Licensing Update

Clarification of Contact Hours for LCSW Experience

The following is the full statement from the State Education Department and the State Board for Social Work.

The State Education Department has been asked to clarify the requirements for supervised experience required for licensure as a Licensed Clinical Social Worker (LCSW) as specified in section 74.3 of the Commissioner's Regulations. In this regard, we are supplying this memorandum which offers general guidance. However, in specific circumstances, individual factors may require further analysis. Generally, an applicant must meet the requirements established in the Education Law and Commissioner's Regulations including clinical social work education, clinical social work examination and an experience requirement. Education Law §7704(2}(c) provides that the experience must be at least three years full-time supervised postgraduate clinical social work experience in diagnosis, psychotherapy, and assessment-based treatment plans, or its part-time equivalent, obtained over a continuous period not to exceed six years. Commissioner1 Regulations §74.3 further defines full-time experience for purposes of this requirement to consist of not less than 48 weeks per year, excluding vacation, with not less than an average of 20 client contact hours per week. The part-time equivalent must consist of the same total number of client contact hours provided over a period of between three and six years.

Psychotherapy Experience.

Since 1988 certain social work licensees qualified for third-party insurance reimbursement by documenting three or more years of supervised experience in psychotherapy that met the requirements of section 74.5 of the Commissioner's Regulations. In relation to qualifying psychotherapy experience for the privilege, the regulation has required and continues to require that "client contact hours" must be earned in sessions of at least 45 minutes each. The Department has accepted the 45-minute session as equal to one client contact hour, according each session with an additional 15 minutes of credit for record-keeping and related activities.   A Licensed Clinical Social Worker who is applying for the psychotherapy privilege after September 1, 2004 (formerly the six-year credential) must meet the requirements for supervised experience, as defined in section 74.5 of the regulations, including the requirement that client contact hours must be earned in sessions of at least 45 minutes each.     

Clinical Social Work Experience.     

An applicant may meet the experience requirement for licensure in clinical social work through the provision of clinical social work services in an agency or other setting, acceptable to the Department. The applicant must be under a qualified supervisor and receive supervision of the duration and frequency specified in section 74.3 of the Commissioner's Regulations. Although the practice of clinical social work encompasses the practice of master social work and other services, only experience in psychotherapy, diagnosis and assessment-based treatment planning is acceptable, pursuant to section 77Q4(2)(c) of the Education Law.

The State Education Department has been asked whether applicants can count sessions of less than 45 minutes to meet the required hours of experience for licensure in clinical social work. It is the determination of the State Education Department, in consultation with the State Board for Social Work that sessions less than 45-minutes may be appropriate, including but not limited to:

• Treatment of clients for whom more frequent sessions of shorter duration are clinically appropriate (e.g., crisis-oriented psychotherapy);            
• Services to clients who may not be able to participate in longer sessions for reasons of age (children with severe emotional disorder) or diagnosis (e.g., Attention Deficit Disorder or Attention Deficit Hyperactivity Disorder); or
• Reimbursement policies of third-parties (e.g., Medicaid or private health insurance) who reimburse psychotherapy sessions of less than 45-minutes; or  
• Facilities where psychotherapy is integrated with other activities (e.g., milieu therapy or residential day treatment).

In clinically appropriate situations, the applicant and the qualified supervisor shall document the weekly client contact hours that were completed as part of the supervised experience for licensure.

If sessions of less than 45 minutes are used, they must aggregate to 45 minutes to equal one client contact hour.

Applying for Licensure.

The applicant for licensure should indicate on Form 4B the weekly average client contact hours (exclusive of record keeping and related activities) in the provision of diagnosis, psychotherapy and assessment based treatment planning. The Form 4B must be signed by the applicant's supervisor who is an LCSW, a licensed psychologist qualified in psychotherapy, or a licensed physician qualified in psychiatry, as defined in Commissioner's Regulations. In verifying the experience, the qualified supervisor is attesting that the individual sessions were of sufficient duration and quality to meet the requirements for supervised experience in diagnosis, psychotherapy and assessment-based treatment plans. All experience forms shall be submitted directly to the Department by the qualifying supervisor and the applicant must meet all other requirements for the supervised experience and licensure.           

The Department believes that this guideline is consistent with the legislative intent and reflects the current provision of psychotherapy in private and public settings across New York State. You can access more information about the practice as a Licensed Clinical Social Worker and the qualifications for licensure and the psychotherapy privilege on the Office of the Professions' web site (www.op.nysed.gov/lcsw.htm).