Social Work and Coaching: Navigating Legal and Ethical Lines

By Paul R. Pace

As social workers increasingly start coaching businesses for extra income or to practice beyond the limits of their professional license, experts stress the necessity of understanding where social work practice ends and unregulated coaching begins.

The fundamental issue lies in the blurring lines between licensed therapy and unregulated coaching, says NASW Deputy General Counsel Ashlee Fox, JD, MSW.

She notes that coaching at its core is non-clinical, goal-oriented, and future-focused. It involves performance, skill-building, action, and accountability, and is not meant to diagnose or treat mental health conditions, process trauma, or manage symptoms of disorders.

Therapy, by contrast, involves the assessment of emotional, behavioral or psychological functioning; clinical interventions; exploring trauma and past experiences; developing treatment plans; managing risk; and addressing diagnosable conditions, symptoms, and disorders, Fox points out. Therapy is strictly regulated by statute, by state licensing boards, and by professional codes of ethics, and providers must be licensed in the state where the client is located.

“Anyone can be a coach,” Fox said during her presentation of the NASW Legal Defense Fund webinar, “The Coaching Conundrum: The Legal Implications of Coaching for Social Workers.” “(Coaching) does not require a license or certification. And there are some programs and certificates that you can get as a coach, but it’s not required.”

Social workers most often run into trouble when their coaching activities look like therapy. This inadvertent clinical practice can lead to a licensed social worker practicing without a license across state lines, Fox explains.

High-risk coaching areas for licensed social workers include:

• Life coaching that focuses on emotional function and identity.
• Wellness coaching dealing with stress, burnout and mood regulation.
• Trauma-informed coaching, relationship coaching, emotional regulation coaching, mindset coaching, inner child work, or anything promising emotional healing.

The central legal concept is that licensing boards focus on the function, not the title. Calling a service “coaching” does not protect the practitioner if the work involves clinical-level activities, such as:

• Processing trauma histories
• Teaching clinical-level coping skills for anxiety, depression or PTSD
• Explicitly using therapeutic modalities like CBT-informed coaching or somatic coaching
• Relying on professional credentials (like LCSW) in marketing to build public trust.

A licensing board has the authority to review any conduct that violates a licensee’s legal or ethical responsibility, and if the work is reasonably perceived by the public as counseling, therapy or mental health treatment, the board is likely to intervene, as their primary role is to protect the public.

For social workers who choose to pursue coaching, a safer approach looks like:

• Being familiar with your state licensing board’s regulations, including how the scope of social work is defined.
• Using clear written disclaimers that coaching is not therapy and not a substitute for mental health treatment.
• Avoiding clinical language in marketing and actual work.
• Establishing a well-defined scope of service that limits you to skills, performance or goals, with no emotional processing.
• Using separate coaching agreement and informed consent documents that are distinct from any therapy paperwork.
• Knowing the laws of the states where clients are located.
• Having a robust referral plan for when a coaching client presents with mental health needs.

These strategies do not eliminate all risk, but they demonstrate that you’re thinking intentionally and ethically about your role, Fox says.

“The Coaching Conundrum: The Legal Implications of Coaching for Social Workers” is available as self-study at NASW’s online CE Institute.