Kathleen Mills Public Comments 5-1-26
I'm Kathleen Mills LPC-S and co-founder of AMHP.
Our legacy professional organizations are publicly encouraging their members to ignore State law and the TX AG’s Opinions. A formal Coalition of professional organizations is openly encouraging their members to break the law and risk the loss of their licenses. The ACA and their state chapter, TCA, are doing so on their websites and through their proposed 2026 Code of Ethics.
Conflict of Interest?
If you're a Professional Member of any BHEC Board and you belong to the ACA then you are by association supporting their illegal directives, playing host to what should be for you a very uncomfortable conflict of interest. You’re required to obey State law but your professional organization is asking you through your membership to ignore and break those same laws. While it’s not illegal to be a board member and belong to a professional organization, I want to call on each and every one of you who find yourselves in that situation to publicly resign your ACA/TCA membership and call them out on their hypocrisy and criminal activities.
If you're a Public Member of any of the BHEC Boards you have an admittedly uncomfortable duty, but it's why you're here; to call out your Professional Member colleagues on this point and I urge you to do it today.
On Enforcement Duties for Licensee Activities
Every licensee-applicant signs a document that clearly states two things:
- That the applicant has read and understands the rulebook, (which they have not), and...
- That they agree to abide by ALL of the laws of the State of TX under the threat of penalty including the potential loss of their license.
The ACA has effectively brainwashed entire generations of grad students to believe their Code of Ethics takes precedence over State Law. It does not. Most universities still require a professorial applicant be an ACA Member to even be eligible for an interview! An entitled segment of licensees are right now thumbing their noses at you and the State. We need to start aggressively enforcing the agreement they signed.
Is This Really a Problem?
Two weeks ago I attended a webinar that offered to teach me how to write notes in my EHR to get around state law and AG Opinions on GAC and avoid any trouble with BHEC. I got 3 continuing education hours for learning how to circumvent and break TX law.
Here’s just a few things the speaker said:
- That SB14 only pertains to hormone and puberty blockers and surgeries by medical personnel; that it did NOT apply to mental health professionals. Paxton’s Opinion clearly states otherwise.
- That Paxton’s Feb 2026 Opinion, “does not apply to mental health professionals” and “created more fear over compliance and it does not apply to mental health professionals.”
- She stated the March 3 email from BHEC to all licensees was, “non-binding; just guidance”.
- She claimed that a SW Board member told her that “since SB14 doesn’t apply to MH counselors, BHEC will not be doing anything to enforce it”. She also relied heavily on the footnote in the email on pg 4.
Call-to-Action
I'd like to see the BHEC Council include the appropriate direct references to SB's 12 and 14 as they have been codified, referenced in all four rulebooks along with the relevant line items listed in the Penalty Matrix, including the loss of license. We’re talking about protecting minors from ALL facets of GAC including and especially the concept and elements of “facilitation” by MH professionals which they are choosing to ignore. Clinical members and the legacy associations will not stop until our laws are strictly enforced, and we should all be on board with this.
Thank you.
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