Thinking out loud here: I believe that this detail (34 CFR 668.16 (r) was initially crafted to address the issue of "business" & commercial internships, whose completion were required for conferment of degrees, but otherwise had no academic measures or oversight and were often seen as unpaid but requisite "hoops" to be jumped through. Social work internships are (supposedly) different as they are (supposedly) linked directly to academic oversight, standards, measures, experiences and outcomes.
I infer the (supposed) detail as it seems increasingly common that many BSW & MSW students, particularly in placements of distant / remote proximity to their online programs, are receiving extremely little in the way of academic guidance in finding and arranging appropriate placements and consequently in receiving appropriate academic oversight or supervision. (CONTRARY to the notion of our "signature pedagogy" and practices described in our EPAS.) So perhaps this policy IS (potentially) relevant.
The issue of admitting students to our professional programs who, for any variety of reasons, may not be able to complete an appropriate and qualified field learning experience, has LONG been an issue. An ethical issue that we as both social workers and faculty must address and acknowledge.
The detail of admitting more students to our programs than we can realistically place is becoming a larger problem. Bigger is not always better. The CSWE once sought to limit accredited programs that were in close proximity to one another and with overlapping field settings. That notion has apparently gone away. But the notion of overlapping market (getting students) and service areas (for placing students in agencies,) is now complicated by online programs accepting students who live in distant communities. Distant communities about which the university may have very little familiarity with social, ethnic, cultural, & geo-political nuances, let alone the availability of appropriate and accessible field placement opportunities.
These are all issues that the CSWE really need to be paying attention to.
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Gary Bachman
Associate Professor
Park University
Parkville MO
816-584-6504
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