2025 Year in Review: What Texas BHEC Licensees Need to Know
A WisePractice Institute Recap of Legislative Updates, Rule Changes, and Regulatory Developments
by Chelsea Fielder-Jenks, LPC-S
*Deep breath. We made it through another year.*
2025 brought significant changes for behavioral health professionals in Texas — from new transparency laws to major shifts in continuing education tracking, supervision standards, and cross-profession harmonization. If you've been following along with our monthly meeting recaps, you've watched these developments unfold in real-time. If you haven't, this is your chance to catch up.
Below, we've distilled a full year of BHEC meetings, legislative updates, and rule adoptions into a clear, accessible overview organized by theme. Whether you're an LPC, LMFT, LCSW, or Psychologist, this recap will help you understand what changed, what's still evolving, and what to watch for in 2026.
Major Legislative Developments
Bills That Passed
House Bill 4224 – Consumer Rights Transparency (Effective September 1, 2025): Perhaps the most immediately actionable change of the year, HB 4224 requires all BHEC licensees to prominently post consumer rights information in two places: on your website and at your physical office (if applicable). Read our full HB 4224 breakdown here.
Senate Bill 1 (State Budget): Funding secured through the state budget included:
Two new BHEC attorneys to address complaint volume and improve enforcement response times
6% salary increase for all state attorneys to support retention
Development of a Texas-based psychology licensing exam as an alternative to the ASPPB's EPPP, driven by concerns about cost, accessibility, and equity
Spanish-language LMSW exam development — Texas will be the first state to fund this initiative, a major win for access and bilingual workforce development
NPDB subscription costs to streamline licensure audits (licensees will no longer need to submit self-inquiries manually)
Senate Bill 646 – Student Loan Repayment Program Expansion: This bill expanded the Texas Mental Health Professional Loan Repayment Program to include LPC-Associates, LMFT-Associates, LMSWs, and master's-level school counselors. The program now offers up to $100,000 for doctoral-level clinicians and $60,000 for master's-level clinicians, with bonus incentives for bilingual practitioners and those serving rural or underserved areas.
HB 3130 – Confidentiality for Protected Individuals: BHEC fully implemented this bill, which protects victims' personal information by allowing licensed professionals to request confidentiality. Although the bill seemed straightforward, it required significant database restructuring to exclude protected data from public records — a complex and costly undertaking that BHEC absorbed internally.
Bills That Did Not Pass
Counseling Compact (SB 498 / HB 1537): Texas did not join the Counseling Compact this legislative session. The next opportunity will be during the 2027 session. Board leadership encouraged licensees to advocate by contacting their legislators if they support joining the compact.
Social Work Interstate Compact: Similarly, the Social Work Compact failed to advance. The Social Work Board indicated they will continue advocating for Texas to join in future sessions.
Medicaid Reimbursement for Associates (HB 1716 / SB 469): A bill that would have allowed Medicaid reimbursement for LPC-, LMFT-, and LMSW-Associates passed in the House but died in the Senate Health & Human Services Committee.
HB 3515 (Safe Haven Act – Reunification Therapy): While discussed during public comment at multiple meetings, this bill did not pass.
Reciprocity Expansion (HB 11): A bill that would have granted BHEC authority to negotiate licensure reciprocity with other states was gutted late in session.
Art Therapy Licensing Board (SB 1081): A bill relating to the regulation of art therapy and the establishment of a Texas Art Therapy Board did not advance.
Rule Changes: What Was Adopted in 2025
Cross-Board Harmonization Efforts
One of BHEC's most visible priorities this year was harmonization — aligning rules across the four licensing boards (LPC, LMFT, LCSW, Psychology) to reduce confusion, promote consistency, and support coordinated client care.
Key Harmonized Rule: Coordination of Care Across Professions
All four boards adopted variations of a rule requiring that when a client is receiving services from multiple licensed mental health professionals, providers must:
Obtain client consent before contacting other providers
Attempt to coordinate care
This rule reinforces shared ethical responsibility and client safety across disciplines.
Revised Continuing Education Language – "Distinct Populations Competency"
All four boards replaced the term "cultural diversity" in CE requirements with "distinct populations competency."
Public response: This change drew significant public comment — both support and opposition. Many clinicians and educators expressed concern that removing explicit reference to "cultural diversity" could undermine commitments to equity, anti-oppressive practice, and social justice. Others supported the broader language as allowing more flexibility in tailoring CE to the populations they serve.
BHEC's clarification: Across multiple meetings, Council members emphasized that the updated language does not prohibit or discourage training in cultural competence, diversity, or identity-centered care. Instead, "distinct populations competency" is intended to give licensees autonomy to pursue training that matches their clinical setting and client base.
As stated during the June 24, 2025 Council meeting:
"We're not saying you shouldn't take training in cultural competence — we're saying it's your responsibility to know who you serve, and seek training that helps you do that well."
Effective date: July 20, 2025
LPC-Specific Rule Changes
Supervision Training No Longer Expires (§681.72): BHEC removed the 2-year expiration window for LPC supervisor training courses (and the 5-year expiration for doctoral-level equivalents). Clinicians who completed qualifying courses no longer need to retake them, removing a common barrier for returning or delayed supervisors.
Proposed & Withdrawn (returned to Rules Committee for revision) Supervision Rules (§681.91 & §681.93): In June, the LPC Board proposed significant updates to Associate and Supervisor requirements, including:
Clarifying that Associates may own a private practice only while under active supervision
Requiring Associates to notify supervisors of pending complaints
Requiring Supervisors to document session duration and practice locations
Child Custody & Adoption Evaluations (§681.53) – Proposed: Updates refine qualifications, clarify scope of practice, and set clearer standards for high-risk evaluations. This rule is still moving through the proposal process.
Military Service Members, Veterans, and Spouses (§681.114) – Proposed: Streamlines licensure pathways for military-affiliated applicants, aligning with state reciprocity laws and reducing barriers.
LCSW-Specific Rule Changes
Comprehensive Supervision Rule Reorganization (§781.401–407) – Proposed: The Social Work Board undertook a major restructuring of supervision rules to improve clarity and usability. The new structure includes:
§781.402 Types of Supervision - Clarifies different supervision categories
§781.403 Supervision Process - Details how supervision should be conducted and includes new requirement that supervisees inform supervisors if a complaint is filed against them
§781.404 Recognition as a Supervisor - Requirements for becoming a recognized supervisor
§781.405 Clinical Supervision for LCSW - Specific requirements for clinical supervision toward LCSW
§781.406 Independent Practice Recognition - New framework for independent practice
§781.407 Prohibited Independent Practice - Clear boundaries on what's not allowedes a remediation plan, it must be shared with any new supervisor (the new supervisor is not required to adopt it but must be aware of it)
Continuing Education (§781.501) – Adopted: Mirrored the "distinct populations competency" language change adopted across all boards. Effective July 20, 2025.
LMFT-Specific Rule Changes
Relationships with Clients (§801.44) – Adopted: Requires client consent to contact other providers and encourages collaboration when clients receive services from multiple professionals. Aligns with cross-board harmonization efforts.
Supervised Experience Requirements (§801.142) – Adopted: Associates must:
Notify supervisors if a complaint is filed
Submit supervisory agreements for each supervisor
Share remediation plans with all supervisors
Supervisor Requirements (§801.143) – Adopted: Clarifies that supervisors may share remediation plans and outlines required steps if a supervisor loses supervisor status.
Continuing Education (§801.261) – Adopted: Adopted the "distinct populations competency" CE language. Effective July 20, 2025.
"Radical" CE Update Coming: Following a recent statewide survey of LMFT licensees, the Board is developing a comprehensive revision of CE requirements described as a "radical" update aimed at harmonizing CE standards across all BHEC boards. Stay tuned for more details.
Psychology-Specific Rule Changes
Supervision (§465.2) – Adopted: Enhanced clarity for delegated supervision structures, especially for postdoctoral fellows. Requires supervisors to:
Create a custody plan for records in case of death or disability
Develop remediation plans for supervisees
Ensure supervisees share plans and complaints with supervisors
Removed the requirement for supervisors to keep liability insurance documentation.
Services to Clients with Other Providers (§465.34) – Adopted: Requires licensees, with client consent, to attempt collaboration with other providers rather than mandating consultation. Aligns with cross-board harmonization.
Professional Development (§463.35) – Adopted: Adopted the "distinct populations competency" CE language with clarification that continuing education should support competence in serving unique populations.
Psychological Services for Schools (§465.38) – Adopted: Clarifies the role and scope of practice for Licensed Specialists in School Psychology (LSSPs) and updates language to align with national standards.
Title Change: "School Psychologist": Positive feedback was received on updating the title from "Licensed Specialists in School Psychology" to the more commonly used and nationally accepted "School Psychologist."
BHEC Administrative Rules (Affect All Licensees)
Continuing Education and Audits (§882.50) – Adopted: Mandates the use of a new electronic CE reporting system (see CE Broker section below). This streamlined approach aims to increase audit efficiency while reducing administrative burden. A free reporting option is available.
Investigation of Complaints (§884.10) – Adopted: Clarifies how and when BHEC has jurisdiction to investigate licensee conduct, especially in cases involving service delivery across multiple roles or settings. Adds language to prevent formerly licensed clinicians whose licenses have been suspended or revoked from practicing under the guise of "coaching."
Executive Council Fees (§885.1) – Adopted: Eliminates the license verification fee now that verifications are accessible online. Reduces barriers and promotes transparency.
Application Process (§882.1) – Adopted: Standardizes handling of incomplete applications across all boards. Incomplete applications will remain active for 180 days from the date of receipt, after which they will expire if not completed.
General Application File Requirements (§882.2) – Adopted: Clarifies how supervised experience is calculated, specifying that the qualifying period begins at license issuance. Licensed experience counts only after a license is issued; part-time experience may be prorated.
License Statuses (§882.21) – Adopted: Allows individuals with a delinquent license to transfer to inactive status, creating more flexibility for licensees managing career transitions.
Major Operational Changes
CE Broker Implementation (Effective January 1, 2026)
The biggest operational change of 2025: mandatory CE tracking through CE Broker.
If you haven't set up your CE Broker account yet, do it now. As of January 1, 2026, all licensees must have a CE Broker account to report continuing education. You cannot renew your license without it. You can learn more about CE Broker in our earlier blog, here. Once you're in the system, CE Broker has its own help desk if you run into issues.
Fingerprint-Based Background Checks Extended to LPC Associates
The US Department of Justice approved the use of fingerprint-based background checks for LPC Associates (already approved for fully licensed LPCs), strengthening license verification and public protection standards.
Application Processing Improvements
Application processing times continue to improve across all boards. As of October 2025:
Average processing time: 29 days
Fastest processing: 24 hours
Over 12,000 new licenses issued in FY 2025
Over 36,000 licenses renewed in FY 2025
This represents a dramatic improvement from 6+ months processing times in previous years.
Enforcement Trends: FY 2025 Summary
Between September 1, 2024, and August 31, 2025, BHEC processed 811 complaints across all four licensing boards.
Complaints Received:
LPC Board: 462
Social Work Board: 168
Psychology Board: 116
LMFT Board: 65
Outcomes:
Total Disciplinary Actions: 99
Reprimands: 48
Probated Suspensions: 25
Revocations: 4
Resignations in lieu of discipline: 22
Cases Dismissed: 516
Most Common Complaint Types:
Sexual Misconduct (37)
Standard of Care Violations (19)
Unprofessional Conduct (8)
Dual Relationships (5)
Advertising/Unlicensed Practice (5 each)
Inadequate Supervision (3)
Record Keeping, Fraud, and Falsification of Documents (3 each)
Key takeaway: While the majority of cases were dismissed or resolved without disciplinary action, boundary violations, standard of care concerns, and professional conduct issues remain focal areas for training and enforcement.
Emerging Issues & Future Planning
Artificial Intelligence Regulatory Sandbox
Texas passed legislation allowing development of AI-based mental health tools under state-supervised "sandbox" regulations. BHEC formed an ad hoc committee to assist staff in developing rules for participation, but rule drafting will not begin until the Texas Department of Information Resources (DIR) establishes the statewide program.
Why this matters: Early engagement ensures mental health perspectives are represented in Texas' approach to regulating AI in behavioral health care.
Guidelines for Use of New Technologies or Emerging Practices
BHEC published new guidelines to help clarify the practical application of existing rules when using telehealth, artificial intelligence, or other emerging digital tools in clinical practice. The guidelines are now available on the BHEC website.
National Supreme Court Case to Watch: Chiles v. Salazar
BHEC leadership highlighted the national significance of the pending U.S. Supreme Court case Chiles v. Salazar, a First Amendment challenge to Colorado's ban on certain counseling speech with minors (essentially, a ban on conversion therapy).
The case questions whether state regulatory boards can limit what licensed professionals say in therapy under the guise of regulating conduct. Described as potentially a "watershed moment" for behavioral health, the outcome may redefine the balance between ethics enforcement and free speech protections.
With over 70 amicus briefs filed, BHEC emphasized its importance and urged stakeholders to monitor the case closely. A ruling is expected in 2026.
Public Comment Themes: What Licensees Are Talking About
Throughout 2025, public comment periods reflected passionate engagement from licensees on multiple issues:
Supervision Structure, Fees, and Ethics
Both LPC Associates and Supervisors raised concerns about:
Associates: Low pay, high supervision fees (often $200–$600/month), lack of mentorship, and exploitative structures
Supervisors: Increased liability, administrative burdens, and the need to protect their right to run profitable businesses
Two petitions for rulemaking were submitted by LPC-Associate La'Nika Graham (supervised by Dr. Joy-Del Snook), addressing fair compensation, supervision fee reform, and ethical oversight of supervisory business practices. While both petitions were denied procedurally, the core issues were referred to the Rules Committee for further study and will be considered alongside upcoming Associate and Supervisor survey results.
Practice Exit Protocols
LPC-S and attorney Laurel Clement submitted a petition calling for adoption of a rule addressing the separation of a counselor from a practice and the ethical protection of client interests. Examples included:
Counselors being locked out of EHRs immediately after giving notice
Counselors being denied termination sessions with clients
Practices refusing to release or charging for client records
Non-compete clauses and "client bounties" in exit contracts
While the board denied the petition procedurally, they expressed shared concern and referred the issue to the Rules Committee for further research and possible rule development.
Continuing Education Language Change
The shift from "cultural diversity" to "distinct populations competency" generated dozens of public comments expressing both support and opposition. Many clinicians worried this signaled a broader political trend away from DEI values, while others welcomed the flexibility.
Ketamine-Assisted Therapy (KAT)
A commenter shared concerns related to KAT and urged BHEC to provide regulation, clarification, and guidance regarding scope of practice, obligation for cross-provider contact, and best practices for supporting and protecting clients. The board responded positively, noting they are following the Texas Medical Board's legislative directive to study this topic.
Looking Ahead to 2026
What's Still in Progress
LPC Board:
Revised Associate and Supervisor rules (expected return after survey results and Rules Committee review)
Child custody evaluation standards
Military service member licensure pathways
Social Work Board:
Large-scale supervision rule modernization (§781.401–407 series)
Spanish-language exam development
Continued advocacy for interstate compact
LMFT Board:
"Radical" CE requirement update following licensee survey
Associate and Supervisor surveys (analysis expected soon)
Future research on required clinical hours for licensure
Psychology Board:
Development of Texas-based licensing exam as alternative to EPPP
Updates to forensic services standards
Refinement of postdoctoral supervision requirements
PSYPACT Rule 10 Revisions: The PSYPACT Commission has proposed revisions that would establish a process for reviewing and adjusting the Annual Assessment fee formula and cap the maximum fee at $6,000 per jurisdiction. Public comment is open through February 20, 2026 (5:00 p.m. EST), with final approval scheduled for the July 13, 2026 Midyear Meeting. Submit comments here.
System-Wide Initiatives
AI regulatory framework development (waiting on DIR guidance)
Research partnership with UT Rio Grande Valley analyzing disciplinary trends across all four boards
Continued harmonization efforts to align standards and reduce confusion across professions
2025 Customer Service and Strategic Planning Survey: BHEC is conducting its biennial survey as part of strategic planning for fiscal years 2027–2031. Your feedback on licensing services, enforcement, and professional trends directly informs process improvements, rulemaking, and communication with state leadership. Survey deadline: January 31, 2026 at 5:00 p.m. Take the survey here.
How to Stay Engaged in 2026
Attend the Monthly Leadership Listening Hour
Date: January 16, 2026 at 12:00 PM CST
Platform: Zoom (virtual)
Registration: Click here to register
The next Leadership Listening Hour offers you direct access to BHEC's Executive Director and key leadership team members in an informal, conversational setting. This is your opportunity to:
Ask questions and get answers directly from agency leadership
Share your perspective on issues affecting the profession
Stay informed about the latest developments and initiatives
Contribute your thoughts and feedback in an open dialogue
These monthly sessions provide invaluable opportunities for licensees to engage with leadership and ensure your voice is heard. While no CE credit is offered, the insights and direct communication are well worth your time.
Monitor BHEC Communications
Complete the 2025 Customer Service and Strategic Planning Survey by January 31, 2026 — your feedback directly informs rulemaking and agency improvements
Attend Board Meetings
Support Advocacy Efforts
Follow updates from professional organizations:
Stay Connected with WisePractice
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Final Thoughts
2025 was a year of significant transition for Texas behavioral health professionals. From new transparency requirements to major shifts in how we track continuing education, from ongoing debates about supervision ethics to emerging questions about AI in practice, the regulatory landscape continues to evolve.
These changes aren't just administrative — they fundamentally shape how we:
Protect clients
Support supervisees
Maintain ethical and legal compliance
Build sustainable, equitable practices
The work of staying informed is ongoing, but you don't have to do it alone.
WisePractice Institute is committed to translating regulatory complexity into clear, practical guidance that supports both professional compliance and clinical excellence. We'll continue attending meetings, reviewing proposed rules, and providing timely recaps so you can focus on the work that matters most.
Here's to a grounded, informed, and intentional 2026.
Questions? Topics you'd like us to cover in 2026? Let us know in the comments.
Guided by Wisdom. Rooted in Practice. Grown with Passion.
A Quick Disclaimer (Because It Matters)
WisePractice Institute is not a law firm, and this post does not constitute legal advice. We are practicing clinicians and educators who aim to translate regulatory information into practical, accessible guidance for fellow professionals. Licensees are ultimately responsible for understanding and complying with applicable laws and board rules, and may wish to consult legal counsel for practice-specific questions.