To: Texas Behavioral Health Executive Council 

Subject: Vote Against the Proposed Language Changes to Continuing Education Requirements 

The Issue

The Texas Behavioral Health Executive Council (BHEC) will meet on Tuesday, February 18th, 2025, to discuss and vote on proposed language changes to continuing education requirements for the state licensing boards for marriage and family therapists, professional counselors, psychologists, and social workers. 

The state licensing boards have voted to proceed with the rulemaking process despite overwhelming opposition from their licensees. The public comments for the recent meeting of the Texas State Board of Examiners of Professional Counselors had only 9 of 286 supporting the proposed changes. 

The proposed changes include replacing the language requiring continuing education hours in “cultural diversity or competency” with "designed to ensure competency when providing services to a distinct population, defined as a group of people who share a common attribute, trait, or defining characteristic of the licensee's choice." 

Additionally, the list of acceptable cultural diversity or competency hours including but “not limited to continuing education regarding age, disability, ethnicity, gender, gender identity, language, national origin, race, religion, culture, sexual orientation, and socioeconomic status” would be removed entirely. 

Why This Matters 

The current language provides clear guidance on how licensees can obtain continuing education that is most likely to address the specific contexts and mental health care needs of Texans. The proposed changes would weaken our core professional values and standards and create a pathway for licensees to avoid training on critical issues related to bias, discrimination, and culture.

There seem to be two rationales behind the proposed changes: 

1. To deal with alleged confusion over the existing terminology.
2. To align with political efforts at the state and federal levels to eliminate diversity, equity, and inclusion (DEI) policies and initiatives.

However, these do not hold up under scrutiny:

1. The confusion surrounding “cultural diversity or competency” is largely manufactured. These terms are well-established in the core professional values, definitions, and ethical standards of the mental health professions under BHEC.
2. The proposed removal of this language is clearly part of the broader attempts to eliminate DEI policies and initiatives. However, requiring continuing education as currently written in cultural diversity or competency for licensees to meet clients’ needs is not the same as implementing these within BHEC or its state licensing boards.

The proposed changes, regardless of their origin, will eliminate or replace clear and specific language around cultural diversity and competency. This presents a significant risk to the welfare of Texas residents by allowing licensees to opt out of continuing education that addresses bias and discrimination, which have been proven to cause harm to clients. The list of acceptable cultural diversity or competency hours provides a guidepost for mental health professionals to better understand and meet the needs of our most vulnerable, and indeed all, Texans.

Our Call to Action

We are joining as licensed mental health professionals and members of the public to call upon the Texas Behavioral Health Executive Council to vote against these proposed changes in order to: 

• Ensure that all licensees continue to receive adequate preparation for serving diverse populations.
• Improve the quality of mental health care of clients across the state.
• Preserve the integrity of licensees’ respective professional standards. 

By signing this petition, you are standing up for competent, effective, and inclusive mental health care in Texas. You are telling the Texas Behavioral Health Executive Council that our commitment to cultural competence must remain unambiguous.

How You Can Help

• Sign and share this petition to demonstrate the widespread opposition to these proposed changes. 
• Be sure to add a comment to your signature indicating your location, as well as your license type or that you are a member of the public. This will help me calculate and present this information to the council.
• Attend the BHEC meeting on February 18th, 2025, where we will present this petition.
• Other advocacy opportunities and updates will be posted as they become available.  

Important Note (Please Read) 

It is important to know that BHEC is not considering removing the continuing education requirements at this time. This petition is in opposition to proposed changes to the language of the related rules.

The proposed changes, according to certain state licensing board members, are intended to address “politically and culturally sensitive touch words” and “trigger words” by replacing the current language with a “broadened” definition of the continuing education requirements. 

As stated in the petition, this is problematic because the broad language allows licensees to opt out of the specific topics of cultural diversity and competency. There are few continuing education opportunities that could not be construed to meet the requirements with the proposed changes. This is as close as it can get to avoiding the ethical mandate of cultural competency without literally removing the continuing education requirements.