There's a BHEC Council meeting today (10/25/22) during which the Council will more than likely be signing off on your new CE renewal requirements package, courtesy of the Standards Committee and your Board. Yes, it will apply to you. If you've been following this self-indulgent travesty with us for the past 6 months then you know your renewal requirements are escalating from fairly simple (less than half a page in your rulebook) to needlessly complicated (right at 4 pages now).

This behemoth is going to pass despite much very vocal opposition and here's why.

The Standards Committee Has Its Own Agenda

When you're not privy to the policy discussions, all one has to go on to determine a group's true motivation are their actions. We can judge the intent of our board and Council members by the fruit they bear. I'll not rehash the entire orchard here, you can review my supporting argument in numerous prior posts, but suffice it to say our Boards and Council are turning out some produce that doesn't make much sense at all (unless you follow the money).

What's the Standards Committee's Job?

Their primary function is to make sure that all board rules comport with State code (laws). (Board rules that allow behaviors that are currently illegal per the TX Legislature make BHEC's oversight task somewhat difficult, to say the least.)

It's a simple directive: Sync the rulebook with TX Code, streamline things across all 4 rulebooks where they can be, simplify them where practical, and leave things alone that aren't broken.

Unfortunately, the Standards Committee is apparently taking this opportunity to drive their own agenda and they're counting on you not paying enough attention throughout the process to stop them.

The Standards Committee is staffed with people from non-profit associations promoting ACA ethics, the various revenue streams that flow from it, and woke, progressive liberal social agendas. This group created two classes of ce providers where no classes were required: Approved Providers and "Other".

Guess which group they put themselves in?

Explain it to me like I'm a 5th grader how that best represents the interests of Joe Citizen, then me, as a licensee? 'Cause it sounds like the non-profit associations and academia are profiting the most here (see the A/P list before you start throwing shade my way!).

The Council Isn't Doing Its Job Properly

Conflict of Interest?

Fact: The Council is made up of the same people that pass issues at the Board level. So they get to pass things as a board member then run over to their Council chair and approve it. Read that again and let it soak in. Sounds like a politician's paradise.

The Rodney King Syndrome

A position on The Council requires a willingness to be confrontational with other Council members where necessary. Why? The Council is supposed to act as a checks and balances between boards (LMFT's holding LPC's accountable, LPC's holding Psych and Social Worker boards accountable, etc. for proposed/desired changes). That's not happening.

But don't take my word for it, do your own research. Watch a recorded BHEC meeting or two and listen to the Council members talk about "how we can all get along and best help each other out". It's a kumbaya party. "Why can't we just all get along?" So much for cross-Board accountability.

Ignoring Required State Code in the Approval Process

The rules change approval process is quite involved and works extremely well on paper but I see two major problems with it so far:

1. The people taking the test get to grade their own paper! (Discussed above)
2. There are numerous State code requirements to be completed for each rule change (impact reports and other cross-checks) that don't appear to be getting done.

I'm not quite sure (yet) if that's something BHEC is responsible for, or if those checks are to be completed at the board or Council level, but either way they don't appear to be happening.

Fact: We made multiple, very loud inquiries about this in the written and public comments but they were totally ignored and went unanswered. So much for "transparency". If these required reports and cross-checks were being done then simply showing them to us might make this entire argument go away, unless the report outcomes don't support the motive for change. I'd like to know why we were ignored but I'm not holding my breath.

P.S. The BHEC Staff is Not to Blame

The BHEC staff did not create its own flawed infrastructure nor is it empowered to fix those issues discussed here today. They don't do new rules, that's the purview of the Standards Committee, your Board, and the Council. So don't waste your resources venting to the BHEC staff about new rules you don't like. Save that fire for your Board members and the Council.

Summary

When people in our profession get caught with their hands in the cookie jar some of the first things they do are a) claim it's for the betterment of the profession, usually with no empirical proof to back it up, or b) claim that they "have a right".

It's true, your Board has the legal right to propose and change the rules as they see fit as long as they don't run afoul of state law, and there's almost nothing you can do about it. But as I've been telling my two boys since they were old enough to understand, just because you have a right to do something doesn't automatically make it a good idea.

If this is your first time hearing about these rule changes, may I politely suggest that you follow what your board is doing a little more closely to see what they're passing when you're not looking? It's your license and your livelihood. You've got to get involved or we're going to get even more of the Frankensteined "improvements" we're getting rammed down our throat today.

Plan Smart. Be Safe. Serve Others.

Kathleen Mills, LPC-S, CEAP