Cutting Red Tape Licensure Survey

On May 14, LARA sent the below communication out to all licensees in Michigan:

Dear licensee,

In a continuing effort to protect people and promote business, the Michigan Department of Licensing and Regulatory Affairs is seeking your input to identify requirements that make the process of obtaining a license challenging. LARA is always seeking ways to make licensure as simple and efficient as possible, and we need your input to identify those regulatory requirements that can be changed or eliminated to improve processes. Please complete this brief survey and tell us about any law, rule, or process changes that would make the process easier for applicants seeking licenses with LARA. The survey will be available for completion until Friday, May 24 at 5 PM.

If you have already completed the survey, there is no need to fill it out again. Thank you for sharing your comments!

Best Regards,

Bureau of Professional Licensing

This feedback provides a unique opportunity for social workers to share their thoughts and experiences with the current licensure process and to provide recommendations for potential changes.

NASW-Michigan has put together a few comments that could be included as it relates to our "Social Work Licensure Modernization Act" and specific rules that we would like to see updated. Please feel free to use the language below and add any personal experiences you have.

Please share your thoughts with LARA by May 24, at 5 pm at https://bit.ly/4avruEN.

4. What requirements, law, rule or process changes do you suggest? Please include specifications, such as law and rule citations if possible.

1. Michigan should eliminate the ASWB examination as part of the current licensure requirements (R 338.2925)

• The current license process requires passage of the ASWB exam (bachelors, clinical or advanced generalist, depending on licensure designation) despite evidence that the exam does not prevent ethical infractions or preserve public safety. 

• The ASWB exam’s disparate pass rates (https://www.aswb.org/exam/contributing-to-the-conversation/) show that it is not a fair or equitable means of measuring competency and harms the public by significantly reducing the number of social workers across our state. Specifically, the ASWB exam disproportionately impacts older social workers, social workers whose first language is not English, and social workers of color. Consider the following data for the clinical examination -

  • Social workers 50 and older have a more than 25% worse pass rate than social workers 18-29 years old\

  • For social workers who have English as a second language we see a 38% first time pass rates and only 60% eventual pass rates (Michigan and New York do not permit English as a second language arrangements nor accept score transfers for test-takers who tested with ESL arrangements in another jurisdiction)

  • From 2011-2021 the first time pass rate for Michigan black social workers were 28.2%, and the eventual pass rate only reached 51% 

  • From the most recent data available (2018-2021) pass rates decreased significance for almost all categories of test takers

• This exam is not only difficult to pass, it is costly - for social workers as well as employers. When social workers have to take it over and over again they are unable to progress into positions that desperately need to be filled with LMSWs. When social workers have to work under a fully licensed social worker longer because of waiting periods and studying they are using time from supervisors that are already often working at capacity. 

• Removing the ASWB exam from the requirements would effectively “remove the red tape” that is holding back agencies, empower more communities who need providers, and expand the number of licensed social workers across the state of michigan. 

• LARA should consider a jurisprudence exam alternative

Statements from social work organizations across the United States:

• The National Association of Deans and Directors of Schools of Social Work (September 2022 statement - https://www.naddssw.org/pages/wp-content/uploads/2022/09/NADD-Statement-on-ASWB-Report-Release-Sep-2-2022.pdf)

• Council on Social Work Education (August 2022 - https://www.cswe.org/news/newsroom/addressing-licensing-exam-pass-rate-data/) 

• National Association of Social Workers (March 2023 statement - https://www.socialworkers.org/News/News-Releases/ID/2611/NASW-Opposes-Association-of-Social-Work-Boards-ASWB-Exams) 

2. Michigan should restructure the current social work licensure tiers to mirror most other states. New licensure levels should be (1) Licensed Bachelor Social Worker (LBSW), (2) Licensed Master Social Worker (LMSW), and (3) Licensed Clinical Social Worker (LCSW). (R 338.2939, R 338.2947

   1. Restructuring would remove the current “limited licensed” process.The current law only allow six renewals of a limited license (R 338.2947), which coupled with the examination issues has caused hundreds of Michiganders to leave the social work profession and many of the jobs across the state

   2. This change would also clear up confusion that occurs with billing/reimbursements, as well as make interstate reciprocity more consistent