Dear TAMFT Members,
The Texas State Board of Examiners has proposed changes to the Rules, and some of these changes could have a significant impact on the MFT profession in Texas. While there are many changes (see attached document for a more complete list of changes), the Board of TAMFT asks you to pay particular attention to the changes listed below and urge you to contact the Board about your thoughts on these proposed changes.
#1: In section §801.112, the TSBEMFT will no longer give any preference in the licensure process to graduates of COAMFTE programs, a step that raises many concerns. We believe that the prudent process would maintain a higher standard for graduates since this standard protects the public as well as assists the board staff in efficiently processing applications for licensure. An alternative proposal would be for the Board of Examiners to keep a tier approach but expand it to include both COAMFTE accredited programs and CACREP accredited programs that meet family/systems/couples requirements.
#2: Also in section §801.112, the TSBEMFT is not changing the 9 semester hours or 12 months requirement for pre-graduation practicums, however the option to complete pre-graduation practicum deficits after graduation appears to be eliminated. Considering that it is possible in some programs can complete the 9 semester hours requirement in less than four months, perhaps it might make sense to change the “or” to an “and” or eliminate the 9 semester hours requirement. Many states require 12 months of practicum, and requiring this in Texas could help the portability of the Texas MFT license.
#3: In section §801.113, the TSBEMFT is recommending that a qualifying degree must be a minimum of 60 hours (the current requirements is 45 hours). Changing the required hours for a qualifying degree from 45 to 60 is a significant change that parallels what is happening in many states across the country. The negatives of this change include it will require current programs in Texas to change their curriculum and it will take students longer to graduate. The positives of this change is that it will make it easier for graduates from programs in Texas to transfer their license to other states and it will put MFTs in a stronger competitive position compared to LPCs who will be required in the future to complete 60 hours in their programs in order to be licensed in Texas.
#4: In section §801.114, the TSBEMFT has added some specific course work that would be a part of a qualifying degree program. Specific additions that raise some concerns are a proposed required course in “therapy in community settings” (three semester hours) and “management of crisis situations” (one semester hour). The therapy in community settings course would be a significant addition for most MFT programs and it is unclear why the Board of Examiners thinks this is a necessary course for MFTs. After a cursory review, this course is not seen in the requirements of other states, and, therefore, requiring this course may make it more difficult for LMFTs in other states with less than five years as a licensee to transfer their license to Texas. In regard to the “management of crisis situations” course, there have been some changes on the AMFTRB exam which would account for this proposed change. Specifically, there is the newly added domain titled Managing Crisis Situations. However, an alternative approach to requiring a one hour course would be to allow programs to include the crisis management in another course. Allowing educational programs to meet this requirement in this manner would allow each program to be more flexible and maintain greater uniqueness.
What to do next:
We strongly urge each member of TAMFT to borrow any language that might be helpful from this email blast and to send an email response to the TSBEMFT. The proposed rules for the Texas State Board of Examiners of Marriage and Family Therapists (TSBEMFT) were published in the June 27, 2014 issue of the Texas Register and are available for review on the Texas Secretary of State’s website at http://www.sos.state.tx.us/texreg/index.shtml and at http://www.dshs.state.tx.us/mft/mft_rules.shtm. The 30-day comment period started June 28, 2014, and comments on these proposed changes may be submitted to Crystal Beard, Executive Director, Texas State Board of Examiners of Marriage and Family Therapists, Mail Code 1982, P.O. Box 149347, Austin, Texas, 78714-9347 or by email to firstname.lastname@example.org. When emailing comments, please indicate “Comments on Proposed Rules” in the subject line.
Dr. Peter D. Bradley, PhD, LMFT-S, LPC-S
President - Texas Association for Marriage & Family Therapy
Dr. Chuck K. West, PhD., LMFT
Legislative Committee Chair - Texas Association for Marriage & Family Therapy