SB 993 amends four Business and Professions Code provisions that require therapists to give clients a printed notice with Board of Behavioral Sciences contact information and the clinician’s name, license number, license type, and expiration date. The bill authorizes an employing entity in narrowly defined high‑risk practice settings—acute psychiatric hospitals, correctional treatment centers, and facilities housing incarcerated patients—to redact any or all of those identifying details in the client notice when there are individual safety concerns, provided the employer has a disclosed process that lets clients request the necessary identification to file complaints and preserves a copy of the notice in the client’s record.
This change shifts part of the transparency burden away from clinicians to employing entities in confined settings and creates a formal pathway for complaint filing that does not require public display of clinician identifiers. Compliance officers in health systems, correctional health administrators, and counsel for behavioral health providers will need to build, document, and retain request-and-release procedures, update intake materials, and reconcile the change with existing Board complaint workflows and recordkeeping rules.
At a Glance
What It Does
The bill inserts an exception to existing therapist notice rules: in three specified practice settings an employer may withhold full clinician identification from the client notice if (1) there is an established process by which a client can request and obtain the identifying information needed to file a complaint with the Board, (2) that process is disclosed in the notice, and (3) a copy of the notice is kept in the client record. If exercised, the employing entity or the clinician must ensure the process exists.
Who It Affects
The amendments cover marriage and family therapists, licensed educational psychologists, clinical social workers, and professional clinical counselors and apply only in acute psychiatric hospitals, correctional treatment centers, and other settings serving incarcerated individuals. Employers (hospitals, correctional health providers, county jails, state prisons) carry operational responsibility for the new process; the Board of Behavioral Sciences remains the complaints authority.
Why It Matters
SB 993 creates a formal avenue to protect clinician safety in constrained environments while preserving clients’ ability to access Board complaint information — but it also decentralizes how identifying information is made available, moving enforcement and audit attention to employers and their intake/records systems. That matters for licensing compliance, risk management, and litigation exposure in correctional and inpatient psychiatric care.
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What This Bill Actually Does
Current California law requires certain behavioral health professionals to hand clients a short, large‑type notice telling clients that the Board of Behavioral Sciences handles complaints, and to include the clinician’s full name, license number, license type, and license expiration date. SB 993 leaves that baseline in place for most settings but creates a narrowly tailored exception for situations where publishing those identifiers could endanger the clinician or compromise safety.
Under the bill, the employing entity in an acute psychiatric hospital, a correctional treatment center, or any setting where incarcerated people receive mental health care may choose to omit some or all identifying elements from the printed notice if the employer determines there are individual safety concerns. That choice is conditional: the setting must have a documented procedure by which a client can request and receive sufficient identification to file a complaint with the Board, the notice delivered to the client must say how to use that procedure, and a copy of the notice must be retained in the client’s record.Practical effects will flow through intake and records operations.
Employers need written procedures explaining who receives requests, what qualifies as “sufficient identification,” how quickly information is provided, and how the interaction is logged. Clinicians in those settings will no longer be required to display their full identifying details at intake when the employer invokes the exception, but they remain subject to Board discipline and complaints can still be filed if clients use the employer’s request mechanism.
The bill assigns responsibility for ensuring the process exists to the licensee or registrant (and in some provisions to the employing entity), creating a shared compliance obligation between clinicians and their employers.Because the statutory edits target four separate licensing sections, administrators should update each profession’s intake templates and train staff who manage client access requests. The legislation keeps the Board’s complaint jurisdiction intact and requires documentation that the notice was delivered; it does not change substantive licensing standards or the Board’s investigative powers.
The Five Things You Need to Know
The employer may redact any or all of a clinician’s name, license or registration number, license type, and expiration date from the client notice in the three enumerated practice settings.
The exception is conditional: the setting must have an established process by which a client can request and obtain sufficient identification to file a complaint, and that process must be disclosed in the notice.
A copy of the delivered notice must be preserved in the client’s records to demonstrate compliance with the disclosure requirement.
When an employer exercises the discretion to withhold identifying information, the licensee or registrant (and in some instances the employing entity) is responsible for ensuring the request-and-provide process exists and operates.
The statutory edits amend four Business and Professions Code sections that govern different professions: marriage and family therapists (4980.32), licensed educational psychologists (4989.17), clinical social workers (4996.75), and professional clinical counselors (4999.71).
Section-by-Section Breakdown
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Marriage and family therapists: employer discretion and documentation
This section modifies the MFT notice rule to let an employing entity or agency in acute psychiatric, correctional treatment, or incarcerated‑person settings decide whether to include the clinician’s identifying details in the printed Board notice when there are individual safety concerns. If the employer elects to omit info, it must both disclose to the client how to request the identifying details and keep a copy of the notice in the client chart. The provision explicitly makes the licensee responsible for ensuring the request process exists, shifting an operational duty onto clinicians who practice in these environments.
Licensed educational psychologists: conditional omission with process disclosure
For educational psychologists the amendment adds the same safety‑based exception, but the text ties the change to an on‑and‑after July 1, 2025 effective framing and phrases the responsibility as falling to the licensee to ensure the request process. Practically, school districts, county offices of education, and contracted providers serving detained youth must craft intake practices that balance student safety with parents’ or guardians’ ability to obtain complaint‑filing identifiers.
Clinical social workers: employer process and record retention
The clinical social worker provision repeats the exception language and emphasizes preservation of the client notice in the record. That retention requirement creates an audit trail: employers and clinicians must be prepared to produce the notice showing the process disclosed and the factual basis for withholding identifiers if a compliance review or Board inquiry occurs.
Professional clinical counselors: operational responsibilities in custodial settings
This section brings professional clinical counselors into alignment with the other professions and clarifies that discretion to omit identifying information applies across correctional and inpatient psychiatric contexts. Administrators running jail, prison, and contracted correctional mental health programs need to adopt formal request protocols and train staff on timeliness, authentication, and documentation to satisfy both the statutory disclosure and the Board’s complaint‑handling needs.
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Who Benefits
- Clinicians working in inpatient psychiatric units and correctional settings – benefit from reduced public exposure of identifying details when safety risks exist, lowering the immediate risk of harassment or retaliation.
- Employing entities (hospitals, county and state correctional health providers) – gain flexibility to protect on‑site staff by centralizing control over how and when identifying information is released and can design secure processes for complaint facilitation.
- Incarcerated and severely vulnerable clients – may receive care without clinicians fearing retaliation in confined settings, potentially preserving service availability where staffing risks are otherwise high.
- Risk managers and compliance teams – receive a clear, statutory mechanism to reconcile clinician safety with client access to regulatory remedies, allowing documented procedures to demonstrate compliance in audits or litigation.
Who Bears the Cost
- Employing entities and contracted providers – must design, implement, staff, and document a robust request-and-release procedure, adding administrative costs and training obligations.
- Licensees and registrants – face a new compliance duty to ensure the employer’s process exists and operates; clinicians may also face scrutiny if an employer’s process fails and a complaint cannot be filed promptly.
- Clients and complainants – encounter an additional step to obtain identifying information needed to file a Board complaint, which could delay or deter reporting of misconduct.
- Board of Behavioral Sciences – may see operational friction as complaints come via employer-mediated channels and may need to adapt intake procedures or guidance to handle complaints initiated without immediately visible license identifiers.
Key Issues
The Core Tension
The central dilemma is safety versus transparency: the bill protects clinicians from exposure in high‑risk, confined environments by permitting redaction, but every step that reduces public visibility of license information potentially increases the friction for clients seeking regulatory recourse—so lawmakers and implementers must decide whether safety gains justify adding procedural barriers to accountability.
The bill tries to thread a narrow needle—protecting clinician safety in settings where public disclosure of identity could be dangerous while preserving a client’s path to file a complaint. That balance raises practical questions.
The statute requires an "established process" that provides "sufficient identification," but it does not define the evidentiary content, acceptable timelines for disclosure, authentication standards for requesters, or whether request denials must be documented with reasons. Those unresolved operational decisions will determine whether the exception is a safety tool or a barrier to accountability.
Another tension is accountability versus centralization. By shifting the disclosure function to employers, the law concentrates operational control in institutions that may themselves be the subject of complaints.
Employers will need rigorous policies to prevent misuse—either by overbroad redaction that thwarts Board access or by inconsistent practices that produce unequal access across facilities. The statute also creates potential enforcement questions: how will the Board evaluate whether an employer’s process is "established" or timely?
Finally, the amendments insert differing phrasing across four code sections (some tie responsibility to the licensee, some to the employing entity), which could generate disputes about who bears legal liability when the process fails.
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