California CE providers routinely violate ad regulations

A review of 15 advertisements for continuing education events for California MFTs and LCSWs finds that all of them violate state regulations by leaving out required information. If no one is complaining, do we need the regulations?                                                     

Forget-me-not2-croppedContinuing education providers in California are expected to offer some basic information about themselves and their events when advertising, just as licensed marriage and family therapists are expected to have our licensure information attached to any advertising we do. Ideally, these disclosure requirements prevent less-than-reputable folks from putting on less-than-worthwhile CE events to swindle therapists out of money.

But no one is following the requirements.

And that’s a literal “no one,” at least in our sample. Not one advertisement followed the letter of the law.


We (my research assistant and I) reviewed ads from every issue in volume 21 (2009) of The Therapist magazine, published by the California Association of Marriage and Family Therapists every two months. We want to emphasize that CAMFT is not in any way responsible for policing outside ads; it is the CE providers who are solely responsible for their own advertising content. We found a total of 15 unique ads, many of which appeared in multiple issues; we did not count duplicates in our calculations.

Section 1887.9 of the California Code of Regulations (it can be viewed in the BBS laws & regulations booklet, page 142 by the on-page numbering, page 149 of the PDF) requires all CE providers to:

ensure that information publicizing a continuing education course is accurate and includes the following:

(a) the provider’s name;

(b) the provider number, if a board-approved provider;

(c) the statement “Course meets the qualifications for _______ hours of continuing education credit for MFTs and/or LCSWs as required by the California Board of Behavioral Sciences”;

(d) the provider’s policy on refunds in cases of non-attendance by the registrant; and

(e) a clear, concise description of the course content and objectives.

Providers seem to be simply ignoring this. We found a total of 15 unique ads for in-person CE events. We ignored ads for online or mail-in courses; they usually were advertising the provider, and not a specific course, and thus they are probably not subject to the above requirements.

We found that among the 15 ads we reviewed, providers routinely ignored all of the required information except the provider’s name:

Item Ads
% of ads
1. Provider name 14 1 93%
2. Provider number 7 8 47%
3. “Meets qualifications”
0 15 0%
4. Refund policy 2 13 13%
5. Course description 8 7 53%

Another way to look at this is to see what proportion of ads had 2, 3, 4, or all 5 of the required pieces of information:

Items present Ads % of all ads
One or more 15 100%
Two or more 11 73%
Three or more 3 20%
Four or more 2 13%
All five 0 0%

The requirements exist to ensure that when licensees hand over their money to CE providers, the licensee knows what they are signing up for and those hours will legitimately count toward the licensee’s continuing education requirement. But the BBS does not enforce those requirements unless they receive a complaint, and such complaints are rare: in a 7-month span reported here, the BBS received just three complaints against continuing education providers. (And those were not likely to have been about advertising, judging by prior complaint data.) For comparison, there are more than 2,000 approved CE providers in the state.


The relative rarity with which the requirements are followed, combined with the relative lack of complaints against continuing education providers, raises an important question: Are these regulations really helping anybody?

Certainly the BBS has better things to do with its enforcement unit than go after such minor omissions. Maybe it would be better to take the requirements off the books entirely.

Or, maybe the current landscape is just fine. After all, it allows licensees who feel they have been duped by unscrupulous CE providers to complain, and gives the BBS leverage to act against the provider who failed to advertise appropriately. It’s the CE-advertising equivalent of jaywalking: we all want the cops to focus their work on more important things, and it’s really only a problem when somebody gets hurt.


If you’re wondering, the flowers in the picture are forget-me-nots. Seemed appropriate.