What Counts as “Prominent”?
A Texas therapist got reprimanded for letter-mill mechanics in July. A complaint filed in December alleged her website was missing the consumer-disclosure pathways state law now requires. The site was
A note on what follows: this piece is commentary on publicly filed regulatory complaints, on the publicly available record, and on the live website at issue. The 2024 BHEC Agreed Order is final and adjudicated. Everything about the December 2025 filings, and the May 2026 supplement, is allegation — not finding. The agencies will decide.
The 2024 case
In July 2025, the Texas Behavioral Health Executive Council issued an Agreed Order against Miki Tesh, LCSW (License #53341), the therapist featured on emotionalsupportanimalsoftexas.com. The Council found that on or about September 15, 2023, Tesh had issued an Emotional Support Animal letter diagnosing a client with a “psychiatric disability” after — and I want you to sit with this — only reviewing a questionnaire and conducting a brief phone call about administrative issues.
That was the clinical encounter. A form and a phone call.
The Council’s findings were polite but unmistakable: “Respondent’s assessment process was inadequate and did not meet accepted professional standards to diagnose or determine disability.” Plain regulator-speak for: this is not how you do an evaluation.
Tesh’s license was reprimanded. The Order required a $2,500 administrative penalty (split as $2,000 in administrative costs and $500 as the penalty itself). The Order also recorded that Tesh “has implemented numerous corrective actions to ensure that a similar violation does not occur.” Brian Clark signed for the staff on July 7, 2025. Darrel Spinks, the Executive Director, ratified the Order in July 2025.
End of story? Not even close.
The disclosure law
According to two December 2025 complaints, while the Tesh Agreed Order was being finalized, the Texas Legislature passed House Bill 4224, codified at Texas Health and Safety Code §181.105. The complaints assert that the law took effect September 1, 2025, and requires “covered entities” — which the complaints argue Tesh’s operation qualifies as under §181.001, because it evaluates and stores Protected Health Information for commercial gain — to prominently post on their website detailed instructions telling consumers how to:
1. Request their health care records.
2. Contact the disciplinary or licensing authority (in Tesh’s case, BHEC).
3. File a consumer complaint with the Attorney General’s Consumer Protection Division.
Layered on top is 22 TAC §884.31, the BHEC rule the complaints cite as requiring licensees to provide public notice of the Council’s name, address, and telephone number for directing complaints.
The whole point, as the complaints frame it, is consumer transparency: anyone purchasing a medical accommodation document for commercial purposes should know how to audit the provider, demand the underlying records, and complain when something looks off.
The complaints
On December 19, 2025, two complaints were filed:
The first went to BHEC’s Enforcement Division, alleging — based on a review of the website that day — that the three required pathways were not prominently displayed. The Council acknowledged receipt on December 23 and assigned TBHEC Complaint No. 2026-00297. Charles Gonzales, Enforcement Assistant, signed the acknowledgment letter. Projected resolution: six to twelve months.
The second went to the Texas Attorney General’s Consumer Protection Division, framed as a deceptive trade practice under three categories: False/Misleading Statements or Advertising, Quality of Care Concerns, and Failure to Provide Requested Health Care Documents/Records. That filing is now logged as TCP-021426, with the BHEC narrative attached.
What changed between filing and now
Here’s where the story turns. As of May 9, 2026 — five months after the complaints were filed — the website does contain a disclosure section. It lives on the FAQ page (URL: emotionalsupportanimalsoftexas.com/ufaq/). It has three subsections:
• “The Right to See and Get Copies of Your PHI” — describes a 30-day records-request process and a $25 fee.
• “How to file a Patient Privacy or other Complaint” — lists, as bulleted hyperlinks: “BEHC” (sic — the typo is on the site), the Texas Attorney General’s Consumer Protection Division, and HHS Office for Civil Rights.
• “Notice to Clients” — explains that BHEC investigates professional misconduct by social workers and provides the address (1801 Congress Ave., Ste. 7.300, Austin, Texas 78701), main number (512) 305-7700, and the toll-free 1-800-821-3205.
I checked the underlying HTML. The links are real and they go to the right places: the BEHC link points to bhec.texas.gov/how-to-file-a-complaint/, and the Consumer Protection link points to the AG’s actual file-a-complaint page. The “BEHC” typo doesn’t break anything; a user who clicks lands on BHEC’s page.
So: today, the consumer-disclosure pathways the complaint said were missing have appeared. That’s not nothing. That’s regulatory pressure doing the work it’s supposed to do.
The interesting question is whether what’s now there satisfies §181.105’s “prominently posted” standard.
What “prominently posted” might mean
Three things worth noticing about the live page.
First, what the navigation tells consumers exists. The site’s main menu has eighteen items. They include “Texas ESA Letter,” “GET STARTED NOW!,” “What I charge,” “About me,” “Reviews,” “Service Dog Letter,” “ESA for Campus Housing,” “What if my apartment rejects my letter?,” “Affordable spay, neuter, vaccines,” “Locations,” “Infographics,” and “Texas ESA PSA Blog.” There is no menu item called “Notice of Privacy Practices,” “Patient Rights,” “File a Complaint,” or anything that would flag the existence of a disclosure section. The disclosures are reachable only by clicking a menu item called “All FAQs,” which a reasonable consumer would read as a help page about emotional support animals.
Second, the page where the disclosures live is structurally an FAQ archive. The HTML page title is “Archives: FAQs.” The H1 is “Archives: FAQs.” The disclosure block is the first item in a list that also includes “What if my ESA letter is rejected?” and “What else are emotional support animals or service dog in Texas called?” Same heading style, same formatting, same visual weight. The disclosure is a peer of “what else are ESAs called,” not a dedicated notice block.
Third, the framing. The complaint pathway header reads: “How to file a Patient Privacy or other Complaint.” The introductory sentence reads: “If you believe your PHI has been or may have been used or disclosed in violation of HIPAA or the Texas Medical Records Privacy Act you may file a complaint with...” That framing scopes the disclosure to privacy complaints — i.e., grievances about how PHI was handled. A consumer with the exact kind of grievance that produced the 2024 BHEC case — namely, an inadequate clinical assessment — would not read this paragraph as describing a pathway available to them. They’d read it as the privacy-complaint section, scroll past, and never reach the “Notice to Clients” paragraph below it that describes BHEC’s actual professional-misconduct jurisdiction.
None of that is a finding. It’s a description of the live page. Whether it adds up to “prominently posted” is precisely what BHEC and the AG now have in front of them.
The supplement
On May 9, 2026, a supplement to the original BHEC complaint was filed with the Council’s Enforcement Division, on the open file in TBHEC Complaint No. 2026-00297. The supplement does three things and only three things.
It updates the factual record by attaching the May 9 capture of the live site and the underlying HTML source, and noting that the website was modified at some point between December 19, 2025 and the filing date.
It identifies the four features of the current configuration that bear on the prominence question: that the disclosures are reachable from the main navigation only via a menu item titled “All FAQs”; that the page hosting the disclosures is, structurally, a WordPress category-archive page titled “Archives: FAQs”; that the complaint-pathway subsection’s introductory sentence scopes the pathway to PHI/HIPAA grievances rather than to the broader category of consumer or professional-misconduct grievances; and that the visible label on the BHEC hyperlink reads “BEHC” rather than “BHEC,” even though the underlying link target is correct.
And it explicitly disclaims any specific outcome, asking only that the Council evaluate whether the current configuration satisfies the prominence requirements of §181.105 and 22 TAC §884.31.
That’s it. No new allegations, no editorial, no demand for a particular sanction. The supplement is two pages plus exhibits.
The reason for filing is preemptive. Without it, an investigator visiting the site for the first time during the six-to-twelve-month review window sees disclosures present and reasonably infers the original complaint has been overtaken by events. The supplement removes that inference. It locks in the December 19 baseline, documents the post-filing change as a change, and identifies the structural deficiencies an investigator might otherwise miss on a casual site visit.
Why this matters
Stack the timeline:
• On or about September 15, 2023 — Tesh issues the ESA letter that launched the original BHEC complaint.
• July 2025 — BHEC ratifies the Agreed Order. Reprimand. $2,500 penalty. Finding of corrective action.
• September 1, 2025 — HB 4224’s disclosure mandate takes effect, according to the complaints.
• December 19, 2025 — Website reviewed. Disclosures, the complaints allege, absent. BHEC and AG complaints filed.
• May 9, 2026 — Supplement filed with BHEC, identifying the structural prominence concerns about the updated site.
The 2024 BHEC complaint was about clinical assessment. The December 2025 complaints are about disclosure. Today’s site shows that the December complaints produced movement: the disclosures the complainant said were missing now exist, with working links. That tends to confirm the complaint’s reading of §181.105 was at least colorable — if it weren’t, you’d expect the site to be unchanged.
But the kind of movement matters. What’s now on the site is the minimum-viable compliance posture: a disclosure block on the FAQ page, with no nav-menu signal, framed as a HIPAA-privacy section, and with the regulator’s name visibly typo’d. A consumer who paid $78 and was unhappy with their evaluation would not, plausibly, find their way through this layout to BHEC’s actual professional-misconduct intake.
Whether that’s “prominently posted” within the meaning of §181.105 is the question. If the answer is yes — if a buried-under-FAQs, HIPAA-framed disclosure block satisfies the statute — then HB 4224 is a much weaker consumer-protection tool than the legislature reportedly designed. If the answer is no, then the December complaints and the May supplement will have done two pieces of work: forcing the disclosures onto the site at all, and clarifying what “prominent” actually requires.
That’s what the supplement was filed to put in front of BHEC.
What happens next
BHEC has Complaint No. 2026-00297 open, now with the supplement on file. The AG’s office has TCP-021426 logged with the BHEC narrative attached. The agencies will take their time — six to twelve months, by BHEC’s own published schedule.
In the meantime, the website is live in its current form. The orange “Schedule Appointment” button still recurs on the marketing pages. The $78 fee still applies. The disclosures exist; the question is whether existing on the FAQ page is the same as being prominently posted.
That is the gap §181.105 was, per the complaints, written to close.
We’ll see if it closes here.
Timothy “Chaz” Stevens runs Revolt Training and investigates ESA letter-mill operations across multiple states. The complaint documents referenced here, including the original BHEC Agreed Order against Miki Tesh (Complaint No. 2024-00218), the December 2025 BHEC complaint (No. 2026-00297), the Texas AG complaint (TCP-021426), and the May 9, 2026 supplement to the BHEC complaint, are publicly available regulatory filings and are available on request. The May 9, 2026 review of emotionalsupportanimalsoftexas.com was conducted against the live site and the page’s HTML source.
One More Thing
I’ve been doing this work for thirty years. Pro se lawsuits. Records requests. Bible challenges in 63 school districts. An FDUTPA injunction against an ESA letter mill, obtained without a lawyer. Statutes rewritten because I filed the wrong kind of paperwork the right way.
None of it has ever had an institution behind it.
No legal defense fund. No nonprofit board. No foundation grant. I fund the work myself. Filing fees, service, transcripts, records costs—it all lands on me. When a records custodian quotes $1,326.08 to produce documents the statute requires them to produce, that’s a bill I either pay or the work stops.
I’ve filed against Donald Trump, the Broward County School Board, State Representative Chip LaMarca, and ESA letter mills as indigent. Court-recognized. Sworn financials. Judges reviewed and approved every time.
This is the work. It produces results.
HB 1467 was rewritten, with the administration of Ron DeSantis naming me in the revision. The ESA injunction is a replicable enforcement model. The Wisconsin State Capitol approved a permit in 48 hours for an installation that normally takes ten business days to process.
The work works.
The math doesn’t.
I’m looking for paid work in three areas—defined by outcomes, not categories.
Accountability & Records
I identify exposure points in agencies and organizations using public records, then force resolution—through compliance pressure, media, or litigation.
Media & Narrative Engineering
I design stories that land. Not pitches that get ignored—events and documentation that reporters have to cover.
Technology & Infrastructure (Ecomm, GEO/SEO, Systems)
I’ve spent thirty years building systems that move money and control visibility.
Helped launch Disney.com and Blockbuster.com
Sold 60,000 vehicles through eBay—full pipeline, not theory
Worked inside NASA, IBM, and Microsoft
What I do now:
Build e-commerce systems that convert, not just attract traffic
Implement GEO/SEO so AI and search engines represent you accurately—and defensibly
Diagnose and fix structural issues in digital infrastructure that suppress performance
If your organization has traffic but no conversion, visibility but no control, or systems that “work” but don’t scale—I fix that.
If you run a nonprofit, newsroom, law firm, municipality, university, or company that needs any of this, contact me.
chazstevens@gmail.com
954-901-0971
If you don’t, forward this. One introduction changes the month.
If neither applies, the Consent Can funds the work. Women In Distress gets a cut.
I’ve spent thirty years making it expensive for corrupt people to stay corrupt.
I intend to keep doing that—and get paid for it.