Board committee weighs safety, scope questions after SB 1024 notice requirement

The California Board of Behavioral Sciences Policy & Advocacy Committee on Oct. 24 heard testimony that the statutory disclosure required by SB 1024 may put some clinicians — and their families — at risk when they work in high‑security settings.

Roseanne Helms, the board’s legislative manager, told the committee that SB 1024 (enacted in 2024 and effective in 2025) amended the board’s display and notice rules to require that licensees and registrants provide in the required notice to consumers their full name as filed with the board, a license or registration number, the license or registration type, and the expiration date “prior to initiating psychotherapy services,” to ensure transparency in telehealth and other settings. Helms said staff have heard two recurring concerns: safety risks for clinicians working with incarcerated populations and confusion about whether the notice must be provided only when psychotherapy is actually delivered or for any activity within a licensee’s scope of practice.

Leahina Claytor, a licensed clinical social worker who said she provides care inside a county jail under a vendor contract with the Department of State Hospitals, described why a broad public disclosure could be dangerous. “If I’m continued to be required to share my full name and license number, I lose that final layer of protection,” Claytor said, adding that she relies on anonymity outside the facility to protect herself and her family. Claytor described current onsite practices — initials or first‑name use with badges in secure units, multiple internal reporting channels (grievance boxes, sick‑call and program slips), and electronic records held by the facility and the Department of State Hospitals — and suggested that using an internal grievance process to provide investigators with a clinician’s full license details could preserve patient access to complaint mechanisms while limiting public exposure of staff identities.

Committee members noted the competing policy goals: worker safety and practitioner privacy versus the public’s right to identify and verify providers. Kelly Ranasini and other members said the issue raises privacy and constitutional considerations and asked staff to gather more information and stakeholder perspectives, including representatives from state hospital programs and county correctional systems. Roseanne Helms told the committee that any statutory change would require the legislative process and likely take about a year; regulatory changes would also be possible but would take time.

No committee motion to change the law was made at the meeting. The committee directed staff to return to a future Policy & Advocacy Committee meeting with a more detailed presentation and additional stakeholder input before recommending legislative or regulatory action.

The discussion also referenced statutory exemptions now in law for certain licensed facilities under the Health and Safety Code (facilities cited included general acute care hospitals, psychiatric hospitals, correctional treatment centers and nursing facilities) and compared the board’s notice rule to Business and Professions Code provisions governing psychologists’ disclosures. Staff noted potential policy options including limiting the required public notice to license/registration numbers with an online lookup or creating narrowly drawn exemptions or administrative‑entity discretion for high‑risk settings.