume providing care. It does so while protecting patient and public safety. Joining the Compact will facilitate multistate practice and reduce the barriers to license portability for our current and potential employees by easing mobility across state lines, expanding employment opportunities to address crucial workforce shortages, allowing continuity of care for our patients that move across state lines, allows the use of telehealth to be leveraged, and supports the relocation of military spouses and their families. Given Virginia’s unique geographic location, bordering NC, TN, KY, WV, MD, and DC –as well as the presence of major military installations where members of the military and their families are frequently relocated into and out of the region, the Compact will positively impact the state’s ability to attract and retain qualified and desperately needed social workers.