I disagree with NASW’s position that social work must retain the oral because of the MFCCs. NASW has provided its members with a red herring to steer them away from seeing the real issues at hand. MFCCs and LCSWs have different educational backgrounds and expertise. There are many differences between MFCCs and LCSWs that are much more important than the oral exam which set the two disciplines apart. LCSWs are required to obtain 3,200 hours of supervision in a minimum of 2 years post degree. MFCCs are only required to obtain 1,700 hours of supervision post degree and there is no minimum time limit set on this. LCSWs obtain nearly twice the post degree supervision MFCCs obtain prior to licensure. I think that it is more than obvious that MFCCs and LCSWs are not on a "level playing field" as NASW CA and others have tried to make us believe. Furthermore, because of the shortage of LCSWs caused by the oral exam, employers are reclassifying jobs all over this state and giving them to MFCCs. MFCCs in California outnumber LCSWs by almost ten thousand (Gwen Carkhuff of the BBS reported that as of 2/1/98 there were 23,322 MFCCs and 13,731 LCSWs licensed in the State of California). This means that there are 59% more MFCCs than LCSWs currently practicing in the state of California.  There are also 4,102 ASWs (registered Associate Social Workers)  as compared to 8,698 IMFs (Intern Marriage and Family Counselors) that’s more than twice the number of ASWs (This information is as of 2/1/98 and was also provided by Gwen Carkhuff of the BBS)!!    Employers are realizing that MFCCs don’t command as high a salary and that there are a plethora of MFCCs to choose from while there is only a very small pool of LCSWs to choose from. Often MFCCs are the only ones even applying for jobs that were historically considered to be social work jobs. The field of social work is shooting itself in the foot by retaining the oral examination for the purpose of competing with MFCCs. In the BBS Business Summer/Fall 1997 edition there is a section entitled Disciplinary Actions. This lists all of the disciplinary actions taken by the BBS in an 8 month period. There were 4 LCSWs on the list and 35 MFCCs. Even when you control for the fact that there are many more MFCCs than LCSWs it remains obvious that MFCCs are disciplined at a much higher rate than LCSWs (Using these figures LCSWs are disciplined at a rate of .00029% compared to MFCCs who are disciplined at a rate of .0015%) This only further proves my point that LCSWs and MFCCs are not on a level playing field with or without the oral examination and it is ridiculous to compare the two professions on the basis of an oral examination. Why not continue to set ourselves apart from the MFCCs once again by measuring competence and ethics in a more effective manner than the oral examination? Virginia repealed their oral exam requirement in 1992 and since that time they have standardized the post degree MSW supervision.

     As far as Psychologists are concerned, they are required to pass an oral exam for licensure in 21 states other than CA. In these 21 other states social workers continue to perform psychotherapy and operate independent private practices. The quality of social work in these states has not been affected and none of these states are considering implementing an oral exam for social work licensure. There is also a misperception that CA is unique in its situation re: MFCCs. I have contacted the American Association of Marriage and Family Therapists (AAMFT) and found out that 37 states license or certify MFCCs.  Some states even require an oral examination for MFCCs to obtain licensure but not social workers.

     Some county employees if  unable to obtain licensure within 3 years of employment will face termination. It takes 2 years just to obtain the required supervision before an applicant is eligible to sit for the written exam. Once an applicant passes the written the oral is only offered twice a year and it takes the average person 3 attempts to pass the oral with the current 35% pass rate.  At this rate if an applicant fails the exam only twice they would exceed the 3 year time limit with the county and risk termination. This issue is a RIGHT TO WORK issue for social workers in the state of CA. NASW CA and Susan Davis are interfering with CA social worker's right to work by opposing SB288 and to keeping SB288 hostage in the Assembly Committee for Consumer Protection.

     Sherry Mehl, Executive Officer of the BBS stated in February that within the year the BBS will discontinue utilization of the national AASSWB written exam and replace it with their own creation of a new California only written exam. This will mean that if an LCSW moves to another state their license will not be honored and they will have to apply to take the national AASSWB written exam in that state. This will also give the BBS the opportunity to change the exam and possibly alter it to increase the fail rate in an attempt to make the oral and written pass/fail rates more commensurate.   In response to questions regarding changing the written exam NASW CA in an email to an NASW member stated, "The BBS is looking at developing their own written exam because they believe the national exam is too easy.  Their psychometricians and lawyers are probably concerned that an exam with such a high pass rate is not valid or puts it at odds with the low pass rate for the oral.  NASW has no position at this time." Charlene Newton of the AASSWB informed me that 49 states, Washington D.C., and the Virgin Islands all utilize the AASSWB written exam. Michigan is the only state that does not utilize the AASSWB written exam and they do not have a written exam requirement for licensure in their state. A newspaper article on this subject in the San Francisco Examiner stated that the BBS’s "projected revenue [for 1997-98] is $6.4 million, more than a quarter of which is expected to come from $200 fees ($100 for appeals) candidates pay when they test". It is obvious that Sherry Mehl would like to boost the aforementioned revenue from the orals by creating a CA only written exam. With a new CA written the BBS would collect revenues from the written AND oral exams. This does not even address the huge revenues collected by LCSWs in the cottage industry that has grown up around the new oral exam because of its incredibly high fail rate.

     If we want to investigate an MSW’s ethics and observe their "personal functioning, interactive skills, and ability to provide safe and effective clinical social work services to the public" (BBS candidate handbook for oral exam 1997, p. 2), the 3,200 supervision hours required post degree to be obtained in no less than 2 years, provides endless opportunities to discern this information. Since VA standardized their supervision they now require all supervisors to take a course on how to be a supervisor. The course educates LCSW’s on what the focus of supervision should be, the process of supervision, and the standards and requirements for supervisees. If the requirements are not fulfilled the supervisee cannot obtain the hours. The VA Board of Social Work has developed a Clinical Supervision Curriculum Guide that consists of 2 textbooks, a videotape, an audiotape and a CD-ROM. This package contains all of the information and requirements necessary for supervision in the state of VA.

     On a personal note, my mother is an LCSW in MD,VA, Washington D.C., and NV. She has 15 years of direct clinical clinical experience in social work. She has worked at the Psychiatric Institute of Washington D.C. for 10 years and was the Clinical Director at the McArthur School for emotionally disabled children in MD. For the past 5 years she has had her own private practice. She has provided clinical supervision for 3 MSW’s and 1 MFCC towards their supervision hours required for licensure. In spite of all of her experience and knowledge she has failed the CA oral twice. The oral exam is supposed to test for entry level competence in an effort to protect consumers. In her 15 years of experience she has never had any disciplinary actions taken against her or ever even been threatened by any malpractice suits. I became a social worker because I wanted to join a profession whose mission is to fight against injustice and inequality and to advocate for the disenfranchised.    Ironically, I have become disenfranchised from my own profession and soon will be the victim of injustice and inequality in the form of an invalid and unreliable oral exam.   Unbelievably all of these injustices are perpetrated by social workers who are also supposed to share these same ideals.

     I would like to take this opportunity to share with you the reasons why the oral examination for licensure in social work should be eliminated:

1. The BBS claims that the oral provides candidates the opportunity to "apply their clinical skills as an independent practitioner does in the ‘real world’" (BBS Candidate handbook for the oral examination 1997, P. 10). However, in reality the sample vignette, which is similar in "style, length, content and structure" to those used in the oral, contains only 7 sentences. Each candidate is given 5 minutes to review these 7 sentences and take notes. They are then asked 10 questions regarding the vignette and allowed 30 minutes in which to respond ( allowing approximately 3 minutes per question). If a clinician in the "real world" read 7 sentences about a client and proceeded to assess, treat and refer they could be sued for malpractice and should be because of their unethical and irresponsible behavior.  Furthermore, applicants are "graded on 7 different content areas. In content area II of the oral applicants are evaluated on 12 different associated knowledges within that one content area. Applicants receive one single numerical score for each content area. The numerical score will correspond with a table that consists of generic standard responses regarding whether or not the response is determined to be deficient. Neither the numerical score nor the table will provide applicants with any individualized information about why their response was determined deficient or which of the different associated knowledges was not covered sufficiently.
2. The BBS has made no attempts to explain the discrepancy between the pass rates for the written and oral exams, or in the rates prior to its standardization in 1992 and after. Before 1992 and the "standardization" of the oral exam the written and oral pass rates were commensurate. According to the BBS Sunset Review Report the average pass rate for the written exam from 1993-1997 is 84%, and the average pass rate for the oral exam from 1993-1997 is 37%. In their report to the Sunset Review and during testimony the BBS failed to offer any explanation for these discrepancies.
3. The BBS continues to claim that the oral examination protects California consumers. In the Sunset Review Report the BBS stated that they have "not had to discipline a single LCSW who was licensed after the standardization of the exam in 1992" (October 1997). However, it is quite interesting that the BBS is not interested in protecting California consumers against 80% of the LCSWs currently practicing in CA who have never taken an oral or those who have not taken the current "improved" oral. If the BBS were truly interested in protecting CA consumers they would require that all LCSWs licensed prior to 1992 pass the current oral as a condition for renewal of their licensure. After all, LCSWs from other states who are unfortunate enough to move into CA must take the oral regardless of their licensure status in other states or their number of years of experience.
4. The BBS also did not address the fact that other states have had oral exams in the past that they have done away with because of their subjectivity. Virginia in particular has recently repealed their requirement for an oral exam. The president of the BBS in VA fought tenaciously to retain the oral and after its repeal stated that it was eradicated because of its subjectivity. She also reported that VA has had no increase in disciplinary actions of LCSW’s since the eradication of the oral. In VA once the oral was repealed the BBS worked to standardize the post degree MSW supervision.
5. California is the only state to continue to require an oral exam for licensure in social work. In spite of all of the facts above the BBS stated in the Sunset Review Report the following: " If any of the examinations required for licensure by the Board were eliminated, public health and safety would be jeopardized. Unprepared, unethical, or potentially harmful people could become licensed as independent practitioners." I guess CA consumers should consider themselves lucky not to live in any of the other 49 perilous states within our unethical and crumbling nation. Except for the fact that CA does have LCSW’s practicing in our great state who have not taken both a written AND an oral examination.
6. The BBS states in the Sunset Review Report that "Oral examiners receive extensive training prior to each examination cycle to ensure that the examinations are standardized" (p. 5). The BBS Business publication Summer/Fall 1997 edition p. 5 addressed the issue of training and requirements for oral examiners as follows: "Any qualified licensee may apply to become an oral examiner. New examiners complete an 8 hour training course and work only with seasoned examiners during their first examination cycle." My only question is in what profession does 8 hours constitute EXTENSIVE TRAINING?

     The precipitous drop in pass rates following the standardization of the exam in 1992 is extremely compelling information and should have resulted in extensive testing of the validity and reliability of the oral exam to rule out the strong possibility that the huge decrease in pass rates was not due to changes in the exam that rendered it invalid or unreliable. My understanding is that the BBS' claims of the oral's validity is based on the inter-rater reliability of 82% and the NEW Occupational Analysis that will develop the questions for the oral exam in the future.

     However, the BBS has not provided information that the above stated inter-rater (examiner) reliability controls for the confounding variable of influence. Any of us who have taken interpersonal psychology understand that two people who are in a confined space for an extended period of time and working towards the same goal as the examiners are influenced by each other non-verbally and otherwise.

     There is a very simple way to control for this confounding variable and the BBS has all of the resources right at its fingertips. Each examinee's audiotape could be sent to two different examiners in different parts of the state who would not have any contact with each other whatsoever. These two examiners could be asked to grade or evaluate the examinee in the usual manner. These separate examiners' inter-rater reliability scores would then be compared with the original examiner's scores and a correlation coefficient could then be performed. Without controlling for this variable the inter-rater reliability scores reported by the BBS are meaningless.

     Validity and reliability must be tested in at least a few different ways in order to provide any substantial information. Stating that the BBS is determining ways to validate the exam questions in the future does not provide any information about current validity or reliability. Once again, the BBS already has all of the information at their fingertips to effectively assess validity and reliability. For example, a wonderful way to test for validity is to utilize the pass rates for examinees who are already licensed in other states and have at least five years of experience practicing in that state. Applicants must provide all of this information in the numerous applications they must fill out prior to being granted permission to sit for an exam. The BBS states on page 57 of the October 1, 1997 Sunset Review Report that the written and oral exams test for "entry -level competency". If experienced LCSWs from other states pass the oral then this would go towards affirming the validity of the oral. If however, experienced LCSWs from other states fail the oral exam it would be apparent that the oral exam is not in fact testing entry-level competence. My mother, of course, is a case in point for the exam's lack of validity.