Public Comments to LMFT Board 4-5-24
I'm Kathleen Mills LPC-S and co-founder of AMHP, the association for Mental Health Professionals.
Public Comments to LMFT Board 4-5-24
After a personal review of BHEC and the various boards' actions over the past 3.5 years I have come to the following 3 conclusions:
#1. That the BHEC Administrative staff have done an outstanding, herculean job of cleaning up the mess DSHS and the four boards left behind. They get an A+.
#2. We're vastly over-regulated at the Federal, State, and Board levels. We need less regulation, not more.
The various boards and The Council seem to be doing as much as they possibly can to add more regulation to the various rulebooks, with little regard for following existing Sub-Chapter B guidelines in the rulebook for new rule development. Those guidelines were developed to keep frivolous rulemaking from happening so I suppose it's no wonder they get ignored.
For an LMFT you, the board, have arbitrarily decided what 43% of their CE hours should be, even if those requirements do not apply to all licensees or their career paths. For an MFT Supervisor that number skyrockets to 63% of their required ce's.
Trying to Stay Relevant Through Busy Work
Your most recent addition to the requirements, 1 hr of crisis management, is another example of an unnecessary rule proposal that...
a. Didn't follow the Sub-Chapter B rulemaking requirements
b. Used weak, quixotic reasoning for justification, points which were easily reasoned away, and
c. Was passed anyway despite all logical arguments presented and extant solutions (eap networks) to the contrary.
Currently there are no 1-hr crisis management courses available. A counselor will have to take a much more expensive 6 hour course which the industry seems to believe is the minimum acceptable # of hours for competent crisis management education, just to get the 1 hour you're requiring. It would be most helpful if the board would post a public list of where to find these non-existent 1 hr courses you're requiring, but I'm not holding my breath. Do you people even consider the market availability of these courses you make up and require before you pass these rules?? Because that doesn't appear to be the case.
Doubling-Down on Existing Regulation?
Another example of an unnecessary rule is your 2 hr telehealth requirement. HIPAA Standards and compliance already have telehealth protocols in place for all counselors when doing their HIPAA Compliance. Why do we need regulation on this topic at both the Federal and Board levels?? (Surely our licensees are putting their HIPAA Compliance programs in place, right?)
We're looking forward to the Quadrennial Rule Review to address this major concern of over-regulation.
#3. You need to put the licensed professionals back in charge of their own continuing education and finances. Our self-regulation seems to be working very well.
From my experience attending board meetings I don't see much if any consideration given to how much your new rules are going to cost a licensee in order to comply.
"Free ce's" that don't exist or take a decidedly Woke delivery aren't the answer to the problem, nor is suggesting that "no one's keeping you from taking as many ce's as you want to". My pocketbook is limiting that, and that limits my career path.
Anyone running a business knows that business operation costs have gone through the roof in the past 3 years, we have demanding pay scales to address, and compliance issues to perform... all rising in price. That doesn't even take into account that on the personal/retail side of the equation we're all dealing with a real inflation rate somewhere far exceeding the single digit CPI number reported by MSM (probably approaching 18% or more) when you include food and energy in the equation. We don't need you to spend our money for us, we're better equipped to do that than you are.
Out of the 96 MFT complaints filed in the last 3 quarters, all but 23 were dismissed as not worthy of pursuit. There are currently 4676 licensed MFT's. Doing the simple math that means that only 23 out of almost 4700 MFT's received disciplinary action in the past fiscal year. That's .49%, or less than 1% of all licensees. Less than half of 1%. I'd say that's a pretty damn good job of self-monitoring!
So I'm asking you directly.......where's the mandate for more regulation??
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About the Author
Kathleen Mills is a fire-breathing, 33+ year veteran of the counseling world. People react in one of two ways when evil touches their lives: some retreat in fear, and some advance without pause to engage it. Kathleen falls firmly in the latter group. She owns and operates Life Tree Counseling in Frisco, TX, possesses a tireless work-ethic, and eagerly awaits your arrival into her growing army of warriors.
