Board debates exam fairness, alternative pathways and oversight of coaches; adds protection for marginalized communities to priorities
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Summary
Stakeholder criticism that national licensing exams contain cultural and linguistic bias surfaced at the Board of Behavioral Sciences strategic session, prompting a commitment to workshop objectives and place bias assessment and alternative pathway review into the action plan. Board members also raised concerns about unregulated 'coaches' and electronic health-record privacy for vulnerable clients, and proposed a new goal to protect marginalized groups.
During the Feb. 19 strategic planning session, external stakeholder input included repeated concerns that examination content and test-development processes can disadvantage some candidates and underrepresent cultural perspectives. Board members and staff discussed how to reflect that concern in a public strategic plan without creating legal exposure: several members argued the plan should explicitly require review and mitigation of biases in exams; others urged cautious wording and treating detailed bias analysis as an action-plan task.
The board reviewed objectives for examination reform: review exam eligibility timing to streamline licensure pathways, improve candidate resources and preparation materials, and expand recruitment of subject-matter experts for exam development. Members suggested adding explicit tasks to measure disparate outcomes (exam pass rates, processing times) and to commission evidence-based bias assessment rather than asserting conclusions in the plan.
Discussion also extended beyond exams. Board members flagged the rapid growth of non‑licensed mental‑health providers — "life coaches" or "wellness coaches" and other paraprofessionals — who advertise therapeutic services. Members asked staff to track developments, coordinate with other state agencies (for example, HCAI where relevant), and explore whether better consumer communication, registration or regulation is needed to protect the public.
A separate thread produced a new proposed goal focused on protection and support for marginalized and endangered communities. Proposed objectives included issuing guidance and memos (for example, how clinicians should handle law-enforcement requests for clinical files), resources for clinicians working with at-risk groups, and reviewing obligations related to storage and access of confidential records in third-party electronic health records. Members suggested concrete action items — one‑page guidance memos, training resources, and coordination with other state boards — to quickly provide clinicians practical steps to protect clients.
The board did not adopt final legal language during the meeting; staff were directed to convert the topics into task-level action plans and to return draft language vetted with counsel. That work will inform future regulatory or legislative proposals if the board elects to pursue them.
