A Texas group practice has to track five things for each LPC Associate. They are the supervisory agreement, at least four hours of supervision in every month, the hours counted toward the 3,000 required, the supervisor's written session record and the supervisor's license status. The practice must also show the Associate's supervised status on every bill and every marketing page.
These rules are in 22 TAC chapter 681, written by the Texas State Board of Examiners of Professional Counselors. On August 7, 2026 the Texas Behavioral Health Executive Council proposed changes to three of them. We found no notice that the Council adopted them in any Texas Register issue through October 16, 2026, so this guide states the text now in force and marks each proposed change.
What hours and time must a Texas LPC Associate complete?
A Texas LPC Associate must complete 3,000 clock-hours of supervised experience over at least 18 months, and at least 1,500 of those hours must be direct client counseling. The rule sets the three numbers in 22 TAC §681.92(a), (b) and (c). Only actual time spent counseling counts as direct client contact.
The hours count only if the Associate held the license when they were earned. 22 TAC §681.91(c) says so in plain words.
Hours obtained by an unlicensed person in any setting will not count toward the supervised experience requirements.
A new graduate should not see clients under the practice's supervision plan until the board has issued the LPC Associate license. The supervisor must also confirm that the Associate earned the experience after the license was issued and over not less than 18 months, under 22 TAC §681.93(f).
How much supervision must a Texas LPC Associate receive each month?
A Texas LPC Associate must receive a minimum of four hours of supervision per month, and no more than 50% of all supervision hours may be in a group. This is the wording of 22 TAC §681.92(e).
The LPC Associate must receive direct supervision consisting of a minimum of four (4) hours per month of supervision in individual (up to two Associates) or group (three or more) settings while the Associate is engaged in counseling unless an extended leave of one month or more is approved in writing by the Council approved supervisor. No more than 50% of the total hours of supervision may be received in group supervision.
The rule states the four hours as a minimum for each month, so the practice tracks each month on its own. The Texas Behavioral Health Executive Council's supervision FAQs say the hours can be divided and scheduled through the month by agreement between the Associate and the supervisor. The same FAQs say a supervisor and Associate may meet for more than four hours but are not required to.
For each Associate, track the individual hours, the group hours, the group share of the running total and any leave of one month or more. A leave needs the supervisor's written approval. 22 TAC §681.93(a)(1)(E) also requires a leave record signed by both the Associate and the supervisor.
What must a Texas LPC supervisor keep in the supervision file?
A Texas LPC supervisor must keep a written record of each supervisory session in the file for the LPC Associate, and must give the Associate a copy of all records on request. Both duties are in 22 TAC §681.93(a). The rule lists seven items for the file.
The supervisor also owes the board a filing when supervision ends. 22 TAC §681.93(d) sets the deadline.
The supervisor must submit to the Council accurate documentation of the LPC Associate's supervised experience within 30 days of the end of supervision or the completion of the LPC Associate's required hours, whichever comes first.
The board's FAQs say the rules do not set a retention period for supervision records. They advise keeping the records at least until the Associate is fully licensed, or giving them to the Associate when supervision ends, as the board's supervision FAQs explain.
Who is responsible for a Texas LPC Associate's work and records?
A Texas LPC Associate and the Associate's LPC supervisor are both fully responsible for the Associate's counseling activities, and the entity that employs or contracts with the Associate is responsible for the client records. The first duty is in 22 TAC §681.93(b).
Both the LPC-Associate and the supervising LPC-S are fully responsible for the professional counseling activities of the LPC-Associate.
The same subsection says the supervisor may face discipline for violations the supervisor knew about or, because of the oversight role, should have known about. The records duty is in 22 TAC §681.91(j), which puts the possession, access, retention, control, maintenance and destruction of client records on the person or entity that employs or contracts with the Associate. In a group practice, that is the practice.
The supervision duties name the supervisor and the Associate, not the practice. A practice owner still needs the dates, because a missed month or a lapsed license falls on the people the practice employs.
What happens to a Texas LPC Associate's hours if the supervisor's license expires?
A Texas LPC supervisor whose license has expired is no longer an approved supervisor, and hours accumulated under that supervisor after the expiration date may not count. This is the rule in 22 TAC §681.93(g).
A supervisor whose license has expired is no longer an approved supervisor and: (1) must immediately inform all LPC Associates under his or her supervision and assist the LPC Associates in finding alternate supervisors; and (2) must refund all supervisory fees for supervision after the expiration of the supervisor status. (3) Hours accumulated under the person's supervision after the date of license expiration may not count as acceptable hours.
One expiration date can end the supervision of every Associate under that supervisor on the same day. Track each supervisor's license expiration date and status from the board's online verification, and list the Associates beneath each supervisor. Subsection (h) of the same section says supervisor status is revoked when the Council executes an order of probated suspension, suspension or revocation of the supervisor's license.
If an Associate pays for supervision, the supervisor owes the refund in (g)(2) for every session after the expiration date. Keep the fee record by month so the refund can be calculated.
Who may supervise a Texas LPC Associate?
Only a Texas LPC with supervisor status may supervise an LPC Associate in Texas, and supervising without that status is grounds for disciplinary action. 22 TAC §681.92(a)(1) states the first point and 22 TAC §681.93(i) the second.
To apply for supervisor status, an LPC must have held the license in good standing for at least 60 months, submit an application and fees and submit a completion certificate for an acceptable supervisor training. 22 TAC §681.72(d) lists the two kinds of training. They are a doctoral-level course in supervision or a 40-clock-hour supervision course.
Four limits shape how a group practice assigns supervisors.
- A Texas LPC Associate may have no more than two Council-approved LPC supervisors at any given time, under 22 TAC §681.91(e).
- The supervisor may not be related to the Associate within the second degree of affinity or the third degree of consanguinity, under 22 TAC §681.93(c)(1).
- The supervisor may not be an employee of the Associate, under §681.93(c)(2).
- The Associate may pay a supervisor for supervision time only if supervising is not part of the supervisor's responsibilities as a paid employee, under 22 TAC §681.91(k).
Sections 681.91, 681.92 and 681.93 set no maximum number of Associates for one supervisor.
What must a Texas practice show on an LPC Associate's bills and marketing?
Every billing document for services by a Texas LPC Associate must show that the Associate holds an LPC Associate license and is under supervision. 22 TAC §681.91(l) sets that rule. The next subsection adds a naming rule that reaches the practice's website and intake forms.
The LPC Associate must not represent himself or herself as an independent practitioner. The LPC Associate's name must be followed by a statement such as "supervised by (name of supervisor)" or a statement of similar effect, together with the name of the supervisor. This disclosure must appear on all marketing materials, billing documents, and practice related forms and documents where the LPC Associate's name appears, including websites and intake documents.
The citation is 22 TAC §681.91(m). When a supervisor changes, every place that names the old supervisor needs the new name.
How long does a Texas LPC Associate license last, and when does supervision end?
A Texas LPC Associate license expires 60 months from the date of issuance, and supervision continues until the Associate receives the LPC license, even after the 3,000 hours are complete. These points are in 22 TAC §681.91(g), (h) and (i).
Supervision is complete upon the LPC Associate receiving the LPC license.
An Associate who does not finish the hours within the 60 months must reapply for licensure. The board's supervision FAQs say hours already completed carry over if appropriate records are submitted to the board. The Associate needs the supervisor to submit a Supervised Experience Documentation Form, so the file in the section above decides whether the hours can be proved.
Which of these rules has the Texas board proposed to change?
The Texas Behavioral Health Executive Council proposed changes to §681.91, §681.92 and §681.93 in the August 7, 2026 Texas Register, and we found no notice of adoption in any issue through October 16, 2026. The comment period closed September 6, 2026, which was also the earliest possible adoption date. Until the Council adopts them, the text above governs. The proposals are numbered TRD-202603110, TRD-202603112 and TRD-202603113.
The proposals would make these changes. Final text may differ.
- Section 681.92(e) would change "a minimum" of four hours per month to "an average" of four hours per month. The proposed text does not state the period over which the average is taken.
- Section 681.91 would require an LPC Associate to notify supervisors within 15 business days of receiving notice of a pending complaint. It would also require the Associate to give a copy of a supervision remediation plan to other current supervisors and to any new supervisor.
- Section 681.91(d) would state that an Associate may own and operate a private practice while under supervision.
- Section 681.93 would require a supervisor to set a plan for custody and control of the supervision records if the supervisor dies, becomes incapacitated or ends the practice. It would also bar a supervisor from receiving extra pay for supervision that is part of the supervisor's paid responsibilities, and it would amend subsection (h), the rule that ends supervisor status when the Council suspends, revokes or puts the supervisor's license on probated suspension.
- Section 681.92(f) would let an applicant with a qualifying master's degree count supervision and experience gained after the degree as part of a doctoral program.
What to do this week
- List every LPC Associate and each Associate's supervisors. Confirm that no Associate has more than two.
- Record each Associate's license issue date and the date 60 months later. Confirm that no client hours were counted before the issue date.
- Look up each supervisor on the board's online license verification. Put each expiration date on a calendar, with the Associates listed under each supervisor.
- Start a monthly supervision log with one row per Associate per month. Use these columns: supervisor, individual hours, group hours, total, group share of the running total and leave approval. Mark any month under four hours.
- Check each supervisor's file against the seven items in the table above.
- Search the website, intake forms and claim forms for each Associate's name. Each one needs "supervised by" and the supervisor's name.
- Name the person who files the 30-day documentation when supervision ends, and add the step to the offboarding checklist for supervisors and Associates.
- Set a date to check whether the Council has adopted the three proposals.
Where Practice Pillar fits
Practice Pillar, software for therapy group practices, states on its operations page that a license counts as current only when the board's status and the expiration date both say so. Its clinical record page says each cosignature a supervisor owes has a due date and that supervision hours are counted against the licensing board's schedule. A spreadsheet can hold every item in this guide.
Sources
- Texas Administrative Code, title 22, part 30, chapter 681 (§§681.72, 681.91, 681.92 and 681.93), Texas Secretary of State. Checked October 19, 2026.
- Texas Register, August 7, 2026, proposed rules, title 22 Examining Boards, Texas Secretary of State. Shows the existing text of §§681.91 to 681.93 with each proposed change marked. Checked October 19, 2026.
- Texas Register, October 16, 2026 issue and the issues back to August 14, 2026, searched for an adoption notice for chapter 681. Checked October 19, 2026.
- Supervision FAQs, Texas Behavioral Health Executive Council. Checked October 19, 2026.
- 22 TAC §681.91, §681.92, §681.93 and §681.72, Cornell Legal Information Institute copies used to read the text. Checked October 19, 2026.
Changes to this guide
- Published, signed by Practice Pillar Editorial Staff.
- First draft. Rules checked against the current text of 22 TAC §§681.91 to 681.93 as the Texas Register printed it on August 7, 2026.
This guide explains the rules it cites. It is not legal advice.