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Commenter urges board to allow supervised hours via 1099 arrangements for undocumented MSWs; requests added to future agenda
Summary
A public commenter asked the Board to expand policies to let undocumented MSW registrants (including DACA recipients) accrue supervised experience through 1099 (independent contractor) arrangements to increase equity and access to licensure pathways.
During public comment on future agenda items, a lecturer at California State University Long Beach urged the Board of Behavioral Sciences to consider revising supervised‑experience rules to allow undocumented master’s‑level social workers—including those with DACA status—to accrue supervised hours under 1099 arrangements.
The commenter said federal work‑authorization limits leave many undocumented MSWs unable to obtain W‑2 employment and therefore dependent on unpaid volunteer roles to accrue supervised hours, which she described as an undue financial burden. She asked the board to consider permitting supervised hours earned under independent‑contractor (1099) arrangements so candidates in this situation could pursue licensure more equitably.
Board response and placement on agenda Board staff said the comment was received as a future agenda suggestion; the chair asked staff to note the request for consideration at a future meeting. No formal action was taken during the May 8 meeting; the board said it may place the matter on a future agenda for study.
Why it matters Allowing 1099 supervised‑hour arrangements could materially affect pathways to licensure for people who cannot obtain W‑2 employment for immigration or other reasons. The board would need to review legal constraints (labor law, supervision rules, and public‑safety considerations) before proposing any change.
Ending note The board recorded the suggestion and will consider whether to add it to a future agenda for policy development; no regulatory or statutory change was approved on May 8.
