DORA Summaries

Regulatory Updates: Key Takeaways from the Department of Regulatory Affairs Meeting

The latest Department of Regulatory Affairs (DORA) meeting reviewed multiple complaints against Marriage and Family Therapists (MFTs) in Colorado. Below are the key takeaways on complaint trends and decision-making patterns:

Common Complaints

• Supervisory concerns: Issues related to unclear guidance, discontinuity in communication, and harsh feedback.

• Dual relationships: Allegations of engaging socially with individuals receiving wellness checks; cases dismissed when documentation confirmed professional boundaries.

• Documentation issues: Complaints of substandard or falsified records; strong documentation helped dismiss concerns, while incomplete records led to deeper review.

• Ethical violations: Alleged HIPAA breaches, failure to report concerning client disclosures, and conflicts of interest in co-parenting cases.

Decision-Making Patterns:

• Dismissals: Many cases were dismissed due to a lack of evidence, clear documentation, or jurisdictional limitations. For example, in one case, a client alleged that a clinician in a high-conflict co-parenting case recommended medication and engaged in countertransference. Upon review, the Board found no evidence that the clinician had recommended medication and determined that the claims of countertransference were actually misinterpreted therapeutic techniques aimed at building rapport (“joining”). The Board ultimately viewed the complaint as retaliatory in nature rather than a substantiated ethics violation. This highlights the importance of maintaining thorough documentation and clearly communicating therapeutic intent, especially in contentious cases.

• Deeper Reviews: Cases involving documentation deficiencies, mandated reporting failures, and supervision-related concerns were examined further.

• Disciplinary Actions: A case involving a voluntarily suspended license in another state and unprofessional conduct moved to executive session for potential action.

Best Practices for MFTs

Clear and consistent documentation: Maintain thorough records of clinical decision-making, especially when modifying treatment plans, clarifying roles, or referring family members to another provider. For example, if transitioning a client from individual therapy to couple or family therapy, document the rationale for the change, client consent, and the impact on treatment goals. One case reviewed involved concerns about dual relationships and role clarity, and the Board requested documentation outlining treatment transitions, consent forms, and court decrees to verify appropriate clinical decision-making. Strong documentation protects both the therapist and the client in the event of a complaint.

Strong professional boundaries: Be mindful of how long-standing therapeutic relationships may impact objectivity. In one case, a clinician worked with a client for over ten years, and the Board questioned whether the length of treatment influenced the clinician’s assessment of red flags for safety concerns. Maintaining a fresh clinical perspective and engaging in peer consultation can help avoid blind spots.

 Ensuring proper office policies: Clinicians should establish and communicate clear office policies to prevent ethical dilemmas. In one case, a co-parent complained about their child being seen without their consent. The clinician explained that the child was brought into session because office policy did not allow children to wait alone in the lobby. However, the Board found that having children present for a parent’s individual therapy session was not an appropriate policy, leading to disciplinary discussion. Ensuring policies align with ethical guidelines and informed consent best practices is crucial.

 Cultural Competency & Client-Centered Care: When working with diverse populations, clinicians must navigate ethical and clinical complexities carefully. One case involved a transgender client whose letter supporting medical transition was removed due to concerns about mental health stability. The Board found that the clinician followed proper procedures to evaluate the client’s stability and worked within a team-based approach. This case highlights the need for thorough assessment, adherence to professional guidelines, and advocacy for client needs while ensuring ethical decision-making.

Supervision or legal consultation: Seek guidance when handling complex situations, such as high-conflict divorce cases or sensitive disclosures from clients. For example, one complaint was filed against a Marriage and Family Therapy Candidate (MFTC), alleging that the clinician expressed bias toward one parent in front of a child. However, the Board’s review found documentation showing that the candidate had received proper supervision to navigate the complexities of the case. This underscores the importance of ongoing consultation and thorough documentation to demonstrate ethical and clinically sound decision-making, particularly for pre-licensed therapists managing difficult family dynamics.

These updates highlight the importance of strong ethical and professional standards in clinical practice. The summaries and notes provided from the DORA Quarterly Meetings are for informational purposes only and represent our observations and interpretations of the discussions. These notes do not constitute official meeting minutes, legal advice, or regulatory guidance. While we strive for accuracy, we encourage individuals to refer directly to DORA for official statements, rulings, and documentation.

To join the next DORA meeting, go HERE and look on the bottom right where it shows dates for board meetings on

Friday, April 18th 9am - 5pm;

Friday, July 25th 9am - 5pm;

Friday, October 24th 9am - 5pm.