AZ Board of Behavioral Health Meets to Discuss "Guidance to the Public" on Unlicensed School Counselors
Tomorrow's meeting will give a first look at how Board may regulate unlicensed school-based behavioral health workers
For their March 8th regular board meeting, the Arizona Board of Behavioral Examiners has agendized a discussion about “educating the public on school counselors.”
This comes on the heels of my successful administrative petition to repeal the agency’s policy on the “Practice Authority of School Counselors” adopted in 2003 when school counselors were still primarily vocational and college planning advisors. Before the morphing of that role into a sort of “support services” band leader for therapy-based education.
Public comment will be available, but only at the end of what is likely a full day’s meeting. The board will also be considering TWENTY-EIGHT (28!) cases of discipline against licensed counselors, social workers, and substance abuse counselors. THAT is regulated behavioral health services, folks.
Things go wrong. Therapy goes bad, and therapists make mistakes. A professional licensing board is, at the core, a kind of consumer protection agency.
Things I will be looking for:
Here’s what the statute says constitutes unlicensed behavioral health in Arizona, a class 6 felony:
“A person who is not licensed pursuant to this chapter and who practices or attempts to practice…behavioral health, including diagnosing or treating any mental ailment, disease or disorder or other mental condition of any person, without being authorized by law to perform the act is engaging in the unauthorized practice of behavioral health….”
By this definition, school counselors who meet with students to “just talk” on any number issues - anxiety, family conflict, trichotillomania (yes, that’s a thing) may be practicing behavioral health.
The public needs guidance on where the line is, and when it’s crossed. I have my own theory, but won’t share here…for now.
What I do know is that Board fully understands that the department of education is simply ill-equipped to manage behavior health services. They don’t even try. There are no policies on how behavioral health services are given, no legally enforceable professional standards of care, no binding ethics rules. School counselor, social worker, these are in reality just employee classifications under the Administrative Code, not indicative of a professional, regulated class of experts. Local school boards have authority to make such policies, but they won’t - because they don’t know how to regulate behavioral health either.
It’s misleading, confusing, and the public has a right to know that school-based behavioral health is really a free-for all, buyer beware, wild, wild West.
With their kids.
So, let’s hope that’s about to change.
End.