Comments on Nursing Home Staffing Ratio Proposed Regulations

Tracking Number PR2022-032

The National Association of Social Workers, CT Chapter representing over 2,300 members supports the proposed revisions to the state regulations for Social Work in nursing homes. The proposed language accurately states the changes passed by the CGA in Public Act 21-185. We urge that the revised language be adopted as proposed.

The state regulations for social work are ancient going back at least 30 years. Since the regulations are being updated, we offer the following recommendations for bringing the regulations to current practice:

1. Under Definition eliminate the Social Work Designee where ever referenced. The designee allowed persons without a social work degree to practice social work in a nursing home with consultation by a Qualified Social Work Consultant. The designee grandfathered in persons practicing nursing home social work without the social work degree prior to January 1, 1989. It is time to eliminate the designee position. Having it in the regulations only confuses who is now eligible to be employed as a social worker in a nursing home.
2. Under the definition of Qualified Social Worker eliminate the language “An individual who has a bachelor’s degree in a field other than social work and a certificate in Post Baccalaureate Studies in Social Work awarded before the effective date of these regulations by a college accredited by the Department of Higher Education, and at least one year social work experience in a health facility, may perform the duties and carry out the responsibilities of a qualified social worker for up to three years after the effective date of these regulations’. (italic added). Again, this is ancient language that references the pre-effective date of the existing regulations. Furthermore, there has never existed a Post Baccalaureate Studies in Social Work offered in Connecticut’s colleges/universities.

 The Qualified Social Work Consultant seems unnecessary given that nursing homes are now required to hire only baccalaureate social workers (BSW) or master social workers (MSW) as defined in the definition of Qualified Social Worker.

We encourage the Department of Public Health to take this opportunity to fully update the state regulations for nursing home social work, rather than simply adding the updated staff ratio language of which we support.

Thank you for consideration of these comments.