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TBCE strategic plan pushes for stronger enforcement tools, including felony for unlicensed practice and business-registration changes
Summary
In its strategic-plan discussion, TBCE staff urged legislative and rule priorities: seek felony classification for practicing without a license to improve enforcement cooperation, expand cease-and-desist authority and faster response, clarify practice definitions, and consider registration or disclosure requirements for clinic owners to hold non‑chiropractor owners accountable.
At the May 28 meeting, Executive Director Dr. Bush presented TBCE’s updated strategic plan and identified enforcement and statutory priorities the board will advance in the next legislative cycle.
Dr. Bush said current law makes practicing without a chiropractic license a misdemeanor and often limits enforcement because local law enforcement is reluctant to pursue misdemeanors. He urged pursuing a felony classification for unlicensed practice so enforcement efforts would have more traction and public protection would be improved.
"If somebody is practicing without a license, likely they are doing fraudulent activities and are going to hurt somebody," Dr. Bush said, arguing that a stronger criminal classification would increase cooperation from law enforcement and reduce public exposure to unlicensed practice.
The strategic plan also proposes: (1) streamlined cease-and-desist authorities for faster responses to unauthorized practice; (2) clearer statutory or rule definitions of chiropractic practice to reduce frivolous complaints; (3) potential requirements that business entities register ownership interests and officers so non‑chiropractor owners can be held accountable; and (4) performance measures and customer-satisfaction data to support legislative outreach.
Board members directed staff to file the strategic plan by the June 1 deadline and to use the plan as a vehicle for legislative outreach. The board did not adopt statutory changes at the meeting; staff will use the strategic plan to inform future rulemaking and legislative proposals.
Why it matters: Reclassifying unlicensed practice as a felony or increasing enforcement tools would be a significant legal and policy change with implications for prosecutorial discretion, agency enforcement, and how clinics are structured and advertised.
Next steps: Staff will submit the strategic plan, continue stakeholder outreach (including with TCA), and prioritize drafting legislative language or rule proposals if the board approves.
