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Advisory committee reviews proposed regulatory edits; flags physician-consult rule for further study

December 04, 2025 | Behavioral Sciences Regulatory Board, State Agencies, Organizations, Executive, Kansas


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Advisory committee reviews proposed regulatory edits; flags physician-consult rule for further study
At its Dec. 3 meeting the advisory committee considered several regulatory items and reached consensus on one recommended change while tabling further action on another. Members agreed to recommend amending KAR 102-4-6a to include 'internship' and to remove references to 'face-to-face' and 'on-site' supervision to reflect contemporary virtual supervision practices; the recommendation will be forwarded to the board for its consideration.

The committee also reviewed KAR 102-4-14, a regulation tied to the statute that directs licensees to consult a client’s primary-care physician or psychiatrist when symptoms of a mental disorder are present. Leslie Allen read the statute-based requirement for the group: "when a client has symptoms of a mental disorder, a licensee under the act shall consult with the client's primary care physician or psychiatrist to determine if there may be a medical condition or medication that may be causing or contributing to the client's symptoms of a medical mental disorder, and that a client may request in writing that such consultation be waived." Members raised practical questions: whether consultation is required for every diagnostic evaluation, how to proceed when a client lacks a primary-care physician, how the rule applies in school settings, and whether the regulation’s language is an artifact of practice patterns from 1999–2000. Given those questions the committee did not recommend immediate edits to KAR 102-4-14 and asked staff to return with comparative language and additional context.

On KAR 102-4-16 (services rendered to individuals located within the state), staff explained the regulation clarifies that jurisdiction for requiring a license depends on the client’s location; the committee reviewed the item and had no recommended changes.

The committee will revisit the physician-consult regulation with additional legal and practice context before deciding whether to propose regulatory language changes.

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