Kathleen’s Public Comments at BHEC Council 6-25-24

Kathleen's Public Comments at BHEC Council 6-25-24 | Association for Mental Health Professionals

Last week the Austin BBQ Club drove to Austin to present our comments to the Council in person. These are Kathleen's remarks.

"My name is Kathleen Mills, LPC-S. I am also a co-founder of the Association For Mental Health Professionals.

On Your Licensees' Self-Regulation

In the last 12 months ONLY 110 complaints survived the initial BHEC Staff review and went on to some form of disciplinary action. "How well are licensees policing their own activities?". The answer is "less than one-sixth of one percent of 70,000 counselors received an official reprimand from the penalty matrix". That means counselors are doing a pretty DAMN good job of self-policing.

On the Quadrennial Review

We will be submitting to the Quadrennial Review Committee a list of rules passed in the last two years with a questionable basis for existence. We'll be requesting that they be repealed as not originally necessary in their development.

That list will include:

  1. The CE Renewal Requirements passed in 2023.

This mash-up of rules simplified nothing, addressed no empirical problems and was driven only by an academic desire to control the direction of our profession. One and a half pages became 5 and it complicated the BHEC administrative effort. Most licensees are still very confused and that's a real problem that you created.

  1. The 3-Hr Cultural Awareness requirement.

I took a cultural diversity course in grad school, and BHEC's not getting complaints about Cultural Diversity issues, so repeal this requirement in its entirety. There's no empirical basis for it. Remember, less than one-sixth of 1%.....

  1. The 1 Hr Crisis Management requirement for MFT's.

This is classic government overreach. Train 100% of the people for something that only 5% of them might utilize, and ignore existing resources and infrastructure that adequately addresses the issue. Repeal this.

  1. The redundant Telehealth training requirement for MFT's.

Regulations for both telehealth and AI already exist in the Federal HIPAA code making this regulation redundant. Reference the code from the rulebook and repeal this rule as redundant.

  1. The (6) Supervisor Refresher hours requirement.

The current requirement states that the 6 hours need to be "related to the supervision of an associate". Are my 6 ethics, and my Human Trafficking hours not related to the supervision of my associates? Any additional coursework I take also satisfies your current refresher requirement that it be "related to the supervision of an associate". So why is this rule necessary?

We have provided far more supporting argument and detail for each of these items in a document you should have already received. We're suggesting that the boards and the council take this opportunity and use it to clean up the rulebooks beyond merely what comports with state law. Do that with the understanding that your licensees, and agencies in other states, are watching to see what you do with this opportunity and the BHEC model. AMHP is suggesting that Texas raise the bar for the nation.

Summary and CTA

YOUR state mandate as our licensing board and council is to protect Joe Citizen, address licensing and ethics issues and obtain more and competent counselors for Texas. Stay out of the "counselor improvement" business.

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About the Author

Kathleen's Public Comments at BHEC Council 6-25-24 | Association for Mental Health ProfessionalsKathleen 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.

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