HB 3330: Behavioral health licensure data bill FAQ

House Bill 3330 by Rep. Cynthia Roe (R-Lindsay) and Sen. Paul Rosino (R-Oklahoma City) would direct state licensure boards to ask a standard set of questions on behavioral health licensure applications and renewals for more robust data collection. Because Oklahoma mental health and substance use professionals are licensed by several state boards, which each collect different data from licensees, Oklahoma lacks consistent, standardized information about the state’s behavioral health workforce.  

For example, licensure boards currently do not capture whether Oklahoma’s behavioral health professionals use their licenses to provide direct services, and if so, how often. Some licensees may maintain their licensure but work in other fields, or they may only see a small patient caseload. Without insight into nuances about how licensees work, we’re left with an incomplete picture of the state’s behavioral health workforce.  

Similarly, licensure boards currently do not collect important demographic information that can show whether the state’s behavioral health workforce is reflective of the populations it serves.  

In response to privacy and data collection concerns surrounding HB 3330, Healthy Minds collected and answered frequently asked questions about the bill and the changes it proposes.

Which licensure boards would be impacted by HB 3330?

• Psychologists, licensed by the State Board of Examiners of Psychologists
• Licensed professional counselors and licensed marriage and family therapists, licensed by the State Board of Behavioral Health Licensure
• Licensed clinical social workers, licensed by the State Board of Licensed Social Workers Alcohol
• Drug counselors, licensed by the Board of Licensed Alcohol and Drug Counselors  

What data would HB 3330 require boards to collect that they don't already collect?

To better gauge the health and needs of Oklahoma’s behavioral health workforce, HB 3330 would direct licensure boards to ask applicants:

• Their race, gender, and date of birth
• The languages they speak
• Whether an individual has multiple behavioral health licenses
• Their projected year of retirement
• The counties in which they provide services
• How many hours per week (1-10, 11-20, 21-30, 30+ hours) they use their license(s) to provide direct services

The bill would add only eight additional questions to an initial application for licensure, and these would not require any verification or paperwork for licensure boards.

For renewal applications, the bill would only add six questions, since an individual’s race and date of birth would never change from their original application.

Where would the data go, and how would it be used?

• The data collected at initial application or renewal would be kept at applicants’ respective licensure boards. De-identified data would be sent to the Oklahoma Department of Mental Health and Substance Abuse Services (ODMHSAS) to publish an annual report on the state of the behavioral health workforce. ODMHSAS would not possess any identifiable data.  

Would ODMHSAS see all information I submit when applying for or renewing my license?

• No. ODMHSAS would only receive deidentified data, meaning it would not be tied to an individual’s name or license number.
• The bill makes no changes to what information about a provider would be publicly available through licensure boards’ websites. No additional information tied to a name or license number would be shared publicly.

Why are these changes necessary?

• Knowing the race, gender, and languages spoken by providers can allow policymakers, researchers, and other stakeholders to see how well the behavioral health workforce reflects Oklahoma’s population.
• Understanding where and what services a clinician provides is helpful in determining where the state has gaps in its workforce.
• It is important to know if a provider holds multiple licenses to avoid inflating Oklahoma’s workforce counts. Similarly, current data about Oklahoma’s workforce cannot distinguish between a person providing direct services full-time and a person who maintains licensure but does not provide direct services or does so in a limited capacity. Capturing these data points would ensure Oklahoma’s provider counts show an accurate picture of the providers directly serving Oklahomans.
• Capturing providers’ dates of birth is useful to estimate how long a person will stay in the workforce. A person’s age is a more accurate indicator for predicting how long they will remain in the workforce than the year they graduated.
• Understanding providers’ estimated retirement age would inform how many new providers would be needed to replace the outgoing workforce and help higher education programs adapt accordingly to meet the needs of the workforce.

Is collecting this data violating my right to privacy?

• The licensure boards collect personal information and records to verify that someone is eligible and meets the qualifications set forth by the state to protect consumers. Some boards already collect some of the data HB 3330 would require, but these metrics are not tracked consistently from board to board.  
• Data collected would be de-identified and aggregated, meaning that responses would not be tied to an individual provider’s name or license number. Information that is already public would remain public.
• This data is like data collected when a provider gets a National Provider Identifier (NPI) number, which any provider who sees Medicaid consumers would already have.  

Is this bill tied to the Health Information Exchange (HIE)?

• No, there is no connection between information collected by licensure boards about licensees and the state HIE. The HIE only involves patients’ medical records being shared electronically between providers.  

Would HB 3330 make all behavioral health licensure applications the same across licensure type?

• No. Each board has different specifications for each unique license type.
• The bill would not impact any licensure, certification, or education requirements.  

Couldn’t ODMHSAS just send out a voluntary questionnaire?

• Possibly, but a voluntary questionnaire likely wouldn’t receive the responses needed to capture a representative sample of the state’s behavioral health workforce.
• In 2022, Healthy Minds Policy Initiative conducted a workforce-specific survey of licensed behavioral health professionals across the state. For the license types that would be affected by HB 3330, the survey received 617 responses out of the 12,407 professionals we contacted – less than 5%.

Do other licensure boards collect demographic information or workforce practice trends?

• Both state licensure boards for physicians (the Oklahoma Board of Medical Licensure and Supervision and Oklahoma State Board of Osteopathic Examiners) list the languages doctors speak aside from English, their practice address, and education details.
• Several licensure boards ask for demographic and personally identifying information.
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