ADVOCACY, NEWS AND ISSUES ARCHIVE
Request for Reply Letter-
The President of OSSWA writes to Minister Pupatello formally requesting
a response to the letters written by SSW students last spring.
(Jan 06)
Student Letter to Minister - Ontario Social
Service Worker students wrote to the Minister of Community and Social
Services to address several issues of concern. (Spring 05)
OCSWSSW Issue Letter - The OSSWEA wrote to the
Registrar of the Ontario College of Social Workers and Social Service
Workers regarding a number of current concerns. (Spring
05)
OSSWEA Review Letter - The OSSWEA submitted a letter
in response to the five year review of legislation. (Spring
05)
OASW Response 2005 - For your information, this
is the response sent by the OASW to the review of the legislation.
Request
for Reply Letter
1363 Woodroffe Ave , Unit B
P.O. Box 33061
Ottawa , Ontario K2C 3Y9
Minister Pupatello
Ministry of Community and Social Services
80 Grosvenor St , 6 th Flr, Hepburn Block
Toronto , ON
M7A 1E9
January 26, 2006
Dear Minister Pupatello,
I am writing as President of the Ontario Social Service Worker
Graduates Association. Our Association was formed in June 2005 and
one of our objectives is to provide information and to facilitate
a unified provincial voice in response to critical issues affecting
our membership. A profile of our Association can be viewed on our
website www.OSSWA.ca.
Some of our members have raised concerns about the lack of response
to a letter that was sent to you by many graduating SSW students
last March. I have enclosed a copy of that letter for your reference.
On behalf of these members I respectfully request a response to
the concerns raised in that letter.
Social service worker graduates are key stakeholders of your Ministry.
They represent the majority of front-line social service workers
in this province. The concerns raised in the letter sent last spring
are important and deserve your consideration and response.
I realize it would be difficult to reply to the many letters you
received last spring, however I would be happy to receive and post
your reply to our membership.
Respectfully,
Shelley Styles
President
OSSWA
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Student Letter to Minister
Minister Pupatello
Ministry of Community and Social Services
80 Grosvenor St, 6th FLr, Hepburn Block
Toronto, ON
M7A 1E9
Dear Minister Pupatello
I am a Social Service Worker student in my final
term of study. As I prepare for graduation and look forward to
establishing my career, I have several concerns that I would like
to address with you. My concerns are related to the recent amendment
to the Ontario Disabilities Support Program; barriers to registration
in the OCSWSSW; and the protection of title policy.
The first issue relates to the recent ODSP amendment,
which excluded Social Service Workers from the right to complete
the Daily Living Index form. The inclusion of our graduates was
supported by the OCSWSSW. The type of assessment required for
this task is well within the scope of practice of Social Service
Workers. I have had many opportunities to complete assessments
both in the classroom and through my extensive field practicum
training. There is no doubt that our skill set enables us to fulfill
this duty. I respectfully ask you to reconsider your position
on this issue.
Secondly, the College of Social Workers and Social
Service Workers is something that I support in principle. However,
as it currently stands there are barriers to my registration.
The fee for registration is unrealistic. With the level of income
that I can expect to earn, paying almost $400 per year for registration
is too much. I realize that we are required to support the College
financially. However, I would ask that the fees for registration
be more in line with the level of salary earned by SSW graduates.
This would make registration feasible. A lower fee would likely
increase the number of registrants significantly.
The proposed entrance exam will also serve as
a barrier to registration. Our program meets provincial standards
set by the Ministry of Education and Training, College Standards
and Accreditation Council. The Social Work Code of Ethics is covered
comprehensively throughout the program and applied through extensive
field practice prior to my graduation. I feel that an entrance
exam is redundant once I have met all of the requirements for
my diploma. The cost attached to this exam will be yet another
barrier.
Lastly, I am concerned about the protection of
title policy. Once I have graduated from my program, I will have
earned an SSW diploma. I feel that I should be able to call myself
a Social Service Worker. It is clear that only if registered with
the OCSWSSW can I call myself a RSSW. The R is a clear indication
to the public and to potential employers of registration. I respectfully
ask that I not be penalized for calling myself an SSW, a title
that I have earned.
In summary, I ask you to reconsider your decision
to exclude Social Service Workers from the ODSP amendment. It
is in the best interest of the public to have access to more professionals
who can complete this form. I also ask that you consider my concerns
regarding current barriers to registration in the OCSWSSW's as
you undertake the five-year review of this College. Finally, I
ask for your assistance regarding the current protection of title
policy. I feel that the difference between RSSW and SSW is clear
to both the public and employers.
I look forward to your consideration and response
to my concerns.
Sincerely,
CC Glenda Mcdonald,
Registrar
OCSWSSW
80 Bloor Street West
Suite 700
Toronto, Ontario
M5S 2V1
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OCSWSSW Issue Letter
March 21, 2005
Glenda McDonald, Registrar
Ontario College of Social Workers and Social Service Workers
80 Bloor Street West
Suite 700
Toronto, Ontario
M5S 2V1
Dear Glenda:
On behalf of the Ontario Social Service Worker
Educators Association we are writing this letter to express concerns
in four areas. The plan to implement an OCSWSSW entrance exam;
the recent Ontario Disability Support Program regulation amendment;
the cost of registration to the College; and the current protection
of title policy are issues that we will address at this time.
The plan to implement entrance exams for SSW
grads applying to the College is an area of great concern. At
the time your College was being implemented this issue was discussed
at length. It was agreed at that point that examination of College
registrants would only be considered in a situation where the
applicant's credentials did not meet Ontario standards. As you
know, Ontario SSW graduates have all met the approved program
standards set by the Ministry of Education and Training, College
Standards and Accreditation Council. Within the program standards
is comprehensive coverage and application of the Ontario College
of Social Workers and Social Service Workers Code of Ethics. We
do not understand the need for examination of our Ontario Social
Service Worker graduates. We would hope that standards set by
our Ontario Ministry and tested by our Provincial Colleges would
be acknowledged and validated as sufficient entrance requirements
for the OCSWSSW.
The second issue we would like to address is
the recent amendment to the Ontario Disabilities Support Program.
Even though the College Council approved the task force recommendations
that both Social Workers and Social Service Workers had the required
qualifications to complete the Activities of Daily living index
form, in the end SSW's were excluded from the regulation amendment.
We would like to know which steps your Council is taking to appeal
this decision.
The third issue concerns the current registration
fees. Based on the level of salary that SSW graduates can expect
to earn, the current fee is unreasonable. A lower fee would most
definitely result in a larger membership. The intent of the College
from the outset was to serve and provide protection to the public.
In light of this we assume that the Ministry is hoping for high
numbers of Registered SSW's. For this to happen, the registration
fee needs to be obtainable.
Finally, we would like to address the protection
of title policy. Currently this policy restricts the use of SW
and SSW. There are many thousands of both Social Workers and
Social Service Workers who are not members of
the College. The idea of policing graduates who are using these
titles seems unreasonable. Logistically, and in the interest of
protecting the public, we suggest the protection of the titles
Registered Social Workers and Registered Social Service Workers.
The term registered would make it transparent to the public and
to employers the differentiation between someone who is or is
not a registered member of the OCSWSSW. This would also allow
the College to make better use of their resources.
The issues we have raised in this letter are
all obstacles, in our view, to Ontario Social Service Worker graduates
registration. Firstly, the proposed registration examination is
redundant for applicants who have graduated from an Ontario College
of Applied Arts. Secondly, the exclusion of SSW's from the ODSP
regulation is an indication to our graduates that the College
Council was not able to facilitate their inclusion in this amendment.
We will be looking to you for a strong appeal to the Ministry
regarding this decision. Social Service Worker Graduates need
to know that you will strongly protect their interest when such
issues arise. Thirdly, the current protection of title policy
is an issue that we would like to see reviewed. Finally, the current
registration fee clearly creates a barrier to registration for
our graduates. This needs to be addressed in some concrete way
if the number of SSW registrants is to substantially increase.
We appreciate your consideration of the concerns
raised by our Association.
We are hoping to inform our current graduating
students and alumni of your response prior to the end of this
term. Thus, we would appreciate your written reply as soon as
possible.
Sincerely on behalf of the Ontario Social Service
Worker Educators,
Benoit Dupuis, Professeur La Cité Collégiale
Shelley Styles, Professor Algonquin College
Cc Carmen Perillo, President OSSWEA
Cc Gerry Barker, Head of Applied Arts
Cc Joan Homer, CEO ACAATO
Cc Mohamad Haniff, Senior Analyst, CSS
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OSSWEA Review Letter
Mohamad Haniff
Senior Policy Analyst
Ministry of Community and Social Services
Community & Social Services
Community Services Branch
56 Wellesley Street West, 12 th Floor
Toronto, Ontario
M7A 1E9
Dear Mr. Haniff:
On behalf of the Ontario Social Service Worker
Educator’s Association, I am replying to the invitation
by the Ministry of Community and Social Services to respond to
the five-year review of the Social Work and Social Service Work
Act. In this response we will be addressing our concerns regarding
misinformation found in the Ministry’s Review Discussion
Paper; we will respond to the Ministry’s two questions pertaining
to the review of the Act; and finally we will conclude by making
a number of further recommendations.
Misinformation
states that Social Service Worker graduates hold
a two-year college certificate. This terminology is inaccurate
and misleading to the public. The Social Service Worker college
programs are two-year diploma programs. Within the Ontario
College system there is a distinct difference between diplomas
and certificates, with diploma programs requiring specific academic
standards that are not required with certificates. It is important
that all communication coming from the Ministry be clear and accurate,
if the public is to be correctly informed.
The discussion paper also states that Ontario
is the only jurisdiction to include Social Service Workers in
such legislation. In fact, the province of Alberta also includes
college graduates under their regulatory Act. In Alberta there
is no distinction of title between college and university graduates.
All members of this College are referred to as ‘registered
social workers’. We are not opposed to the current distinction
of title in Ontario because it makes it clear to the public which
educational training has been completed by members. However, we
think it is important for all stakeholders to know that Ontario
is not the only province to regulate college graduates of social
service work.
Response to Questions
- Are the provisions in the Act adequate for achieving the objectives
of the Act?
a) Public Education
To achieve the objectives of the Act we believe
there needs to be more public education regarding the existence
of the College and its role in public protection. It is clear
to us, and our community partners, that there is not sufficient
awareness about the OCSWSSW and the implications of regulation.
Given the limited awareness of the College and its purpose at
this time, it would seem that the task of measuring success would
be a difficult one. We are also interested in knowing if the Act
has had any influence over the hiring practices of employers.
b) Scope of Practice
The distinction between the scope of practice
of Social Workers and Social Service Workers may be more relevant
in large urban centers. In smaller communities and northern centers,
there are more similarities than differences concerning the role
of Social Workers and Social Service Workers. The current distinctions
as to scope of practice could create barriers to qualified SSW
professionals currently working in outlying communities who typically
have broader expertise in areas that the legislation defines as
Social Worker function. Some of these communities have difficulty
recruiting university-trained Social Workers and rely on the critical
services offered by Social Service Workers.
c) Barriers to Registration
Membership Fees
The level of current college membership fees
create a barrier to Social Service Worker graduates who would
like to register. The Ontario College of Social Work and Social
Service Workers did not receive start-up funds for the establishment
of this body. During the implementation of the Ontario Health
Disciplines Act, other professions received financial support
from the provincial government to implement their regulatory bodies.
The OCSWSSW, on the other hand, has been established totally at
the expense of their members. The registration fee for SSWs is
disproportionate to their level of income. The College’s
need for a certain level of operational funding has resulted in
fees for Social Service Workers that are not manageable. We believe
that this is a major reason why there are fewer Social Service
Workers who are able to join the College. This issue clearly has
implications regarding the effectiveness of the legislation to
protect the public.
Registration Exam
The proposed registration exam will serve as
yet another barrier to registration for our Ontario College Social
Service Worker graduates. This process is seen as redundant. Our
graduates have each met the standards set by the Ontario Ministry
of Education and Training, College Standards and Accreditation
Council. The Social Work Code of Ethics and the Standards of Practice
are covered comprehensively throughout our programs, and are applied
by students during extensive field practice prior to graduation.
We would expect that standards set by the Ontario Ministry of
Education and Training and evaluated by our provincial colleges
would be acknowledged and validated as sufficient requirements
for registration in the OCSWSSW. In 1998 Ministry representatives
and stakeholders discussed the implementation of an exam at length.
It was agreed at that point that an exam for College applicants
would only be considered in a situation where the applicant’s
credentials did not meet Ontario standards. Therefore the proposed
registration exam is unnecessary in our view. The additional costs
that will be attached to this process will provide a further barrier
to registration, and therefore affect the protection of the public
mandate.
d) Stakeholder Representation
While working on committees and with the Council
of the OCSWSSW, members of our Association have found that there
is an over representation of health related Social Workers. It
is felt that at times decisions are skewed to be reflective of
that group. This does not provide the broad perspective that represents
the daily operations of our profession. We would like to see a
broader representation of front line workers, community organizers
and developers, and policy practitioners involved in committee
and Council work. For example, in the critical area of determining
whether or not there should be a registration exam, with the exception
of the Council staff person, the entire membership of the task
group was comprised of professionals with health related experience.
2. What changes to the act, if any,
should be considered by the government to improve the operation
of the College to carry out their roles and responsibilities?
a) Amendment to the protection of title
policy.
Currently the protection of title strategy is
to police the use of the title Social Worker and Social Service
Worker by members who are not registered. As there are many thousands
of both Social Workers and Social Service Workers who are not
currently members of the College, the task of policing graduates
who are using these titles is daunting. Logistically, and in the
interest of protecting the public, we suggest the protection of
the titles Registered Social Workers and Registered Social Service
Workers. The term “registered” would make
transparent to the public and employers the differentiation between
someone who is or is not a registered member of the OCSWSSW. This
would also allow the College to make better use of its resources.
b) Prior learning assessment to extend
scope of practice.
We recommend that there be a clause in the Act
that would identify the need for some of our northern and rural
Social Service Worker graduates to extend their scope of practice,
based on experience and specific training. To ensure that they
do have the expertise to extend their scope of practice, there
could be a prior learning assessment component put in place.
c) Halting implementation of an exam.
We recommend that the Ministry does not support
the OCSWSSW’s proposal to implement an exam for graduates
of accredited Social Service Work and Social Work programs in
Ontario. It is felt that this is unnecessary, costly and a poor
use of Council resources.
d) A more representative College Council
and committee membership.
Our recommendation is that the Ministry provide
the OCSWSSW with clear guidelines regarding the composition of
both Council and task force committee membership to insure a broader
representation of the community. Currently membership is heavily
weighted in the area of health.
Further Recommendations
1. We recommend that the College and the Ministry
articulate and implement an appropriate public education strategy
to better inform the general public and previous SW and SSW graduates
regarding the existence and purpose of the OCSWSSW.
2. We recommend that the Ministry take steps
to evaluate the success of the College in fulfilling its intended
role in protection of the public.
3. We recommend that the Ministry provide funds
to the OCSWSSW to compensate for its start up costs so that registration
fees can become more attainable.
Sincerely,
Carmen D Perillo
Chairperson
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OASW Response 2005
The Ontario Association of Social Workers (OASW)
is pleased to respond to the 5-year review by the Ministry of
Community and Social Services (MCSS) of the Social Work and Social
Service Work Act (1998) which regulates the practice of social
workers and social service workers in Ontario.
Social workers practice in many settings serving
children, youth and adults that include:
- acute, chronic and medical rehabilitation services attached
to hospitals
- child welfare
- community-based health clinics and home care
- education system
- employee assistance programs
- family and marital counselling services
- justice system
- mediation and conflict resolution
- mental health and addictions
- private practice.
Unethical or incompetent practice by professionals
can seriously harm clients. Regulatory legislation provides public
protection and a means to monitor and support excellence in practice.
As the Honourable Minister of Community and Social Services Sandra
Pupatello states, "Ontario Social Workers and Social Service Workers
help individuals and families through tremendous personal challenges
every day. We owe it to Ontarians to make sure the profession(s)
continue to maintain the highest standards."
OASW commends the Ontario government for its
commitment to self-regulation of our profession and to competent
and accountable service delivery. The last 5 years have afforded
an opportunity to ascertain what mechanisms have been effective
and what needs to occur to further strengthen public protection.
By way of enhancing the effectiveness of the regulatory framework,
OASW will address the following issues in its response to the
Ministry's "Discussion Paper":
1.0 SELF-GOVERNANCE AND PUBLIC PROTECTION
Since the implementation of the legislation,
a key issue of concern to social workers relates to the composition
of the Ontario College of Social Workers and Social Service Workers'
(OCSWSSW) Council. When the government enacted legislation, it
was anticipated that there would be strong representation from
both groups resulting in reasonably equitable numbers of social
worker and social service worker registrants. Hence, it was decided
to have 7 social workers, 7 social service workers and 7 public
members. In fact, the reality has been quite different. Currently,
91% of College registrants are social workers.
OASW believes that the under-representation of
social workers on the College Council, given the high number of
social work registrants, has serious ramifications for self-regulation
of the profession and ultimately the protection of the public.
Implicit in equal representation is that the energies and priorities
of the College should be equally directed in supporting the objects
of the College in relationship to both disciplines: that is, providing
for public protection with respect to each discipline (including
complaints procedures and disciplinary hearings), as well as providing
for the continuing education of each discipline; establishing
standards of practice for each discipline; and promoting high
standards and quality assurance for each discipline.
The implications of equal representation of the
two professions are that the College's resources and attunement
to the development of social work are negatively affected. In
essence, the public, who are the recipients of services from social
workers, are placed at potential risk if the attention, focus
and expertise of the College do not take into account both the
wider scope of practice of social workers and the larger number
of social workers who will need to be educated about standards
of practice and the promotion of excellence within the discipline.
Social workers and social service workers were
regulated as distinct professions because there are important
differences in the nature of each discipline's work. Differences
between the two groups include: the scope of practice; the level
of independent judgment required in conducting professional practice;
the expectations with respect to client outcomes; and the depth
and breadth of academic preparation.
Marlene Zagdanski, Director of Complaints and
Discipline at the College, presents these differences clearly
in an article in the Fall/Winter 2004/05 issue of Perspective
entitled, "Scope of Practice-Demystified". She states: "There
is no precise line that clearly demarcates the bodies of knowledge
of these two professions.There are, however, essential distinguishing
differences, based on formal levels of education and the intensity,
breadth, depth, comprehensiveness and theoretical richness of
the relevant bodies of knowledge of each profession" (p. 11).
We would highlight that social workers' potential
span of complexity of practice is broader than that of social
service workers, in part due to the differences in the span of
professional education in that social work education includes
baccalaureate, master's and doctoral degrees. While social service
workers may and do pursue additional education, there is not an
accredited progression of education beyond the diploma that is
specific to social service workers in the manner that the progression
of social work education is accredited by the Canadian Association
of Schools of Social Work. The social work profession represents
a more expansive and complex terrain of practice, with a greater
expectation of independent judgment. Such differences have important
implications for standards of practice and continuing education,
which are part of the objects of the College, as well as when
addressing disciplinary issues.
Despite important differences in the scopes of
practice between the two disciplines, the fact that social workers
and social service workers are currently held to the same code
of ethics and standards of practice is concerning and would reasonably
imply to the public and employers that there is one, rather than
two professions. The implications of this blurring were recently
underscored when the College Council recommended to MCSS that
the Ontario Disability Support Program Regulations be amended
to add both Registered Social Workers and Registered Social Service
Workers to the list of professionals who can complete the Activities
of Daily Living (ADL) Index in the Disabilities Determination
Package. MCSS only approved adding Registered Social Workers to
the list as they deemed that completion of the ADL Index was outside
the scope of practice of Registered Social Service Workers.
2.0 HARMONIZATION OF LEGISLATION
2.1 Need for Amendments to Ontario Statutes:
When the Social Work and Social Service Work
Act, 1998 was originally passed, there was an expectation that
amendments would be made to regulations in existing statutes under
which social workers have traditionally practiced, especially
in the health care sector, to reflect our profession's regulatory
status. While some movement has been made in this direction, significantly
more needs to be done to complete this process. Barriers continue
to prevent the public from accessing timely social work services
because major statutes refer only to members of the RHPA, and
fail to recognize the important role that registered social workers
play in the delivery of health care services in Ontario. This
has led to confusion on the part of the public, members of allied
professions and within the profession itself.
Immediately after the Act was passed, amendments
were made to regulations under the Health Care Consent Act, 1996
to recognize registered social workers as evaluators. Similarly,
regulations under the Substitute Decisions Act, 1992 were amended
to recognize "registered social workers" who perform capacity
assessments. It is important to point out, however, that both
pieces of legislation had previously recognized social workers,
certified under the former voluntary college, the Ontario College
of Certified Social Workers. In essence, the designation "certified
social workers" was replaced by the phrase "registered social
workers". As previously noted, in December 2004, the Ontario Disability
Support Program Regulations were amended to add "registered social
workers" to the list of professionals who can complete the Activities
of Daily Living Index in the Disability Determination Package.
Additionally, the newly enacted Personal Health Information Protection
Act, 2004 references members of the Ontario College of Social
Workers and Social Service Workers who provide health care, in
their description of health care practitioners who are defined
as "health information custodians".
Amendments now need to be made to other Ontario
statutes under which social workers practice, or that refer to
social workers, to reflect the profession's regulatory status.
These statutes include: the Child and Family Services Act, 1990;
Long-Term Care Act, 1994; Family Law Act, 1990; Health Insurance
Act, 1990; Workplace Safety and Insurance Act, 1997; Education
Act, 1991; Insurance Act, 1990; Public Hospitals Act, 1990; Pay
Equity Act, 1990; Mental Health Act, 1990 and French Languages
Services Act, 1990. Despite the fact that a number of these statutes
recognize social workers as health professionals (namely the Family
Law Act, 1990, Health Insurance Act, 1990 and Workplace Safety
and Insurance Act, 1990), regulations have not been amended to
formally reference the regulatory status of "registered social
workers".
Furthermore, serious barriers continue to exist
for registered social workers providing rehabilitation services
to victims of motor vehicle accidents. The "Statutory Accident
Benefits Schedule (SABS)" under the Insurance Act, continues to
restrict those who can sign treatment forms to professions regulated
under the Regulated Health Professions Act (RHPA), 1991. Currently,
social workers working in this sector are obliged to rely upon
the judgment of other regulated health professions to sign treatment
forms for clients requiring social work services. This practice
is inappropriate, because other professions are not qualified
to determine whether social work is indicated or the nature of
social work treatment goals and interventions required. This restriction
is perplexing from the perspective of public protection since
social workers are regulated under legislation that has an almost
identical complaints and disciplinary process to the RHPA, the
regulatory legislation that is recognized in the SABS.
2.2 Use of the Title "Doctor":
An additional barrier to service delivery impacting
upon public protection is the fact that social workers holding
earned doctorates are denied the ability to use this title while
providing clinical health services. This prohibition arises from
Section 33 of the Regulated Health Professions Act, 1991 which
restricts the title "Doctor" to professions that are registered
in a College for the following five disciplines: Chiropractors,
Optometrists, Physicians, Dentists and Psychologists.
This restriction applies only in situations where
individuals are providing or offering to provide health care to
individuals in Ontario. The challenge for social workers with
doctorates, as outlined in a legal consultation obtained by OASW,
reflects that the concept of health care is not well defined and
there are some inconsistencies across various pieces of relevant
legislation. In 2002, OASW issued a Bulletin to members with doctorates
in social work who provide direct therapeutic interventions to
clients alerting them that they should refrain from using the
title "Doctor", in such situations as: verbal exchanges with clients,
voice mail messages, business cards and public events where clients
may be solicited.
For example, a social worker with a doctorate
may call himself or herself "Doctor" in a university or administrative
setting but when working directly with clients, is forbidden from
the use of this title. This restriction is discriminatory as a
university awards the doctorate, and as such, the individual who
has been granted a degree should be allowed use of the title,
as is the case with the five other professions providing clinical
services. While it can be argued that this restriction may have
been justified in previous decades, when only a small number of
select professions were involved in the provision of clinical
services, the landscape has changed considerably in recent years
with a burgeoning number of regulated professions legitimately
holding doctoral degrees. This development has afforded the public
a greater choice for service delivery and, in an age of increasing
consumer sophistication, knowledge of appropriate qualifications
and credentials enables the public to make informed decisions
regarding modalities of treatment.
This limitation implies that clients will not
sufficiently distinguish social workers from the other professions
who use the title "Doctor". We maintain that consumers do not
need such protection, and that the restriction on the title only
serves to create an unwarranted hierarchy among professions.
3.0 COMPLEXITY OF PRACTICE AND ACCOUNTABILITY
3.1 Provision of Services to At-Risk Populations:
When the Social Work and Social Service Work
Act was introduced by then Minister of Community and Social Services,
the Honourable Janet Ecker, she linked this legislation to the
Child and Family Services Act. The stated expectation at that
time was that social work regulation would enhance public protection
within the field of child welfare. As laudable as this intention
was, the reality has been that contrary to this aim, following
the enactment of the Social Work and Social Service Work Act,
child welfare agencies across the province quickly moved to change
job titles for positions traditionally held by social workers
to the title "child protection". With the change in job title,
"child protection" jobs then fell outside of regulatory legislation.
Additionally, the change in job titles has reduced
the credibility of social work testimony within the courts since
individuals with academic qualifications in social work, who are
not registered with the College, cannot call themselves social
workers or hold themselves out as social workers. No longer able
to draw upon their academic preparation as a social worker, the
weight of their testimony as an expert witness is seriously diminished.
Most importantly, social work is the leading discipline for practice
and scholarship in the child welfare field, and the scope of practice
of social work encompasses the breadth of expertise required to
ensure child protection. This includes assessment, diagnosis,
treatment and evaluation of individual, interpersonal and societal
problems to achieve optimal psychosocial and social functioning
for the child and his or her family (Fall/Winter 2004/05 Perspective,
Zagdanski, 2004, p.10).
The practice of changing job titles in positions
traditionally held by social workers has also occurred within
other publicly funded agencies serving at-risk populations. These
include the Office of the Children's Lawyer and community health
clinics, as well as a variety of other settings such as children's
mental health treatment centres. In effect, changing job titles
has served to eliminate a mechanism of public protection afforded
to the individuals and groups who receive services from other
regulated professions.
Given the vital role that government plays in
protecting at-risk children through child welfare organizations
and the criminal justice system, tolerance of the practice of
changing job titles sends a troubling message that the harms from
abuse, neglect and family disruption are less significant than
harms arising from a health condition or impairment, or that children
and families who are disenfranchised do not need the same level
of protection afforded other members of the public. It is inconceivable
that other regulated professionals such as nurses, doctors, physiotherapists,
lawyers or teachers would be permitted to provide services without
membership in their professions' regulatory body. Indeed, the
Child and Family Services Act exists to codify our responsibility
as a society to ensure the well-being of children who are more
vulnerable than adult members of society.
3.2 Categories of Practice:
Another issue of concern to OASW relates to the
increasing complexity of social work clinical practice and the
related need for advanced training in certain domains. At one
time, it was sufficient for graduates from academic programs in
social work to simply enter practice and fluidly move from one
practice area to the next, relying upon employers to provide professional
development and training. This is no longer the case and social
workers, across the academic spectrum, are currently pursuing
advanced clinical training. In fact, within all professions, there
is a growing realization that the ever-changing nature of today's
society poses a challenging array of problems, together with improved
research in understanding the nature of those problems as well
as an ethical duty to offer services that are commensurate with
the enhanced levels of knowledge and training.
Professions within Ontario and across the country,
including social work, are exploring ways of addressing this issue.
The solutions being considered include raising the academic level
required for entry to practice, instituting categories of practice
that prescribe the nature and type of additional training required,
as well as establishing mechanisms for evaluating the training.
The Quebec Ordre currently provides certification of social workers
who wish to conduct capacity assessments and provide international
adoption services. Similarly, many states in the United States
provide specialty certification and advanced clinical credentials
with specific criteria required to obtain licensure. For example,
New York State has two categories: licensed clinical social worker
and licensed master of social work. Further, a number of social
workers pursue specialty certifications, such as "marriage and
family therapist", "psychotherapist", "play therapist", "addictions
counselor", and "family mediation."
Given the breadth of social work practice and
academic preparation (baccalaureate to doctorate), further classification
of social work expertise would serve to enhance the ability of
the public and employers to determine the level of expertise needed
to address particular problems.
4.0 ENSURING TIMELY FLOW OF COLLEGE BUSINESS
4.1 Replacement of Public Members
The Social Work and Social Service Work Act,
1998 specifies that 7 public members must be in place in order
for the College to conduct its affairs. This can pose significant
disruptions and delays for the College Council in the event of
the resignation or incapacity of a public member. This issue needs
to be addressed in order to ensure the timely flow of College
affairs.
RECOMMENDATIONS
The Ontario Association of Social Workers (OASW)
wishes to make the following recommendations:
1.0 Self-Governance and Public Protection
The principles of self-regulation are compromised
by the current composition of the College Council that provides
for equal representation of social workers and social service
workers. The interests of the public are not well served by the
under- representation of social workers on the Council, given
the fact that over 91 % of registrants are social workers. Furthermore,
the blurring of the social work and social service work role raises
troubling practice and public protection issues.
1.1 OASW recommends that the Ministry address
this serious issue in one of two ways:
. Increase the number of social work representatives
on the College Council to 12 to better reflect composition of
College registrants and the intent of self-regulation.
. Separately regulate social workers given the
high number of our profession who has registered which demonstrates
a clear commitment to self-regulation.
2.0 Harmonization of Legislation
Existing statutes under which social workers
have traditionally practiced as well as those referring to social
workers need to be amended to reflect the profession's regulatory
status. Failure to do so creates barriers to accessing timely
social work services by the public, undermines public protection,
diminishes the credibility of the Social Work and Social Service
Work Act and perpetuates confusion within the public, allied professions
and the social work community about the self-regulation of social
work practice.
2.1 OASW recommends that all statutes under which
social workers practice and those that refer to social workers
be harmonized to recognize registered social workers.
The restriction under the RHPA that prohibits
social workers who have earned doctorates from using the title
"Doctor" when providing health care services is discriminatory
and does not serve to protect the public. This restriction denies
the public important and relevant information about the individual's
academic qualifications and training which informs their choice
of health care provider and decisions regarding treatment.
2.2 OASW therefore recommends that the RHPA be
amended to exempt social workers with doctorates from restrictions
on use of the title "Doctor" in all facets of professional activity.
3.0 Complexity of Practice and Accountability
Society plays a vital role in the protection
of at-risk populations, particularly children. Children, who receive
involuntary or mandated services through child welfare organizations
and the courts, have a right to protections offered to others
in society through professional regulation. This role has been
substantially weakened by the change of job titles for positions
that have traditionally been held by social workers to generic
job titles, effectively placing these positions outside of the
jurisdiction of the Social Work and Social Service Work Act. This
practice is contrary to the original intent of this legislation,
which was seen as enhancing protection for children served by
child welfare and related organizations. Vulnerable children are
thereby denied access to a mechanism of public protection afforded
to other segments of the population. Social workers employed in
child welfare and in the justice system make decisions that affect
the safety and psychosocial well-being of children and their families.
The public has the right to expect the same level of protection
from people with backgrounds in social work as from people in
other regulated professions.
3.1 OASW thus recommends that the Ministry require
all organizations that provide mandated services to at-risk populations,
and who hire social workers, to require these individuals to register
with the College, thus meeting the original intent of the Minister
of Community and Social Services' introduction of the Act in the
Legislature and recorded in Hansard on December 15, 1998. This
requirement would serve to tie the need for registration to the
academic qualifications of the person providing the service. In
other words, organizations providing mandated or involuntary services
would continue to be free to hire individuals who do not hold
academic backgrounds in social workers; however, if individuals
with social work degrees are hired, these individuals must hold
the registered social worker designation.
The context of today's practice requires advanced
training beyond that provided in academic programs in social work.
With the growing privatization of service delivery, the hiring
of contract workers and cuts in training funds within organizations,
employers can no longer be counted upon to provide this training.
Ownership of specialized training needs to be assumed by the profession.
3.2 OASW recommends that categories of clinical
specialization be established within the College to reflect the
growing need for advanced training in a variety of recognized
specialties.
4.0 Ensuring Timely Flow of College Business:
The work of the College can only be accomplished
by timely meetings of Council and committee members. Disruptions
in such meeting can interrupt the accomplishment of the College's
objects and undermine public protection. Presently, the time between
a public member stepping down and a new appointment being made
for a replacement can leave important matters in limbo and not
addressed in a timely manner.
4.1 OASW therefore recommends that a mechanism
be put in place that permits the College Council to continue to
conduct its affairs in the event of less than a full complement
of public members.
March 2005
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