The deadline for objecting to the proposed rule change is August 12, 2013. I URGE you to write to the LPC Board here:
Please submit your comments to lpc@dshs.state.tx.us, or bobbe.alexander@dshs.state.tx.us
Here are a few pointers from the Texas Counseling Association for for making effective comments to the LPC board :
- Keep in mind that the mission of the LPC board is to protect the interests of the public, not counselors. Therefore, frame your comments in terms of how this change would affect clients.
- Reference the proposed rule change, and suggest specific changes to be made to the proposed rule (or alternately you may suggest that the current rule which allows online-initiated counseling be allowed to stand as written).
- Be as succinct as possible.
You can view the proposed rule changes here:
The proposed change is underlined on the top of page 17. (Adobe Acrobat)
As a fellow mental health professional, I would like to share my reasons for opposing the proposed change to the LPC rule which states:
Technological means of communication may be used to facilitate the therapeutic counseling process which has already been established. Technological means may be used in crisis counseling with no previous counseling relationship.
Thousands or Texans will be denied access to needed counseling services as a result of the proposed change. Texas counselors, including myself, have been ethically practicing online counseling for a numbers of year now with great success, and just as in my practice, quite a few clients WOULD NEVER have initiated treatment in-person. This is an unnecessary barrier to treatment, especially affecting underserved populations including the sick, disabled, geographically remote, and those with certain disorders such as agoraphobia, as well as other reasons. Moreover, this restriction is possibly discriminatory and undermines mental health parity.
There is no empirical justification behind making this restrictive change, as studies have repeatedly shown online counseling to be just as effective, and in some cases even more so. These studies have not made a distinction between counseling initiated in-person versus online. Please reference the World Health Organization endorsement of online therapy and this list of studies showing the effectiveness of online therapy.
I will be spreading the word to my other Texas colleagues and urge you to contact the board as soon as possible to overturn this proposed restriction. I appreciate your time and thoughtfulness in this matter.
Thank you.
Stephanie Adams, MA LPC
P.S. Even if you DON'T plan on offering online therapy, if you're in Texas, would you send an email on behalf of the many counselors such as myself who hope to ethically continue to offer online services without needless restrictions to our clients? This could cripple counseling businesses such as mine and more importantly, turn people away from therapy who need it. Please send your respectful objections on their behalf.
P.P.S. You should feel free to adapt and use information in this blog post today as necessary to write your letter.
REMEMBER, you have to send email before August 12th. Please comment below if you have sent that, so I can reference in a follow-up email to Ms. Alexander.
THANK YOU!
For further reading: Conservative attacks on online therapy.
FYI: Original Rule for LPCs In Texas reads:
Subchapter C. Code of Ethics. §681.41. General Ethical Requirements. (g) Where the client is in one location and the counselor is in another, technological means of communication may be used to facilitate the therapeutic counseling process.
A huge debt of thanks goes to Donna Rose, LPC, Counselor in Austin, TX. She told me about this change and took the time to help me draw up a post about this information on really short notice. I literally could not have done anything without her help. Thank you, Donna!