08/06/2026
In the State of Texas, there is a proposed rule change where a pre-licensed clinician will no longer has to apply to the Texas BHEC to retake the exam after failing three times.
Danny Marsh, MSW, LICSW, LCSW, LCSW-S, CFMHE, CFP provided the following feedback:
The folks on the Council appreciated my input and my comment is likely to be published:
I am writing to express my strong support for the proposed rule change removing the mandatory re-application and approval requirements for applicants who have failed an examination three or more times. Removing the requirement to re-apply and submit detailed study plans directly to the Council eliminates unnecessary administrative bottlenecks.
The current process creates delays for pre-licensed professionals seeking to re-take their licensing examinations, placing an undue burden on applicants and unnecessarily consuming Council resources. Removing this red tape directly benefits Texas by streamlining the pathway to full licensure and helping expand the behavioral health workforce to better serve communities across the state.
Clinical supervisors are already tasked with monitoring supervisee progress, professional growth, and competency. Supervisors are in the best position to provide targeted mentorship, identify specific clinical or knowledge deficits, and guide study remediation plans following failed examination attempts. Allowing supervisors and supervisees to manage exam preparation internally, without administrative Council intervention, preserves high standards of clinical oversight while ensuring a more efficient licensing process.
Thank you for proposing this practical rule modification to support mental health practitioners and improve access to care across Texas.
Thank you for all you do for Texas.
Respectfully Submitted,
Danny Marsh, MSW, LCSW, LCSW-S
Texas State Licensed Clinical Social Worker
Texas State Licensed Clinical Social Work - Supervisor
