Licensure: Seems like it should be simple enough...

One of the issues that feels like a road block for me is obtaining licensure. Typically, in this day and age, we obtain our license over three years (at least in my former state, and my current one) at an agency. New York State now actually requires this - i.e., you can't hire a supervisor to supervise you outside of an agency setting, so there is no way to open a private practice until you work for three years in "psychotherapy setting"; then you take the test and get an LCSW (Licenced Clinical Social Worker), which allows you to practice privately, or not. This is a controversial issue - at least it was when I got my MSW - but I won't go into it now. Currently I am living in Washington State, and I want to get my LICSW (Licensed Independent Clinical Social Worker). I have two years of experience in New York that I want to transfer, then I have to get the rest of the hours completed, take the test, and I'm done! In the mean time, I have to be a "licensed social work associate-advanced clinical" (which is just a terrible string of words) in order to practice. The "Associate" essentially means "Under supervision".

My original plan was to go the standard route - get a job in an agency and work for another year or so to complete my 3 years. However, I haven't gotten a job in the last few months, and I can't just wait around going broke, so I'm starting a private practice without my LICSW (hence this blog). This is perfectly legal in Washington, as long as I am under the supervision of an LMHP (Licenced Mental Health Professional) who is an approved supervisor. (Note: Washington has two types of SW licensure: LICSW, and LASW, but for the life of me I don't know why LASW credential exists; maybe a reader can illuminate me in the comments... Meanwhile, everything I write applies to LICSW, which is what you need to practice privately.)

Okay, that should be simple enough, and maybe it will be, but I'm having a hell of a time parsing the law to figure out what, exactly I need to do. First, let's take a look at the relevant legislation (with my highlighting):

(2) The following are the supervised postgraduate experience requirements for the social worker applicant's practice area:

     (b) Licensed independent clinical social worker. Successful completion of a supervised experience requirement. The experience requirement consists of a minimum of four thousand hours of experience, of which one thousand hours must be direct client contact, over a three-year period supervised by a licensed independent clinical social worker, with supervision of at least one hundred thirty hours by a licensed mental health practitioner. Of the total supervision, seventy hours must be with an independent clinical social worker; the other sixty hours may be with an equally qualified licensed mental health practitioner. Sixty hours must be in one-to-one supervision and seventy hours may be in one-to-one supervision or group supervision. Distance supervision is limited to sixty supervision hours.

[Pause; let's discuss]

I've color-coded the relevant requirements, and will parse each one below:

• Green: Minimum of 4,000 hours of experience - This should be fairly simple: If I work at an office, 40 hours per week, I will accumulate 4,000 hours of work experience in 100 weeks, or about two years (counting staff meetings; chatting at the water cooler; and surfing the net in my office). What, though, does 'experience' mean for some one working as a private practitioner under supervision? What do I count for hours? If I count just client contact, I need to have a very full load of clients. Can I also count planning? Scheduling? Administration? Paperwork? Who knows? And, maybe more importantly, who decides? 
• Blue: 1,000 hours of direct client contact - This is pretty clear too. I essentially need to sit down, face-to-face, with clients, for 1,000 hours - more or less, have 1,000 sessions with clients. Okay.
• Yellow: Over a three year period - I THINK this means that I can't cram all 4000 experience hours and all 1000 client contacts into a whirlwind 18 months and get my license, the presumable, and understandable, rationale being that I would be so overworked that I would not learn much or do much, and that it takes three years of growth to get to the point where you can do things on your own. But I could be wrong in my interpretation. "Over a three year period" could mean I have to get all my hours done within a three year period. Hmmm...   
• Orange: Supervised by a LICSW - This seems to suggest pretty clearly that during all 4,000 hours of experience, all 1,000 hours of client contact, and all three years, I must have an LICSW as a supervisor. Right? Well, look at the next section...
• Purple: With supervision of at least 130 hours by a Licenced Mental Health Practitioner; of the total supervision, seventy hours must be with an independent clinical social worker; the other sixty hours may be with an equally qualified licensed mental health practitioner. ["Licensed mental health practitioner" (LMHP) is a more general term that includes licensed psychologists, psychiatric nurses, psychiatrists, marriage and family therapists, etc.] Wait a minute... I thought they just said all of my 3 years and 4,000 hours needed to be supervised by an LICSW? So what the point of saying that some of my supervised hours can NOT be under a LICSW?

This last point isn't just a technicality: I have received some good recommendations for supervisors, but they have MAs, not MSWs. I don't want to find out, after applying, that, ooops, no, those hours do not count! So how can I be sure? (my concern may be prompted by my experiences in New York, where some SWs I knew worked three years at agencies, only to find out that the work they were doing did not count as "psychotherapy" (it was school psychology, or case management) and they had to start from scratch. (Just to make clear, I don't think licensure requirements should be loosened; I only wish it were more clear what was required).

All this is to say that I've been pretty confused, but I haven't found any info online that would help me. Even the otherwise very helpful Counseling Seattle website just cuts and pastes the laws; as does the Washington State chapter of the NASW (seriously, WA NASW, you could really enhance your website - these laws you list are "drafts" from 10/04 - that's seven years ago - and you list "new sections" and "amendatory sections" in a way that doesn't make sense. This isn't convincing me to get a membership anytime soon. How about a few useful FAQs?)   

Anyway, the point of all this is that I couldn't find the info so I contacted the DOH directly. When I get answers to my questions, I will post them here, on this blog, so that future social workers don't have to wonder the same questions I'm wondering.