Chiropractic License Defense
Representation Before the State Board of Chiropractic
The State Board of Chiropractic licenses chiropractors and certifies the use of adjunctive procedures in the Commonwealth. The Board enforces the Chiropractic Practice Act and its regulations, which address patient records, billing, advertising, the supervision of staff and professional conduct.
Board matters commonly arise from patient complaints, insurer and third-party payor referrals, advertising and solicitation concerns, and allegations of boundary violations. Because the Act specifically addresses false claims to insurers and the maintenance of patient records, billing and documentation are frequent subjects of investigation.
Mimm Law, LLC represents chiropractors at every stage of a Board matter, from the initial inquiry through final order, including impaired-professional matters under section 509 of the Act.
Governing Law
- Board
- State Board of Chiropractic
- Statute
- Chiropractic Practice Act, 63 P.S. § 625.101 et seq.
- Regulations
- 49 Pa. Code Chapter 5
- Licensees
- Chiropractors
- Renewal
- Biennial; licenses expire September 1 of even-numbered years; 24 hours of Board-approved continuing education (no credit for office management or practice building)
Who the Board Regulates
- Chiropractor license
- Certificate to use adjunctive procedures
- License by reciprocity
- Limited license for graduate program faculty (no more than one year, not renewable, and not for treating patients)
- Volunteer license
Grounds for Discipline
Section 506 of the Chiropractic Practice Act (63 P.S. § 625.506) authorizes the Board to discipline a licensee for, among other things:
- Misleading, deceptive or fraudulent representations, or fraud or deceit in obtaining a license
- Gross incompetence, negligence or misconduct in practice
- Conviction of a felony, or of a misdemeanor in the practice of chiropractic, including probation without verdict and similar dispositions
- Discipline by another jurisdiction
- Inability to practice safely because of illness, alcohol, drugs or a mental or physical condition
- Immoral or unprofessional conduct, including sexual activity with a patient and the abandonment of patients
- Solicitation of patients through coercion, intimidation or harassment
- Intentionally submitting to an insurer or other third-party payor a claim for a service or treatment that was not actually provided
- Failure to keep chronological records of patient care
- Unconditionally guaranteeing a cure, claiming chiropractic will cure cancer or an infectious or communicable disease, or holding oneself out as a specialist without a postgraduate certification in that specialty
- Aiding unlicensed practice, and violation of the Board's regulations or orders
Sanctions the Board May Impose
The Board may deny, reprimand, revoke, suspend, limit or restrict a license, require care, counseling or treatment, impose probation, or restore a license subject to conditions. Where a licensee presents an immediate and clear danger to the public, the Board may suspend the license temporarily pending a hearing, and a license is automatically suspended upon a felony drug conviction. Automatic suspension also follows a legal commitment to an institution for mental incompetency, and an automatic suspension for a drug-felony conviction is not stayed pending an appeal of the conviction. A revoked license may not be reinstated except by court order, but the person may reapply after five years; after a suspension or revocation for a felony drug conviction, reinstatement may be sought only after ten years.
In addition to the sanctions in the Board's own statute, Chapter 31 of Title 63 of the Pennsylvania Consolidated Statutes authorizes each licensing board to impose a civil penalty of up to $10,000 per violation and to assess the costs of investigation against a licensee found to have violated the law.
Obligations That Often Lead to Board Matters
Patient Records and Billing
The Act requires chronological records of patient care, and claims submitted to insurers must accurately reflect the services rendered. Records requested by an investigator should be produced complete and unaltered.
Malpractice Insurance
Licensees must maintain professional liability insurance (or approved self-insurance) of at least $100,000 per occurrence and $300,000 annual aggregate and must notify the Board within 30 days of cancellation, non-renewal or termination. The license is automatically suspended 60 days after coverage is cancelled, not renewed or terminated, unless the Board postpones the suspension while it considers a waiver, and it stays suspended until proof of new coverage is filed.
Supervision of Staff
Unlicensed support staff require direct, on-premises supervision, and auxiliary staff who perform X-ray procedures must pass the approved examination. The licensee may be disciplined for improper delegation to, or inadequate supervision of, staff.
Matters We Handle
- Billing, coding and insurance fraud allegations
- Advertising and solicitation issues
- Patient complaints concerning treatment or conduct
- Recordkeeping deficiencies
- Continuing education audits
- Criminal charges and convictions affecting licensure
How We Can Help
Board Investigations
Upon receipt of a letter of inquiry, a subpoena or contact from an investigator, the firm evaluates the allegations, reviews the licensee's records, prepares a written response and attends any investigative interview. In some matters, an early, well-documented response may resolve the matter before formal charges are filed.
Formal Charges and Hearings
When the Commonwealth files an Order to Show Cause, the time to respond is short, and a respondent who misses the deadline may be held in default and the facts alleged deemed admitted. The firm prepares and files the answer, negotiates a consent agreement where one serves the client's interests, and tries the matter before the hearing examiner or the Board where it does not.
Applications and Reinstatement
For applicants whose history may raise questions, and for licensees seeking reinstatement after suspension, revocation or lapse, the firm assembles the application and supporting record and presents the matter to the Board.
Questions Licensees Ask
An insurer has accused me of improper billing. Does the Board become involved?
It may. Submitting false claims to insurers is a ground for discipline, and insurer special investigation units sometimes refer matters to the Department of State. A response to an insurer audit should be prepared with the licensing consequences in mind.
Is an impaired professional program available to chiropractors?
Yes. Section 509 of the Chiropractic Practice Act provides an impaired professional program: the Board may defer and ultimately dismiss corrective action for a licensee who progresses satisfactorily in an approved treatment program. This option is not available after a drug-related felony conviction, and the terms should be reviewed with counsel before enrollment.
What if my malpractice insurance lapses?
The license is automatically suspended 60 days after the coverage ends unless replacement coverage is in place or the Board postpones the suspension pending a waiver request. A licensee should notify the Board of any cancellation within 30 days, secure replacement coverage immediately and avoid practicing during any period of suspension.
Should I speak with an investigator before I have counsel?
A licensee who receives a letter of inquiry, a subpoena or a telephone call from an investigator with the Bureau of Enforcement and Investigation should be courteous and should note the investigator's name and contact information, but should not give a substantive statement before obtaining advice. Anything said to an investigator may be included in the report reviewed by the prosecuting attorney and, later, by the Board. Counsel can determine what is being alleged, gather the relevant records and prepare a response that is accurate, complete and appropriately limited.
Must I report a criminal conviction, plea or ARD, or discipline in another state?
Yes. Pennsylvania law requires every licensee to notify the licensing board in writing within 30 days of discipline imposed by a licensing authority in another jurisdiction and of a finding of guilt, guilty plea, plea of nolo contendere, probation without verdict, disposition in lieu of trial or Accelerated Rehabilitative Disposition on a felony or misdemeanor charge. Some boards' regulations impose additional or earlier reporting duties, including, for nurses and massage therapists, a duty to report the filing of criminal charges within 30 days. A failure to report is itself a ground for discipline, and it is frequently charged alongside the underlying conduct.
Meet Your Attorney
Steven A. Mimm, Esq.
Founder, Mimm Law, LLC. Admitted in Pennsylvania (2008) and New Jersey (2022).
From 2014 to 2022, Attorney Steven A. Mimm served as a prosecuting attorney bringing disciplinary actions on behalf of the Bureau of Professional and Occupational Affairs before Pennsylvania's licensing boards. That experience informs how the firm evaluates evidence, negotiates with the Commonwealth and prepares cases for hearing. Where a licensee also faces criminal charges, the firm handles the licensing matter and coordinates with the licensee's criminal defense counsel.
Related: All Licensing Boards · Licensing and FAQs
Last reviewed September 2026. The information on this page is general in nature and is not legal advice. Contacting the firm does not create an attorney-client relationship.