October 2025 BHEC Meeting Recap: Key Updates for LPCs, LMFTs, LSWs, & Psychologists
By Chelsea Fielder-Jenks, LPC-S, CEDS-C, PMH-C
October 14, 2025
BHEC Meeting Recap
The Texas Behavioral Health Executive Council (BHEC) convened on October 14, 2025, covering a wide spectrum of updates impacting behavioral health professionals across Texas — including rulemaking actions, fiscal reports, enforcement trends, and emerging discussions around artificial intelligence and technology use.
While not every agenda item was discussed in depth, BHEC released 221 supporting files (linked here in case you want to take a look at any of the original source materials) offering rich background and context. To keep our WisePractice community fully informed, I reviewed those materials (and several related public sources, linked throughout) to distill what matters most — so you don’t have to. (My prefrontal cortex may need a vacation after this deep dive, but your recap is ready.)
BHEC Enforcement Report – FY 2025 Summary
Between September 1, 2024, and August 31, 2025, the Texas Behavioral Health Executive Council (BHEC) processed a total of 811 complaints across all four licensing boards.
Complaints Received:
LPC Board (TSBEPC): 462
Social Work Board (TSBSWE): 168
Psychology Board (TSBEP): 116
Marriage & Family Therapy Board (TSBMFT): 65
Complaints Resolved:
LPC Board: 360
Social Work Board: 144
Psychology Board: 61
Marriage & Family Therapy Board: 50
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)
Overall, while the majority of cases were dismissed or resolved without disciplinary action, the Council noted continued patterns in boundary violations, standard of care concerns, and professional conduct issues — areas expected to remain a focus for training and enforcement in FY 2026.
Informational Highlights
Performance & Licensing Reports: Application processing times continue to improve across all boards, with average application processing time being 29 days, with as little processing time as 24 hours. This past fiscal year (FY), BHEC issued over 12,000 new licenses and renewed over 36,000.
Enforcement & Complaints Report: Complaint volume as increased (811 complaints received this past FY — see a summary of the report in sidebar), with speculation that this is due to an overall increase in the number of licensees. To strengthen due process and consistency, BHEC has been working to hire a staff attorney dedicated to enforcement matters to no avail. The agency is also exploring bringing in a law intern to assist with addressing complaints in a timely manner.
Financial Reports: The Council reviewed year-end financials and the FY2025 Annual Financial Report.
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.
HB 3130 Implementation — Confidentiality for Protected Individuals: BHEC has fully implemented the bill protecting certain victims' personal information by allowing licensed professionals to request confidentiality. Although the bill seemed simple, it required major database changes to exclude protected data from public records. Sharing the database with multiple agencies made this process complex and time-consuming. BHEC absorbed the unfunded implementation costs, highlighting the logistical and financial challenges of enforcing such legislation.
ASWB Workforce Study: The Council received an overview of national findings on the social work workforce, highlighting demographic shifts and emerging challenges in recruitment and retention.
PSYPACT Update: Texas continues active participation in the Psychology Interjurisdictional Compact, with new interjurisdictional data-sharing updates expected in early 2026.
Further Discussion and Action Items
CE Broker Rollout Progress
A progress update on the CE Broker implementation was provided:
Nearly 18% of licensees are now registered since the initial announcement this past August.
Mandatory reporting begins January 1, 2026 — license renewals will not be processed unless CE hours are entered into CE Broker.
Three live webinars remain (Oct 29, Dec 10, and early 2026).
Reminder: Free CE Broker accounts meet all BHEC requirements; paid tiers are optional. Want to know more about CE Broker and how to get started? Read more in our August BHEC round up blog here.
Artificial Intelligence “Regulatory Sandbox” Planning
The Council agreed to form an ad hoc committee to assist staff in developing rules for participation in the state’s forthcoming AI regulatory sandbox, but rule drafting will not begin until the Texas Department of Information Resources (DIR) establishes the statewide program and the Texas Artificial Intelligence Council.
Executive Director Darrel Spinks noted that while the Legislature authorized the sandbox under Business & Commerce Code §553.052, DIR has not yet finalized its framework. He emphasized waiting for DIR’s criteria to ensure BHEC’s rules align with statewide standards.
Next Steps: BHEC will monitor DIR’s progress and reconvene the committee once state guidance is issued. Early engagement ensures mental health perspectives are represented in Texas’ approach to regulating AI in behavioral health care.
Review and Consideration of New BHEC Guidelines
The Council reviewed and considered two new sets of guidelines designed to help clarify the practical application of existing rules. While the content of both documents aligns with current regulatory standards, Council members acknowledged that stakeholders often seek additional support in interpreting and applying these requirements in practice.
Approved for Publication on the BHEC Website — Guidelines for the Use of New Technologies or Emerging Practices: These guidelines provide direction for licensees using telehealth, artificial intelligence, or other emerging digital tools in clinical practice. The guidelines are now live and you can read them here.
Approved for Internal Use Only — Guidelines for Practice Monitors (Council-Ordered Supervision): This document clarifies expectations, reporting standards, and documentation requirements for monitors assigned in disciplinary or remediation cases. It will serve as an internal reference for enforcement and compliance staff rather than a public-facing resource.
Rulemaking Updates
Unfamiliar with the BHEC Rulemaking Process? Here’s a map that delineates the process. Source: https://bhec.texas.gov/wp-content/uploads/2023/03/BHEC-Rulemaking-Process-Map-20230327.pdf
Texas Behavioral Health Executive Council
Proposed Rule Changes:
§881.2 Definitions – Updates terminology for clarity and consistency across professions regulated by BHEC.
§882.42 Ineligibility Due to Criminal History – Clarifies how criminal background information will be reviewed and how mitigating factors are weighed.
§882.60–61 Special Provisions for Military Service Members, Veterans, and Spouses – Updates to align with state laws supporting expedited licensure for military families and clarify documentation requirements.
§884.11 Informal Conferences – Refines language around informal disciplinary conferences to ensure due process while improving administrative efficiency.
§885.1 Executive Council Fees – Updates fee structures to reflect removal of obsolete categories and modernized processes (e.g., online verification).
Adopted Rule Changes:
§882.1 Application Process – Standardizes the handling of incomplete applications across all licensing boards. Incomplete applications will remain active for 180 days from the date of receipt, after which they will expire if not completed.
§882.2 General Application File Requirements – Clarifies how supervised experience is calculated, specifying that the qualifying period begins at license issuance.
§882.21 License Statuses – Allows individuals with a delinquent license to transfer to inactive status, creating more flexibility for licensees managing career transitions.
Texas State Board of Examiners of Marriage and Family Therapists:
Proposed Rule Changes:
§801.2 Definitions - Minor editorial changes.
§801.57 Child Custody Evaluations – Aligns child custody evaluation standards across BHEC member boards for consistency.
§801.112 & §801.113 Academic Requirements – Clarifies required coursework and educational standards for licensure eligibility.
§801.204 Licensing of Military Service Members, Veterans, and Spouses – Provides expedited pathways for military-related applicants in compliance with new statutory mandates.
Adopted Rule Changes:
§801.44 Relationships with Clients – Aligns expectations when clients receive services from multiple professionals. Requires client consent before contacting another provider and encourages coordinated care.
§801.142 Supervised Experience Requirements and Conditions – Adds new requirements for Associates to notify supervisors of any filed complaints.
§801.143 Supervisor Requirements – Requires that remediation plans follow supervisees to subsequent supervisors to ensure continuity of oversight.
Texas State Board of Examiners of Psychologists:
Proposed rule changes:
§463.8 Licensed Psychological Associate – Updates eligibility and supervision conditions for LPAs to ensure consistency with national standards and BHEC oversight.
§463.9 Licensed Specialist in School Psychology (LSSP) – Clarifies scope of practice and supervision requirements for school-based psychological services.
§463.11 Supervised Experience for Licensure as a Psychologist – Refines acceptable supervised experience definitions and recordkeeping expectations for licensure applicants.
§463.20 Special Provisions for Military Service Members, Veterans, and Spouses – Streamlines licensure reciprocity and portability for military-affiliated applicants.
§463.30 Examinations Required for Licensure – Aligns exam requirements with updated national testing standards and procedures.
§465.1 Definitions – Updates terminology and definitions to match current professional standards.
§465.2 Supervision – Clarifies delegated supervision responsibilities and introduces clearer expectations for postdoctoral supervision.
§465.18 Forensic Services – Revises standards for conducting forensic psychological evaluations to ensure alignment with ethical and procedural best practices.
§465.21 Termination of Services – Clarifies responsibilities when ending a therapeutic or professional relationship, including documentation and continuity of care.
§465.38 Psychological Services for Schools – Updates to better define service delivery, consultation, and ethical standards for psychologists working in educational settings.
Adopted Rule Changes:
§465.2 Supervision – Aims to enhance clarity for delegated supervision structures, especially for postdoctoral fellows.
§465.34 Providing Mental Health Services to Those Served by Others – Clarifies collaborative care boundaries in alignment with the other boards under BHEC. The newly proposed language ensures that:
If a client is also working with another licensed mental health professional, you must obtain consent and attempt to coordinate care.
This rule reinforces the shared ethical responsibility of collaborative treatment, reducing confusion and increasing client safety across professions.
Texas State Board of Examiners of Professional Counselors:
Proposed rule changes:
§681.53 Child Custody, Adoption, and Contested Adoption Evaluations – Refines qualifications and documentation standards for counselors performing these evaluations.
§681.114 Licensing of Military Service Members, Veterans, and Spouses – Streamlines pathways for military applicants to promote license portability and timely processing.
Adopted Rule Changes — Withdrawn:
§681.91 LPC Associate License – Withdrawn September 19, 2025, and sent back to the Rules Committee for revision after stakeholder feedback.
§681.93 Supervisor Requirements – Also withdrawn for revision; updates are being reconsidered to address supervision structure, documentation, and remediation reporting requirements.
Note: Read our LPC Board Recap from the September 19th meeting to learn more.
Texas State Board of Social Worker Examiners:
Proposed rule changes — The Social Work Board continues its large-scale rule modernization initiative, reviewing definitions, supervision requirements, and licensure procedures to align with BHEC’s broader standardization efforts across boards.
§781.102 Definitions – Updates and modernizes definitions for consistency across BHEC boards.
§781.302 The Practice of Social Work – Expands and clarifies descriptions of clinical and non-clinical practice.
§781.303 Rule of Practice – Reaffirms ethical and procedural standards of practice.
§781.322 Child Custody Evaluations – Standardizes requirements for custody evaluations to match other mental health disciplines.
§781.401 Qualification for Licensure – Updates education and experience requirements for social work licensure.
§781.402–§781.406 (Repeal and Replace Series) – Comprehensive updates covering clinical and non-clinical supervision, recognition as a supervisor, independent practice recognition, and required documentation for licensure.
§781.407 Prohibited Independent Practice – Clarifies what constitutes unauthorized independent practice.
§781.419 Licensing of Military Service Members, Veterans, and Military Spouses – Adds clearer language for licensure portability and expedited application review.
§781.805 Schedule of Sanctions – Revises and updates disciplinary sanction ranges for greater clarity and consistency across cases.
Adopted Rules — None at this time.
General Updates
Representatives of each of the four licensing boards provided updates on current initiatives and areas of focus:
Psychology Board:
Provided an update on the development of a new psychology licensing exam: As shared at the previous BHEC meeting, the state legislature funded the development of a Texas-based psychology licensing exam as an alternative to the ASPPB’s EPPP. This initiative arose from concerns about the cost, accessibility, and equity of the national exam. Board representatives have been collaborating with other state regulatory bodies and psychology boards, receiving strong encouragement for this Texas-led effort. They also plan to attend the upcoming ASPPB national meeting to continue gathering feedback and fostering dialogue. Expect opportunities for stakeholder engagement as the exam’s design and content are developed — psychologists and educators will likely be invited to contribute input during the process.
MFT Board:
The MFT Board reported a few major initiatives currently underway:
“Radical” CE Update: Following a recent statewide survey of licensees, the Board is developing a comprehensive revision of continuing education (CE) requirements, described by LMFT Professional Member, Dr. Merchant, as a “radical” update with an aim to harmonize CE standards across all BHEC boards.
Supervision Surveys: The Board also completed data collection from LMFT Associates about their supervision experiences, with analysis expected to begin soon. A companion survey for supervisors will follow this winter or spring. The results from both surveys will help inform future supervision rules and possibly new guidance materials for the BHEC website.
Future Research: Additionally, the MFT Board hopes to initiate research on required clinical hours for licensure, aligning with ongoing national discussions about competency and readiness for independent practice.
LPC Board:
TCA Professional Growth Conference: Four LPC board members will be providing a panel discussion at the upcoming conference. Members and attendees are invited to submit questions and topics to their TCA liaison to be included.
National Spanish Exam available soon: NBCC will be releasing a Spanish version of their counseling exam available in the US.
Growing number of LPCs: LPC and LPC-Associates, combined, have now reached 40,000 licensees.
SW Board:
Progress toward Spanish-language licensing exam: The board discussed the development of a Spanish-language licensure exam with ASWB in August, with the aim to improve access and equity. The discussion facilitated insight into potential challenges with development, including ensuring cultural and linguistic accuracy.
Texas SW Interstate Compact Failed: An update that SW was not able to enter into the interstate compact this past legislative session, however the board will continue to support Texas joining the compact.
Other notable items:
Honoring Leadership: The Council recognized Chairwoman Gloria Canseco, presenting an agency resolution and gubernatorial proclamation in appreciation of her service as BHEC’s inaugural presiding member.
Discussion of Pending Litigation: The Council entered closed session to discuss the pending lawsuit Youniacutt, et al. v. Texas State Board of Social Worker Examiners, et al., filed in Travis County District Court (Nov 2024). No public action was taken following the discussion.
Public Comment Highlights — The public comment period reflected a wide range of professional and ethical concerns:
Ketamine-Assisted Therapy (KAT): A commenter shared concerns related to KAT and urged BHEC to provide regulation, clarification, and guidance on KAT regarding scope of practice, obligation for cross provider contact, and best practices for supporting and protecting clients. The board responded positively, noting that the Texas Medical Board has been directed by the legislature to undergo a study of this topic and provide guidelines and regulations, which they are following closely and set an agenda item on the following Council meeting to further discuss this topic.
School Psychologist Title Change: Positive feedback on the update from using the title, “Licensed Specialists in School Psychology” to “School Psychologist,” with comments that this change will help eliminate confusion and increase public understanding of a term more commonly used and nationally accepted.
CE Broker Experiences: Licensees expressed mixed feedback — some praised its ease and organization, while others reported frustration with account setup and time intensive CE entries.
Board Representation: A commenter expressed feeling a sense of disconnection between the Council and the licensees it represents, sharing the perception that the Council is composed primarily of members with doctoral or legal backgrounds rather than master’s-level clinicians. Author Note: The Council is made up of nine members - one licensed professional and one public member (who hold various backgrounds) from each of the four licensing boards (MFT, LPC, SW, and Psychology) as well as one public member appointed by the Governor to serve as Chairperson - you can learn more about the current Council members here.
Christian Counselors of Texas: A representative voiced appreciation for the Council and provided a blessing.
Unethical Advertisement Concern: A licensee asked a question about how to report unethical or misleading advertising practices by a non-licensed individual. The Board responded with guidance stating that such concerns along with a copy of the advertisement can be shared via the board’s online contact form and staff will be able to review and support with next steps.
Additionally, Will Francis, Executive Director of NASW Texas and Louisiana, offered remarks supporting BHEC’s creation of the AI Ad Hoc Committee and the Spanish-language licensure exam initiative, noting both as crucial for equitable access and professional integrity.
How You Can Engage — Stay Informed. Stay Empowered.
Attend an upcoming BHEC Leadership Listening Hour — an open forum where licensees can ask questions, share concerns, and connect directly with the Executive Director and leadership staff.
Submit written public comment for proposed rule changes (usually due by 5 pm CST the day prior to the meeting) to the board for any issue affecting your professional practice.
Stay tuned to WisePractice’s Blog, Collective Wisdom, and subscribe to our newsletter for expert insights, ethical guidance, and real-time updates on policies that shape our profession.
