NASW Statement on ASWB Exam Pass Rate Analysis

Standardized tests are as biased as the people who create them.  Ethical social work practice requires each practitioner and organization to strive toward cultural humility and competence.  The highest level of care incorporates individual and community culture in healing practices.  Social work is a unique profession that requires mastery of a complex skill set including problem solving, investigation, assessment, analysis, written and verbal communication, and an understanding of how culture impacts human behavior.  The ASWB exam pass rate report highlights how this standardized test has failed to capture the competence of all social workers by not centering the diverse cultures of those who take the test and recognizing their diversity is the strength of the profession.

For the full NASW statement on ASWB Exam Pass Rate Analysis, click here.

Modernizing New York’s Social Work Board and Regulations: The Report & Recommendations

Social workers provide the majority of mental and behavioral health services in the country. In New York State there are 61,685 licensed social workers compared to 15,309 licensed psychologists, 9,292 licensed mental health counselors and 1,403 licensed marriage and family therapists.⁠

The number of people experiencing mental health crisis has grown exponentially during the COVID-19 pandemic. In much the same way that medical professionals are the face of the workforce combatting the physical impact of this virus, social workers and other mental health providers are the face of the workforce combatting the mental health impact of this worldwide tragedy. Social workers are trained for this type of work and are here to answer the call. ⁠

It is imperative that social workers in New York have the ability to navigate the licensing process quickly and easily. Currently, New York has one of the most complex set of regulations for social work licensure in the country. Over the last two years, social workers across the state have contacted NASW-NYS for support obtaining their licenses from the New York State Education Department Office of Professions (NYSED). Social workers reported poor customer service, difficulty obtaining their licenses, and multiple obstacles with inter-state reciprocity. As a result, NASW-NYS is recommending changes to improve the process of licensing the social work workforce. ⁠

We invite you to read the report, and participate in the upcoming Town Hall on Modernizing New York’s Social Work Board and Regulations taking place September 19 at 6pm EST. NASW-NYS leadership and staff will provide an overview of the report, updates on movement with NYSED, and engage in transparent conversation about how we plan to move forward. Just as the report was developed with the input of social workers and members across the state, our advocacy must include feedback and guidance from social workers with direct practice experience.

To read the report, click here. 

To register for the Town Hall, click here. 

2022 Legislative Session Report

Chapter supported legislation that passed in the 2022 legislative session 

  • A6008E/S5301A: Article 163 Professionals Legislation.

The legislation establishes clinical experience requirements for certain mental health practitioners and other mental health professionals and authorizes designated professionals to make assessment-based treatment plans and other related provisions, issuance of a privilege to diagnose and develop assessment-based treatment plans including issuance of a privilege to diagnose and develop assessment-based treatment plans the following requirements were established as noted below:

  • be licensed and registered as a mental health counselor, marriage and family therapist, or a psychoanalyst in the State.
  • verify the completion of a sixty-semester hour Master’s degree or higher that includes at least twelve semester hours or clock hour equivalent of clinical courses.
  • persons who have received a Master’s during which they did not complete the required hours must have completed at least two thousand hours of supervised, direct client contact that shall include, but not limited to, diagnosis, psychotherapy and the development of assessment-based treatment plans. 

A6678E/S1046E: John R. Lewis Voting Rights Act of New York.

The following provisions include:

  • establishes rights of actions for denying or abridging the right of any member of a protected class to vote;
  • provides assistance to language-minority groups;
  • provides for preclearance of certain voting policies along with other related provisions.

Telehealth Parity: Telehealth Parity has been included in the NYS 2022-2023 FY Budget.

 

Chapter supported legislation that did not pass this legislative session, 2022.

Listed below are legislations the chapter supported but did not pass in the 2022 legislative session.  The commonality of these legislations is that they were referred to committees, however, they were not voted on within the committee during the session.  This means that for the respective legislations to be activated in the 2023 legislative season, it will need to be reintroduced by a legislative sponsor from both the Assembly and Senate and be reassigned to a committee for subsequent review and passage before being placed on the floor calendar for each chamber.

A217/S2736: Maternal Health: C Section.
The legislative intent is to assure maternity patients are informed about the risks associated with cesarean section prior to undergoing the procedure. The specific provisions include:

  • Every maternal health care provider shall provide written communication prior to delivery to each pregnant woman for whom a cesarean section delivery is planned.
  • Every maternal health care provider who performs a cesarean section which was not planned prenatally shall provide written communication to the patient following delivery which shall include, but not limited to, information on:
    • potential maternal injuries associated with cesarean delivery and potential risks to the fetus.
    • the impact a cesarean delivery may have on future pregnancies and deliveries.
    • circumstances in which cesarean delivery may be necessary to save the life of the mother or fetus.
  • The Commissioner of Health shall ensure that all information included in the written communications is maintained and updated to reflect current clinical guidelines.

This legislation passed in the Assembly on 1/25/22.  However, although assigned to the Women’s Issues Committee in the Senate there was no further legislative action, hence the bill did not pass in committee.

A2348/S3979C: End Predatory Court Fees.
The legislative intent is to eliminate court surcharges and fees and probation and parole surcharges and fees.   Specifically, it requires that a parolee or releasee receiving a merit termination of sentence be financially able to comply with an order of restitution; that a person receiving a discharge of sentence be financially able to comply with an order of restitution and the payment of certain surcharges or fees.  The legislation is divided into six parts, namely:

(Part A); prohibits mandatory minimum fines for penal law and vehicle and traffic offenses; (Part B); mandates that courts engage in an individualized assessment of a person’s financial ability to pay a fine prior to imposing a fine (Part C); eliminates the availability of incarceration as a remedy for a failure to pay a fine, surcharge, or fee, lifts and vacates existing warrants issued solely on a person’s failure to timely pay a fine, surcharge or fee and ends existing sentences of incarceration based on such failure (Part D); vacates existing unsatisfied civil judgments based on a person’s failure to timely pay a surcharge, or fee (Part E); prohibits the collection of a fine, restitution or reparation from the funds of an incarcerated person; prohibits the payment of court fines, mandatory surcharges, certain fees, restitution, reparation, or forfeitures from the earnings of prisoners (Part F); vacates existing unpaid surcharges, DNA databank fees, crime victim assistance fees, sexual offender registration fees, supplemental sex offender victim fees, or probation or parole supervision fees.(Part G); repeals certain provisions of law relating to restrictions on remitting such fees.

The legislation was assigned to Code Committees in the Assembly and Senate.  It was not assigned to a committee in both chambers for legislative action.  The chapter gave supporting testimony for passage of this bill.  (Please see…copy of the testimony)

 

A5019/S1969: Mental Health Professionals in NYS School Districts
School health and mental health services shall be provided by each school district for all students attending the public schools in this state, except in the city school district of the city of New York. School mental health services provided by licensed or certified school social workers shall mean the several procedures and services including, but not limited to, assessments, evaluations and psychosocial intervention plans that are designed to prevent and intervene to address mental, social, emotional, behavioral, developmental, and addictive disorders, conditions, and disabilities of the psychosocial aspect of illness and injuries experienced by the child.

NASW-NYS collaborated with Senator Jackson’s office in writing an op-ed

 

A4331/S1991: Eliminating Qualified Immunity
An act to amend the civil rights law, in relation to providing a civil action for deprivation of rights. A person or public entity acting under color of law that subjects or causes any other person to be subjected to the deprivation of any rights, privileges, or immunities secured by the federal or state constitution or laws, is liable to the injured party for legal or equitable relief or any other appropriate relief.

The legislation was assigned to the Judiciary Committee in the Assembly and the Investigations and Government Operations Committee in the Senate.  In both chambers the bill did not pass in committee.

 

A00306/S00794: Anti-Torture Bill
Prohibits participation in torture and improper treatment of incarcerated persons by health care professionals; prohibits a health care professional from engaging, assisting, or planning the torture or improper treatment of an incarcerated person; and requires health care professionals to report torture and improper treatment.

The legislation was passed in the Health Committee in the Assembly; however, it did not move off the full Assembly’s Floor Calendar for a vote.  In the Senate, the bill was not voted on in the Health Committee

 

A3873/S6264: The establishment of caseloads standards for preventative services caseworkers

Establishes regulations in consultation with local social services districts, relating to caseload standards for preventative case planning services. Such standards shall be no more than twelve families per full-time preventative case planning services caseworker per month.

The legislation was not passed in Ways and Means Committee in the Assembly and the Social Services committee in the Senate

The Chapter also received requests from the Governor’s office to comment on legislation that was on the Governor’s desk for signature.  Our comments are briefly presented below:

 

S6300C: Edit recommendations

    • Include advance care planning for this population as it is often neglected due to the stigma. Advanced care planning is defined as offering each consumer, that is deemed to have decisional capacity, the opportunity to complete a health care proxy. Additionally, utilizing pro bono attorneys offer to assist with completing a durable power of attorney and a will.
    • Change language within the bill to the following: 1) change “combat”, which is in the war paradigm, to potential synonyms as “rectify, eliminate, transform;” 2) change “accomplishments.” This term connotes having achieved a predetermined standard, however, who will be determining what that standard is? We suggest using language that emphasizes the roles, activities, and personal successes within the larger communities in which they reside

 

S7752: Edit recommendations

    • That a licensed social worker from an underserved (Black and Brown community) perinatal center also serve as a member on this committee.
    • Include a representative from SAMHSA (Substance Abuse and Mental Health Services Administration) on the committee to address possible associated addiction

A7661: Edit recommendations

      • Line 5: There may be disparity between various locations. The criteria that are used for counties, cities or towns may vary.
      • Line 7: The wording “his territory” can either be replaced by “his/her territory” or “their territory”.
      • Lines 8-13: This section should include guidance on what else can be included in making the decision regarding childcare services. What do they rely on as the criteria for determining care? Leaving this section open-ended can lead to inappropriate determinations for childcare.
      • Lines 17-19: Who makes the determination of a reasonable fee? The impact may be more beneficial if the policy includes the process to determine the ability to pay for the individuals seeking childcare

 

A8386A: Edit recommendations

    • The word privacy should be defined by the legislation.
    • Language should be added that states actions to ensure privacy

 

A9080A: Edit recommendations:

    • Section 1: The study should not be restricted to the state agencies’ processes, policies, and recorded data. A complimentary study from the side of the families and perhaps those youth who are of age to be able to participate in a research undertaking should also be included. Since the study will be led by the commissioner of the office of children and family services, in consultation with the commissioner of the office for people with developmental disabilities, what steps will be taken to reduce bias in the reporting?
    • Adding in Section 1 (d): assessing if the children in foster care with a developmental disability are receiving appropriate services to address the symptoms of their diagnoses.
    • Adding Section 1 (e): assessing if children in foster care that will not be capable of living independently have a transition plan prior to aging out of care.

 

A10165: Edit recommendations:

    • The legislation should define what constitutes “public official.” Also, if there is a decision-making hierarchy whereby the final determination ends at the program staff level, this should be clarified in the legislation.
    • The due date for response to the re-engagement correspondence be changed from 10 days to a response time between 20-30 days. The 10-day limit does not consider the rapidity of mail be placed in a recipient’s mailbox, placed in the wrong mailbox, nor such factors as the mailbox may be destroyed and/or tampered with resulting in the recipient not receiving the correspondence in a timely manner. Also forwarding only one correspondence is insufficient in such a situation whereby a person could lose the articulated benefits. We recommend at least two mailings occur prior to the cut-off of appeal date.
    • In the re-engagement correspondence, the exemptions need to be clearly delineated starting with the meaning of an exemption followed by a listing of all exemption categories. This offsets the potentiality of variance amongst different localities having authority to be flexible in their decision-making. If a particular circumstance is requested to be an exemption, but that circumstance does not correspond to the listing in the legislation, a process is noted in the legislation on how such a circumstance is to be addressed for final determination. We also recommend that the re-engagement correspondence identifies a contact person and their contact information, who can explain the correspondence and the associated exemptions to assist the recipient in making an informed decision.
    • Change “plain language,” which is vague, to “fourth-six grade reading level.” For example: while it may be understood by those reading and administering the legislation the descriptor “conciliatory conference,” it will not be a term familiar to some persons who wish to activate the re-engagement process.

 

S6287C: To strengthen the legislative provisions, we propose adding that the provision of information is documented in the medical record or supporting file, which includes the signature of the patient indicating that they have received an explanation and relevant patient information.

S7107B: We believe this bill is very comprehensive and addresses all aspects of supportive agreements between the clients and human service agencies. We are pleased that this bill is designed to protect individuals with intellectual, developmental, cognitive, and psychosocial disabilities.

We supported the legislation listed below without additional comments:

A9749B; A2150A; A2263; A6266A; A7652; A9344A.

We are hiring! | Program Coordinator at NASW-NYS

NATIONAL ASSOCIATION OF SOCIAL WORKERS
JOB DESCRIPTION STATEMENT 

TITLE:   Program Coordinator                                 POSITION STATUS: Full-Time
DEPARTMENT:  NASW-NYS
REPORTS TO: Chapter Executive Director              PAY LEVEL: $50,000- $62,000 plus bonus pay dependent on Chapter finances
FLSA STATUS: Exempt
Location: NYS, Hyrid work option

  1. MAJOR FUNCTIONS:

Under the strategic direction of the Chapter Executive Director, the Program Coordinator oversees all aspects of the Chapter’s continuing education trainings, social justice initiatives, and other professional development programming.

The Program Coordinator works closely with the Chapter Executive Director, Director of Operations and Development, Business Operations Manager, Executive Assistant, and Chapter interns.

BASIC DUTIES AND RESPONSIBILITIES:

  1. Manages and implements all aspects of curriculum development, delivery coordination, registration policies, certificate distribution, and evaluation of live and self-study continuing education and conference programming including working with other NASW stakeholders.
  2. Ensures compliance with New York State Education Department Continuing Education provider requirements as they pertain curriculum review and approval, delivery, evaluation, and recordkeeping.
  3. Develops and implements community engagement programs to support the Chapter’s membership and social justice initiatives.
  4. Manages the program evaluation for continuing education with yearly reports.
  5. Creates content to assist with the development of all marketing and promotional materials for Chapter events.
  6. Serves as staff liaison to the Student Leadership Committee.
  7. Collaborates with Chapter Executive Director or work-related projects and other related initiatives.

III. MINIMUM WORK REQUIREMENTS: 

Skills:

  1. Excellent verbal and written communications skills, including the ability to make presentations to a wide variety of audiences.
  2. Ability to lead and collaborate in a complex environment with multiple competing priorities.
  3. Ability to manage time effectively.
  4. Ability to plan, organize, and manage a wide array of business-related services.
  5. Ability to establish and maintain cooperative business relationships and to build credibility and trust throughout the organization.
  6. Strong problem identification skills, including the ability to problem solve and generate creative solutions, exercise common sense and sound judgment, and make effective decisions based on accurate and timely analyses.
  7. Detailed oriented and the ability to think critically.

Knowledge:

  1. Master’s degree in Social Work or a related field.
  2. MSW, LMSW, or LCSW preferred.
  3. Technical proficiency including VOIP phone system, Microsoft Suite, cloud-based document storage, Zoom, organizing data, etc. Learning management system experience a plus.

Experience:

  1. Minimum of 2-5 years of related work experience, preferably at a professional association and/or nonprofit setting.
  2. Minimum of 2-years’ experience and responsibility for organizing events, program development, or similar activities.

ATTRIBUTES

  1. Results driven: The Program Coordinator sees the big picture, assists with the development and monitoring of key performance metrics to produce the desired results.
  2. Strong business acumen: The Program Coordinator sees opportunities and emerging trends, and is knowledgeable about the operations, unique needs, and goals specific to member-driven, not-for-profit organizations.
  3. Firm and fair leadership: The Program Coordinator will work with a wide range of staff, colleagues, and members, requiring a firm, fair, and flexible style that both complements the efforts and supports the needs of others.
  4. Partnership: This individual is able to build trust internally and externally and must be viewed as highly professional, discreet, and accountable.
  5. Organizational agility: The Program Coordinator has a thoughtful, respectful communication style that fosters an open environment, enabling thought-provoking discussions and collaborative decision making.
  6. Perceptive:  The Program Coordinator is creative and intuitively recognizes opportunities and takes appropriate action.

================================================================

To apply: Send resume and cover letter to info.naswnys@socialworkers.org with subject line ‘Program Coordinator’. Writing sample is also encouraged.

This document describes general job duties and responsibilities.  It is not a complete listing of job duties.  Further clarification should be obtained from the supervisor listed above (e.g. Work plans, performance standards, task lists etc.).  Incumbents may be required to perform tasks related to these duties.  Major changes in job duties should be incorporated in this description.

NASW is an equal opportunity employer. All applicants will be considered for employment without attention to race, color, religion, sex, sexual orientation, gender identity, national origin, veteran or disability status.

 

 

License Master Social Work – Scope of Practice Alert

License Master Social Work – Scope of Practice Alert

Over the last year, the New York State office of the National Association of Social Workers (NASW-NYS) received numerous complaints about Licensed Master Social Workers (LMSWs) practicing outside their scope of practice.  While NASW-NYS is not the regulating body of licensure for the state, our mission includes strengthening the profession.  In order to strengthen the profession, it is essential that all social workers understand and work within their legal scope of practice.  LMSWs are not clinical social workers.  Clinical social work services (diagnosis, psychotherapy, and assessment-based planning and treatment) are not within the LMSW scope of practice.  According to the Regulations of the Commissioner, §74.6 and Education Law, Article 154, § 7704, LMSWs are only allowed to practice clinical social work under the supervision of a Licensed Clinical Social Worker (LCSW or LCSW-R), licensed psychologist, or board certified psychiatrist. The clinical supervisor is legally and professionally responsible for clients seen by an LMSW.

According to the New York State Office of Professions, clients seen by LMSWs should receive informed consent that the social worker will be supervised by an approved clinical professional. “It is the responsibility of the supervisor/employer to ensure that patients are informed the licensed master social worker (LMSW) is only authorized to practice clinical social work under supervision. The client should understand that the supervisor is responsible for the diagnosis and practice of the LMSW. The LMSW shares with a qualified supervisor information about the diagnosis and treatment of each client and the supervisor is professionally responsible for the services provided by the LMSW. The client should be provided with the supervisor’s contact information so the client can share any concerns or questions about the LMSW’s practice with the supervisor.”

LMSWs are not allowed to establish a private practice or professional entity for the purpose of providing clinical social work services.  This type of practice is outside the scope of practice for LMSWs.  According to Education Law, Article 154, § 7701, LMSWs can only practice clinical social work under appropriate supervision in a facility setting or other supervised setting approved by the New York State Education Department.  The following private practice entities must be approved by the department:

  • A professional corporation, professional limited liability partnership or professional limited liability corporation that is authorized to provide services that include psychotherapy;
  • A professional service corporation, registered limited liability partnership, or professional service limited liability company authorized to provide services that are within the scope of practice of licensed clinical social work;
  • A sole proprietorship owned by a licensee who provides services that are within the scope of his or her profession and services that are within the scope of licensed clinical social work;
  • A professional partnership owned by licensees who provide services that are within the scope of practice of licensed clinical social work;

LMSWs working in an approved private practice setting must be employed by the owner (receive a W-2) and receive appropriate supervision.

Social workers practicing outside of their scope of practice are subject to professional discipline. The New York State Board of Regents supervises the disciplinary proceedings for all licensed professionals, which are conducted by the New York State Education Department’s Office of Professions.  Licensed professionals practicing outside of their scope are subject to censure and reprimand, fines, suspensions and/or probationary terms.

To ensure you are practicing within your scope of practice, all social workers should review the following webpages.

File a Complaint || CareDash and BetterHelp Update

CareDash and BetterHelp — Disturbing Practice

CareDash acts as a healthcare review website for a wide variety of providers, including clinical social workers, providing information on patient reviews, disciplinary actions and other issues. According to its website, CareDash “is a solution for patients looking for transparent and trustworthy information about healthcare providers, practices and hospitals in their area.”  BetterHelp, according to its website, is the largest online therapy platform worldwide. The site states that BetterHelp matches individuals with therapists that fit their objectives, preferences and issue areas. 

As many of you already know, CareDash has created and posted on its website  profiles of thousands of clinical social workers around the country — without their knowledge or consent. (The profiles are created from public records, including NPI records.) It has done so for the purpose of driving prospective clients of these therapists to BetterHelp for referrals to other therapists who are participating providers with BetterHelp, or to CareDash itself for referrals to its participating therapists. 

The process works as follows: when searching for a specific therapist on CareDash.com, after selecting that therapist and clicking on “check availability,” the website automatically provides the prospective client with the following message: “[The desired therapist] has not provided a way to schedule online through CareDash. However, you could get connected with an online therapist or chat with our virtual assistant to get help finding a therapist.” 

Just below that message, the prospective client is offered the option to select from one or more alternative therapists – who participate with either CareDash or with BetterHelp.  Or, the individual may choose to chat with CareDash’s virtual assistant. If choosing the virtual assistant option, the prospective client is automatically directed to a page where only BetterHelp’s participating providers are listed. The website notes that CareDash may receive commissions when the consumer chooses one of these providers.

This practice has multiple harmful effects on both the therapist and prospective client. For details, see the description of concerns in the discussion below on filing a complaint. Although public information on therapists is used in creating the profiles, this appears to be an improper deceptive practice. It potentially violates federal and/or state consumer protection laws.

Filing a Complaint

Overview

If CareDash has created a profile of you and posted it on their website without your consent, we suggest you consider filing a complaint with the consumer protection division of the state attorney general’s office. Click here to find the link to the state’s office and its complaint form. You may also choose to file a complaint with the Federal Trade Commission. (It is your choice whether to file with only one or with both of these agencies.) The FTC’s complaint form can be found here. 

Both the state attorney general and the FTC are authorized to investigate apparent scams and deceptive business practices such as this one, pursue a voluntary resolution and, if necessary, bring enforcement cases. 

Note that it is not entirely clear whether this practice violates state or federal law, although NASW believes it likely does. Even if the practice is illegal, there is no guarantee that either of these agencies will investigate a complaint or ultimately require CareDash and BetterHelp to discontinue the practice. 

However, the more complaints filed, the greater the likelihood that these agencies will act. Please review the state attorney general website for more information on its authority and complaint process; for more information on the FTC’s authority and complaint process, see their FAQs.

Again, you should only file a complaint if CareDash has posted your profile without your consent. Please go to www.CareDash.com to confirm whether that is the case. If so, you should note any inaccurate information contained in the profile and the improper posting of personal information (such as home address or phone number); these points can be included in your complaint.  

What to Include in Your Complaint

The following information may be included in both your state attorney general and FTC complaints (note that when starting to complete the FTC’s complaint form, one is prompted to choose a problem category; we suggest you select “Health” and the subcategory “Any other health care problem”):

  • Name of companies to complain about – CareDash and BetterHelp. Note that the FTC form allows only a reference to one company; include only CareDash for the FTC complaint.
  • Companies’ location: CareDash’s corporate office address is: 614 Massachusetts Ave., Ste 400, Cambridge, MA 02139. BetterHelp’s corporate office address 990 Villa Street, Mountain View, CA 94041.
  • Prior attempt(s) to resolve the issue: If this information is requested in the complaint form, indicate whether you have called or emailed either company to complain about this practice, provide the date of the contact(s) and describe your efforts. Also note the identity of the representative with whom you communicated and the date and a description of any response provided.
  • Description of the practice and concerns: the following is a general description of the practice and its impact – feel free to use this a guide, modifying the description in your own words, as appropriate (of course, only include the statements noted below that apply to you personally): 

CareDash, a healthcare provider review website, has created and posted on its website my profile as a therapist. It has done so without my knowledge or consent. I believe the purpose of this posting is to drive my prospective clients to BetterHelp, an online therapy platform, for referrals to other therapists who have agreed to participate with BetterHelp, or to therapists who participate with CareDash itself. I am not a participating provider with either CareDash or BetterHelp; therefore, it is impossible to seek my services through these providers.

The process works as follows: when searching for a specific therapist on CareDash.com, after selecting that therapist and clicking on “check availability,” the website automatically provides the prospective client with the following message: “[The desired therapist] has not provided a way to schedule online through CareDash. However, you could get connected with an online therapist or chat with our virtual assistant to get help finding a therapist.” 

Just below that message, the prospective client is offered the option to select from one or more alternative therapists – who participate with either CareDash or with BetterHelp.  Or, the client may choose to chat with CareDash’s virtual assistant. If choosing the virtual assistant option, the prospective client is automatically directed to a page where a selection of only BetterHelp’s participating providers is available. The website notes that CareDash may receive commissions when a consumer chooses one of these providers.

This practice misleads or deceives individuals who may be seeking to engage me as a therapist. That is, CareDash is falsely marketing my services to generate online traffic for BetterHelp or itself, ultimately resulting in the selection of BetterHelp’s participating providers or its own, rather than me.

CareDash’s diversion of my prospective clients in this way interferes with my business. This amounts to a misappropriation of my name and reputation for commercial gain. 

Additionally, the practice harms the direct consumer of therapy services: a client who is seeking my services is the victim of a bait and switch scheme. In being diverted to BetterHelp or CareDash providers, they may be routed to a provider who cannot meet their needs.

[INCLUDE THE FOLLOWING PARAGRAPH ONLY IF IT APPLIES TO YOU] Further, the posted profile is incomplete and contains erroneous information, misrepresenting my practice areas. It also contains personal information. I am very concerned about this misrepresentation because it misleads potential clients and may implicate my ethical duties as a licensed therapist.

CareDash’s website (see last FAQ for Doctors) states that it will not take down postings of providers. Specifically, they say, “Because the information listed on CareDash profiles is of interest to the general public, CareDash’s policy is that we do not, under any circumstance, remove a profile.” Accordingly, I do not have this option available to address my concerns.

I understand this practice extends to other types of mental health care providers, including psychologists.

Thank you for your attention to this matter. I look forward to hearing from you.