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BSRB begins crosswalk of unprofessional-conduct rules for seven professions; board debates uniform language on reporting, discrimination and romantic contact
Summary
Board members reviewed a drafted crosswalk aligning unprofessional-conduct regulations across seven licensed professions and debated uniform language on who the rules apply to, when licensees must notify the board, protected-class discrimination language, and time limits on post-client intimate relationships.
Board members spent substantive time on March 5 reviewing a draft crosswalk that compares proposed unprofessional-conduct regulation language across the board's seven professions and identifying items for harmonization.
Executive Director David Pfei said staff assembled the crosswalk after advisory committees for each profession recommended changes. He described the document as a draft intended to show where language aligns across addiction counseling, behavior analysis, licensed psychology, master's-level psychology, professional counseling, social work and marriage and family therapy. "This should be considered a draft," he said, adding staff will bring refined language to future meetings.
Board members and investigators identified recurring issues:
- Scope and subjects: whether the unprofessional-conduct code should apply to "licensees," "applicants," "registrants," "permit holders," or a broader phrase such as "persons authorized to practice," to cover compacts and other credential types.
- Notification clauses: many professions currently make it an offense to "fail to notify the board within a reasonable period of time" about disciplinary actions, criminal convictions, facility-level actions or abuse findings. Investigators cautioned that "reasonable period of time" is vague in enforcement practice and asked the board to consider clarifying intent and thresholds.
- Discrimination language: professions vary in wording and covered categories. Staff proposed considering a harmonized approach that refers to "protected classes under federal or state law," but social-work representatives cautioned that professional ethical codes sometimes include categories not covered by statutory protected-class lists.
- Sexual or romantic contact with clients: the crosswalk shows varying time limits and standards. Some professions prohibit relationships with current clients or supervisees; others impose a 24-month cooling-off period for former clients while one advisory group proposed a five-year standard. The board discussed whether the rule should bar relationships "ever" after professional care or adopt a fixed time window and whether practitioners must demonstrate a lack of exploitation in post-client relationships.
- Terms such as "registration," "credential," or "board/agency" differ across professions; staff proposed standardizing terminology while preserving profession-specific exceptions.
Members asked staff to circulate appendices that compare lengthy items side-by-side and to return with proposed uniform language for the board to consider and publish for public comment. Investigators stressed these rules directly affect how the complaint-review committee screens jurisdiction and drafts allegations.
