Who BHEC Regulates
Section summaryBHEC administers licensure for psychologists (PhD/PsyD), licensed psychological associates (LPAs), licensed specialists in school psychology (LSSP), and licensure candidates. The Council also administers other behavioral-health professions; this article focuses on psychology.
The BHEC consolidated the administrative functions of four Texas behavioral-health boards (psychology, social work, marriage and family therapy, and professional counseling) into a single agency, while preserving the substantive rules of each constituent board. For psychologists, the rules are codified at 22 Tex. Admin. Code Title 22, Part 21.
Disciplinary Grounds
Section summarySection 501.451 of the Occupations Code lists grounds for discipline. The most common are unprofessional conduct, code-of-ethics violations, criminal conviction touching fitness to practice, and failure to comply with continuing-education or supervision requirements.
The TSBEP Rules of Conduct (formerly Texas Administrative Code Title 22, Part 21) define a detailed ethics framework. Specific complaint categories include:
- Sexual relationships with current clients (absolute prohibition).
- Sexual relationships with former clients within two years of termination (absolute prohibition; longer periods may also be prohibited depending on the nature of the relationship).
- Non-sexual boundary violations (gift-giving, business relationships, dual roles).
- Failure to maintain confidentiality.
- Forensic evaluation conduct that departs from the Specialty Guidelines for Forensic Psychology.
- Inadequate supervision of LPA or trainee.
Boundary and Dual Relationships
Section summarySexual contact with a current client is an absolute prohibition with strict liability. Non-sexual dual relationships are evaluated on a fact-specific basis but carry significant discipline risk where exploitation, harm, or impaired judgment is shown.
Boundary violations in psychology are evaluated under the Rules of Conduct and the APA Ethical Principles. Sexual contact with a current client violates both ethical standards and Texas Penal Code §22.011(b)(9) where the client is under the psychologist's professional care.
Non-sexual boundary issues — accepting gifts, providing personal services to a client, social or business relationships with current clients — are evaluated case-by-case. Documentation of clinical reasoning around any potential dual relationship is essential.
Forensic and Custody Cases
Section summaryCustody-evaluation complaints under Texas Family Code Chapter 107 are a leading source of psychology discipline. Complaints typically come from a parent dissatisfied with the evaluator's findings. The Specialty Guidelines for Forensic Psychology and the Guidelines for Child Custody Evaluations frame the standard of conduct.
Custody-evaluation work under Texas Family Code Chapter 107 is high-conflict. Parties often file complaints with both the BHEC and the court. The evaluator's documentation, methodology, and adherence to professional guidelines drive the disciplinary analysis.
Defensive practice in custody evaluation includes:
- Detailed engagement contracts and informed consent.
- Adherence to multiple-data-source methodology.
- Documented use of accepted assessment instruments.
- Documentation of contacts with collateral sources.
- Clear separation of opinions about the child's interests from advocacy for any party.
LPA Supervision Issues
Section summaryLicensed psychological associates practice under licensed psychologist supervision. Supervision lapses can produce discipline of both the LPA and the supervising psychologist. Common issues include inadequate documentation of supervision sessions, exceeding LPA scope, and supervisor unavailability.
LPA supervision rules require a written supervisory agreement, documented regular supervision contacts, and supervisor responsibility for the LPA's professional work. The supervising psychologist's vicarious liability for the LPA's conduct extends through the discipline process.
Investigative Process
Section summaryBHEC investigations follow the Texas APA framework. Intake, notice, written response, investigative workup, informal resolution conference (or referral), and either dismissal, agreed order, or SOAH litigation.
BHEC's investigative process tracks closely with other Texas boards. The most distinctive feature in psychology is the heavy use of code-of-ethics analysis — both the TSBEP Rules of Conduct and the APA Ethical Principles inform investigators' framing of allegations.
Sanctions
Section summarySanctions range from reprimand to revocation. Boundary-violation cases often produce sustained suspensions or revocation; standard-of-practice cases more commonly resolve with CE, supervised practice, and chart review.
The sanction range available to BHEC for psychologists:
- Reprimand
- Administrative penalty (capped per §501.504)
- Restriction (e.g., no forensic practice, no minor clients)
- Probation with monitoring and supervision
- Suspension (active or stayed)
- Revocation
Sex-based misconduct cases — sexual contact with clients, sexual exploitation, sexual harassment — typically draw the most severe sanctions and rarely resolve with less than a multi-year suspension.
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Texas State Board of Examiners of Psychologists Discipline matters begin with a written complaint that the board's staff investigates. The licensee typically receives a notice of investigation that summarizes the allegation in general terms. The licensee has a finite window — often 20 to 30 days — to respond. For a TSBEP matter, the response is the first strategic decision in the case and shapes the rest of the proceeding.
Counsel handling a TSBEP matter should evaluate the strength of the underlying complaint, the agency's likely evidence, and the licensee's exposure across multiple sanction levels. The response can be comprehensive (admitting agreed facts, reserving contested issues, framing the licensee's narrative) or minimal (denying allegations broadly, reserving all issues for formal proceedings). Each approach has strategic advantages and costs.
The response should be coordinated with any parallel criminal case. Statements made to the board can become evidence in the criminal forum. Where the criminal case is active, the administrative response may need to be limited or to invoke the Fifth Amendment. The board can draw adverse inferences from privilege invocation in administrative proceedings; counsel must weigh whether the inference cost exceeds the criminal-exposure cost.
Sanction Continuum
Texas State Board of Examiners of Psychologists Discipline matters resolve across a sanction continuum from informal letter (the lightest, often non-public), through advisory letter, formal reprimand, fines, conditions on practice, suspension, and revocation. The right strategic target depends on the strength of the State's evidence, the licensee's history, and the agency's internal calibration.
For a TSBEP matter, counsel should map the likely sanction range early and negotiate toward the best feasible outcome. Where the evidence is strong and a public sanction is unavoidable, counsel should focus on minimizing the sanction's severity and on shaping the public-record language. Where the evidence is contestable, counsel should consider whether contesting through SOAH produces a better expected outcome than accepting an Agreed Order.
The public-record consequences of any formal sanction are significant. Most Texas boards maintain searchable disciplinary databases that anyone can access. The record persists for the duration of the license and often beyond. Counsel should always discuss the public-record dimension with the client before recommending any disposition.
The Texas State Board of Examiners of Psychologists framework
The Texas psychology licensure framework now operates under the Texas Behavioral Health Executive Council with profession-specific committees handling psychologist discipline. The substantive framework derives from Texas Occupations Code Chapter 501 and the related rules. The framework covers licensed psychologists, licensed psychological associates, and various related categories of psychological professionals.
The disciplinary grounds include unprofessional conduct, boundary violations, fraudulent practice, conviction of specific offenses, departures from psychological practice standards, and various other categories. The framework provides substantial scope for disciplinary action across the diverse psychology practice contexts. The defense must address both the specific grounds and the broader psychology regulatory context.
The investigation framework operates through the unified BHEC administrative structure with profession-specific input on substantive matters. The investigations include review of clinical records, interviews with clients and other parties, examination of practice materials, and consultation with psychology experts. The respondent has rights to notice and to participate in the investigation through counsel.
The psychological assessment and the testing framework
The psychological assessment framework addresses the use of psychological tests and assessments in various contexts including clinical practice, forensic practice, employment evaluation, and various other applications. The framework includes specific requirements for test selection, administration, interpretation, and reporting. Failures in assessment practice can produce disciplinary action and parallel civil exposure.
The forensic psychology cases involve special considerations because of the substantial impact of psychological testimony on legal proceedings. Forensic psychologists must comply with both general psychology practice standards and specific forensic practice standards. The cases can involve allegations of inappropriate assessment methodology, exceeding the scope of competence, or various other issues.
The defense in psychological assessment cases requires expert engagement with practicing psychologists in the specific assessment area. The expert testimony can address the appropriate methodology, the interpretation of the assessment results, and the broader practice standards. The expert input can substantially affect the case analysis and the disposition.
The boundary violation framework in psychology practice
The boundary violation framework in psychology practice addresses the appropriate boundaries between psychologists and clients. The framework includes specific concerns about sexual contact, financial arrangements beyond professional fees, dual relationships, and various other forms of inappropriate boundary crossing. The framework reflects the substantial power differential between psychologists and clients in therapeutic relationships.
The sexual boundary cases are among the most serious psychology discipline matters and typically produce substantial sanctions including license revocation. The framework typically includes specific timing requirements for any post-termination contact with former clients. The defense in sexual boundary cases must address both the substantive allegations and the broader professional ethics framework.
The dual relationship cases address situations where psychologists have multiple roles with the same client. The defense can sometimes succeed in cases where the dual relationship was unavoidable or where the alleged dual relationship did not actually compromise the therapeutic relationship. The defense should examine the specific circumstances and the broader context.
Disposition framework and the practice implications
The disposition framework in psychology discipline cases includes various negotiated outcomes and contested litigation. The negotiated outcomes can include continuing education requirements, supervised practice arrangements, practice restrictions, license suspensions, and license revocations. The disposition options should be evaluated against the realistic litigation outcomes and the comprehensive practice implications.
The practice implications of psychology discipline include effects on insurance contracts, employment opportunities, professional standing, and various other practice considerations. Public discipline affects the psychologist reputation and the ability to maintain various professional relationships. The defense should address these comprehensive implications when evaluating disposition options.
The interstate practice implications affect psychologists who practice in multiple states. The PSYPACT interstate compact for psychology practice affects how Texas discipline may affect practice in other compact states. The defense should consider these interstate implications and should structure dispositions to support continued interstate eligibility where possible and consistent with the Board concerns about the specific conduct.
Frequently Asked Questions
Are BHEC complaints public?
Can an LSSP (school psychology specialist) be disciplined?
What if a custody-evaluation complaint is filed by an unhappy parent?
Does BHEC report to other states?
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If you are facing a situation described here, consult counsel promptly. Many issues in this area run on strict deadlines.
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Cite this guide
Bluebook: Reggie London & Njeri London, Texas Psychology Board Discipline, L&L Law Group (May 30, 2026), https://landllawgroup.com/insights/texas-psychology-board-discipline/.
APA: London, R., & London, N. (2026, May 30). Texas Psychology Board Discipline. L&L Law Group.