Local Mental Health Clinic Seeks Advocacy Partnership

Proposed Op-Ed Submission 

RE: Proposed Texas Rules Could Limit Mental Health Treatment for First Responders and Countless Others Needing Care

March 13, 2026

Every day across Texas, first responders answer calls that most people will never witness.  

They respond to fatal accidents, violent crime scenes, suicides, overdoses, and disasters. They step into chaos to protect strangers, often carrying those experiences with them long after the sirens stop.

For many first responders, the psychological toll of that work is profound. Research has shown that firefighters, police officers, paramedics, and other emergency personnel experience significantly higher rates of post-traumatic stress disorder, depression, substance abuse, and suicide than the general public.

Despite the growing awareness of this crisis, many first responders still struggle to find effective mental health treatment.

Over the past decade, physicians have begun exploring new treatment options for individuals suffering from severe, treatment-resistant depression and PTSD. One of those treatments is ketamine therapy.

Ketamine is not a new medication. It has been used safely in medicine for more than fifty years and remains an FDA-approved anesthetic used daily in hospitals across the country. In recent years, clinicians have also studied its potential to help patients whose depression or trauma has not responded to traditional medications.

For many individuals — including many first responders — this therapy has offered relief after years and sometimes decades of unsuccessful treatment attempts.

Across Texas, medical clinics begun offering ketamine therapy in carefully monitored clinical environments. These clinics operate under existing medical regulations and provide treatment to patients who often arrive after exhausting nearly every other option.

However, the Texas Medical Board is currently considering revisions to Chapter 173 of the Texas Administrative Code, specifically Sections 173.6 through 173.15, which govern Psychotropic Ketamine Therapy.  

While regulatory oversight is essential for protecting patient safety, some of the proposed changes could significantly alter how clinics providing this treatment are allowed to operate.

The proposed rules introduce new requirements regarding physician presence, administration personnel, and the establishment of the physician-patient relationship. While these measures are intended to ensure safe practice, they may also create barriers that make it more difficult for patients to access care.

“Safe outpatient ketamine care is already being delivered in Texas. At Austin Ketamine Clinic, more than 7,000 individual ketamine treatments have been administered in less than six years without a single serious adverse event. That record demonstrates that established clinics can provide structured, physician-supervised care responsibly and safely.

We support appropriate oversight, accountability, and patient safety. However, any rule intended to improve safety must also account for the real-world consequences of reduced access to care. Regulations should not unintentionally force compliant clinics to close or leave vulnerable Texans without treatment.” change.org/ketaminetherapy

For individuals suffering from severe depression or PTSD — particularly those who have already struggled for years to find relief — access to treatment can be life-changing.

For first responders, it can be life-saving.

As someone who spent decades working as a rescue paramedic, I witnessed firsthand the emotional burden carried by the men and women who respond to emergencies in our communities. First responders often continue working through trauma while quietly struggling with the psychological effects of what they see every day.

Today, through my work in mental health care, I have seen another side of that story — individuals who finally experience relief after years of suffering.

This is why thoughtful conversation around these proposed regulations is so important. No one disputes that medical treatments should be regulated carefully and responsibly. Patient safety must always remain the priority. But when regulatory changes are proposed, it is equally important to consider their potential impact on access to care for those who need it most.

Austin has long been a city that values innovation, compassion, and community support. As discussions around these proposed rules continue, Texans deserve the opportunity to understand what is being considered and how it may affect patients seeking help.

Mental health treatment should always prioritize both safety and access.

For first responders who spend their lives protecting others, access to care should never become another obstacle they must overcome.

“The economic assumptions behind the proposal are also difficult to reconcile with operational reality. In the Texas Register, the Board states there will be only a probable minimal economic cost to individuals required to comply and no effect on small businesses, micro businesses, or rural communities.[8] Yet for smaller clinics, the combination of registration, onsite physician availability, staffing restrictions, delegation protocols, log maintenance, inspection exposure, and renewal compliance is plainly not trivial.[4][6][8] To characterize that burden as minimal, especially for independent outpatient clinics, does not reflect the actual cost of maintaining a physician physically onsite throughout administration while also meeting the proposal’s other compliance demands.[4][6][8]

The Texas Medical Board’s own rule-making page confirms that the Chapter 173 PKT proposal was published in the January 2, 2026 issue of the Texas Register, that written comments are being accepted, and that a public hearing will be held at a later date.[2] That means this is the proper moment to reconsider whether the current proposal is over-broad, internally inconsistent, and likely to reduce access to care in ways the Board has underestimated.[2]

Texas should regulate parenteral ketamine therapy responsibly, but not irrationally. A more balanced approach would preserve the core safety measures already described in the proposal—proper physician-patient relationship requirements, psychiatric diagnosis, informed consent, monitoring, equipment, emergency logs, protocols, and prohibition of home administration—while allowing flexibility for clinics that can demonstrate actual competency and safe outcomes without requiring a physician to be physically onsite at all times.[3][4][5][6] The real question should not be whether a physician is in the building as a symbolic safeguard. The real question should be whether the clinic can demonstrate safe patient selection, appropriate psychiatric evaluation, clear delegation, effective monitoring, documented staff training, immediate rescue capability, and accountable oversight.

For those reasons, I respectfully urge the Texas Medical Board to reconsider the categorical onsite-physician requirement, and align the staffing provisions with actual clinical competency rather than title-based assumptions.[4][5] Texas patients with treatment-resistant psychiatric illness deserve access to safe, evidence-informed ketamine care. Clinics that already provide that care responsibly should not be regulated out of reach.” change.org/ketaminetherapy

Jon V. Wolfe, LP/MPA-EM

CEO / Co-Founder

Austin Ketamine Clinic

Austin, Texas