“Don’t Pick Up the Paddle”

How the NBCE & FCLB Engineered a Merger Vote, and Why It Will Not Stand

On April 30, 2026, in Atlanta, Georgia, the Federation of Chiropractic Licensing Boards held what it pretended to be a democratic vote to merge with the National Board of Chiropractic Examiners. What actually happened was something else entirely.

Over the course of a single afternoon, state licensing board delegates were presented with a rigged budget, blocked from offering opposition amendments, subjected to a legally questionable vote structure, and pressured by the combined weight of FCLB leadership, much of which simultaneously serves on the NBCE board, to ratify a governance overhaul and merger. The merger gives the NBCE complete control over the entre profession.

Within minutes of the vote, the meeting was declared permanently adjourned, all remaining business struck from the agenda, and the delegates sent home.

It was not a deliberative assembly. It was a closing ceremony for a decision that had already been made.

“Don’t pick up the paddle. Don’t put your thumb on the scale.” — Dr. Daschner, advising Nevada delegates on a pre-meeting board call

The Coaching Call: Nevada Was Told to Stand Down

Perhaps the most revealing moment of the entire Atlanta episode did not happen in Atlanta.

In the last days before the annual meeting, Nevada board delegates who were uncomfortable with the merger and expressed serious concerns about the FCLB’s finances, prepared to abstain from the vote. But suddenly someone joined the board meeting at exactly the right time. Keep in mind that nevada special meeting was a day long but they somehow knew exactly when to jump on. On that call was Dr. Daschner, who advised those delegates against abstaining. His reasoning: an abstention would effectively count against the merger, and would therefore be putting their “thumb on the scale.”

His instruction was direct: don’t pick up the paddle.

In other words, rather than vote their conscience, or follow the direction of their state, delegates were coached to simply not participate. To vanish from the vote entirely. The effect, if followed, would be to shrink the denominator and make the required two-thirds threshold easier to reach so the merger could go through despite their objection.

This is not a neutral act of guidance. It is documented, on public record, pre-meeting coordination designed to suppress dissenting participation and manipulate the arithmetic the governance vote of a private corporation. And it targeted the Nevada delegation specifically, the same state represented by Dr. Jason Jaeger, NBCE Vice President and Nevada Board Treasurer, who simultaneously sat on the FCLB Bylaws Committee that drafted the very governance package being voted on.

No, you can’t make this up.

A Vote Structure That Demands Explanation

The 99th Delegate Assembly opened with a roll call recording properly registered delegates, a mix of FCLB delegates, NBCE delegates, and individuals serving in both capacities simultaneously. When the chair later announced the voting thresholds, those numbers raised immediate questions about who among those present actually held a binding vote on the merger, and on what basis.

As we continue to investigate the composition of the voting body, how dual-role delegates were counted, and whether the threshold calculations were properly derived and disclosed to delegates in advance, what is not in dispute is the outcome: FCLB leadership got the votes it needed by the slimmest possible margin. Even with cheating, the pre-meeting coaching of Nevada and other state delegates, the blocked amendment process, the financial pressure brought to bear in the budget presentation, or some combination of all three, those votes were delivered and will be a matter the profession will be scrutinizing for some time as the truth of what they did seeps out.

The NBCE Held the Check

Before a word of debate was spoken on the merger, the FCLB treasurer delivered a financial presentation that functioned less like a report and more like a lever.

The NBCE has funded the FCLB since at least 2008 under a formal contract, a relationship confirmed in NBCE’s own audited financial statements and acknowledged on the record in Atlanta, where the treasurer stated that NBCE funding has comprised approximately 63% of FCLB’s annual revenue. That contract, delegates were told, is expiring.

The 2026 budget presented assumed the merger would pass. NBCE contributions were budgeted at zero. The projected result: a deficit of just under $1 million.

One delegate asked the obvious question: why are we budgeting as though NBCE money is gone if a contractual agreement is still in place?

The treasurer’s answer was stunning in its candor. If the merger didn’t go through, she said, “we will be getting that check from NBCE probably Monday.”

The check existed. It would have been delivered the next business day, but only if the vote failed. Delegates were shown one budget: a picture of near-insolvency. They were not shown an alternative. When a delegate asked directly whether two budgets were available for comparison, the answer was no.

This is not a budgeting irregularity. It is the use of contractually obligated funds as a lever to coerce a governance vote. It happened on the record, by the organization’s own treasurer, before the vote was called.

“In the past, NBCE funding comprised approximately 63% of FCLB’s annual revenue, but none is budgeted for 2026... we will be getting that check from NBCE probably Monday.” — FCLB Treasurer, 99th Annual Meeting, April 30, 2026

Arizona Wanted a Secret Ballot

Dr. Wayne Bennett of Arizona, a sitting member of the very Bylaws Committee that drafted the merger governance package being voted on, and himself a disgraced Arizona Board member, rose during debate ostensibly to speak in favor of adoption. He then moved that the vote be conducted by confidential written ballot, with no identifying information attached.

Bennett offered his rationale for supporting the merger: extensive legal resources had been brought to bear in support of this combination, and delegates should not be swayed by what he called “AI-generated treatises being spread around.”

He did not address the substance of the legal challenges circulating among delegates. He did not dispute the arguments about whether delegates possessed the statutory authority to vote on a private corporate dissolution. He did not engage the formal opinion issued by the New Mexico Attorney General’s office concluding that the merger vote fell outside the scope of delegate authority. He dismissed those concerns as machine-generated noise, and then asked that the vote be taken in secret so no one would know how any individual delegate voted.

Remember, Bennett thinks he’s a leader of the profession.

Dr. Marc Bronson of Texas objected on transparency grounds. Delegates, he noted, were present to represent their state licensing boards. A secret ballot would make it impossible to verify whether they did so.

Sadly, even without a secret ballot, those states who chose not to “pick up a paddle” did the FCLB and NBCE’s bidding and swayed a vote they otherwise would have lost.

CLICK Here for more about Wayne Bennet and the mess he made in Arizona

CLICK HERE for more on Arizona

“I believe that the risk... is far greater a bet than to be worried about these AI-generated treatises being spread around.” — Dr. Wayne Bennett, Arizona, Bylaws Committee member, 99th FCLB Annual Meeting

States Tried to Offer Amendments. They Were Shut Out.

At least one state delegation arrived in Atlanta having submitted proposed bylaw amendments under Article 16 of the FCLB bylaws, the proper procedural vehicle for delegates seeking to modify what they were being asked to vote on.

Those amendments were ruled untimely by Kevin Fogarty DC the Bylaws Committee chair and recently dethroned Chair of LIFE University’s Board of Trustees. LIFE is the first chiropractic College to require all students to pass all parts of NBCE exams PRIOR to graduation or no diploma is issued. Fogarty just brought Sal Larusso, an old time NBCE and FCLB leader onto LIFE’s board as Fogarty battles governance problems plaguing the LIFE Board that threaten accreditation.

The delegate pushed back in detail on the record: their state had submitted language before the deadline. were asked to reformat it and resubmit which they did but it was then ruled late, even though the original filing predated the deadline. Fogarty’s ruling was that the initial submission “could not, in any reasonable interpretation” be considered a proper proposed amendment, meaning the corrected version became the first filing, and missed the deadline.

No written instructions on proper formatting had ever been provided. The only guidance given was an oral instruction to resubmit. When the correction arrived, it was treated as a new filing rather than a timely amendment.

The result: no opposition amendments reached the floor. Delegates faced a binary choice, approve the full governance revision as written, or vote no and face the financial collapse scenario the treasurer had just walked them through.

The People Running This Meeting Had a Stake in the Outcome

In the formal introductions at the start of the session, FCLB’s own presiding officers were identified:

• Dr. Lisa Kouzes, FCLB Vice President — simultaneously a member of the NBCE Board of Directors

• Dr. Karen Campion, FCLB Immediate Past President — simultaneously a member of the NBCE Board of Directors

The organization holding the vote and the organization it was voting to merge with shared leadership. Those same leaders presided over a meeting where the merger was presented as the only fiscally viable path forward.

Dr. Jason Jaeger of Nevada, NBCE’s Vice President and Nevada Board Treasurer, the individual documented in Nevada state board communications as having described NBCE’s for-profit subsidiary EBAS as “the for-profit portion of the NBCE”, simultaneously sat on the Bylaws Committee that drafted the governance revisions delegates were voting on.

The people who wrote the rules were the same people who stood to benefit from them passing. And one of those people was from the same state whose delegates were coached before the meeting not to vote.

A Supplemental Notice, Ten Days Before the Vote

Bundled into the final motion was a requirement that delegates ratify “all actions presented in the supplemental notice dated April 20, 2026.” That notice was issued just ten days before the vote, after most delegates would have completed any independent review of the merger documents.

The motion made ratification of this last-minute notice a condition of bylaw adoption itself. Delegates could not approve the new governance structure without simultaneously ratifying a document distributed at the eleventh hour.

Adjourned Sine Die Before Anyone Could Reconsider

The moment the votes were tallied, a motion was made to amend the agenda to strike all remaining business and adjourn the 99th Delegate Assembly permanently, sine die, with no scheduled reconvening.

One delegate objected.

The motion carried anyway.

The 99th Delegate Assembly of the Federation of Chiropractic Licensing Boards was declared closed. No further business. No opportunity for reconsideration. No ability to revisit the procedural challenges that had been raised during debate and dismissed without full resolution. No chance for any delegate to report back to their state board and return with a mandate.

It was over in an afternoon and complete control of the educational, testing, regulatory, post graduate, continuing education and disciplinary pipeline of the chiropractic profession was handed over to the NBCE.

“The Delegate Assembly will not reconvene for the transaction of business, and the 99th Delegate Assembly of the Federation of Chiropractic Licensing Boards will adjourn sine die.” — Chair’s declaration, immediately following the merger vote

What Happens Now

The Chiropractic Freedom Coalition is reviewing the full record of the April 30 meeting and the state board meetings that occurred beforehand. Questions remain about how individual state boards instructed their delegates, and whether those instructions were honored or overridden. Questions remain about the coaching of Nevada and other state delegates before the meeting even convened. Questions remain about whether the vote, conducted in the manner it was, can withstand legal scrutiny.

One delegate reportedly urged colleagues before the vote to simply refuse to participate rather than be maneuvered into an abstention that would be counted against them. It was a recognition, in real time, that what was being asked of them exceeded their authority and their mandate.

The paddles that were raised did not represent the profession. They represented the conclusion of a campaign, financial, procedural, and personal, to deliver a predetermined result.

This will go down as a sad and embarrassing day in chiropractic history.

CLICK HERE for merger related reports

Most chiropractors have never heard of Ethics and Boundaries Assessment Services, LLC.

That is, in all probability, by design.

EBAS, as it is known to the state chiropractic boards that have quietly embedded it into their disciplinary machinery, is not listed on the National Board of Chiropractic Examiners’ website. It did not appear in any NBCE annual report given to state boards until investigators began asking questions. It has never been mentioned in any of the three town halls NBCE and FCLB held to explain the proposed merger to the people being asked to vote on it. And it has been completely absent from every Form 990 filing, audited financial statement, and public communication ever issued by the Federation of Chiropractic Licensing Boards, the organization whose delegates are casting the deciding vote in Atlanta on April 30, 2026.

Yet EBAS is, by NBCE’s own sworn admission to the Internal Revenue Service, the only source of revenue NBCE derives from activities unrelated to its exempt purpose. It is a for-profit LLC. It operates out of NBCE’s own headquarters at 901 54th Avenue, Greeley, Colorado. It uses the same telephone exchange. And it has accumulated $4,912,318 in debt to NBCE, money advanced to keep a perpetually money-losing enterprise afloat for over a decade, a figure that did not appear in any merger communication delivered to delegates.

This is the story of EBAS: what it is, how it operates, who profits, why no one told you about it, and what delegates in Atlanta are actually voting to entrench.

“The For-Profit Portion of the NBCE”

On July 11, 2024, the Chiropractic Physicians Board of Nevada convened its regular meeting. Agenda item: FCLB/NBCE Matters. The person presenting was Jason Jaeger, DC, simultaneously Nevada’s board Secretary-Treasurer, NBCE Vice President and Board Member of the International Chiropractors Association (ICA). Speaking on the public record, Jaeger told the Nevada board that “the revenue from the EBAS program has doubled, which is the for-profit portion of the NBCE, and the target from the revenue is beginning to off-set the costs of chiropractic testing.”

That sentence contains more verified information about EBAS than most chiropractic practitioners will find in any official NBCE publication.

The characterization was not a slip of the tongue. NBCE’s own IRS filings confirm it. For seven consecutive fiscal years, FY2018 through FY2024, NBCE reported EBAS revenue in Column C of Part VIII of its Form 990: the column designated specifically for “Unrelated business revenue.” In every one of those years, NBCE confirmed it had filed a Form 990-T, the supplemental return required when a nonprofit generates taxable business income. NBCE’s own Schedule D stated explicitly in FY2018 and FY2019: “NET INCOME UNRELATED TO NBCE’S MISSION IS SUBJECT TO UNRELATED BUSINESS INCOME (’UBI’) TAX TO BE REPORTED ON FORM 990-T.”

NBCE tells the IRS that its mission is chiropractic examinations. EBAS is, by the organization’s own sworn statements, something else entirely.

The Product: $400 Per Scenario, No Contract Required

EBAS sells essay-based ethics assessments to state licensing boards for mandatory use in disciplinary proceedings. When a board orders a licensee to complete EBAS as a condition of reinstatement, probation, or discipline, the licensee pays all costs. The published fee: $400 per scenario, paid directly by the licensee to EBAS.

The assessment is administered at a Prometric testing center, the same vendor that proctors hundreds of other professional licensing exams, and consists of open-ended essay questions graded on four criteria: Introductory Opinion Statements, Consequences, Solutions, and Public Protection. Each criterion is scored on a 1–4 scale. The maximum score is 16. The passing threshold is 12. Human graders at EBAS, described on the company’s website as “professionals with regulatory experience,” make the final determinations. No qualifying credentials for those graders are publicly disclosed. No state has formal audit rights over the grading process.

EBAS offers assessments in five domains: Fraud, Professional Standards, Unprofessional Conduct, Boundary Violations, and Substance Abuse. Boards are encouraged to order multiple domains simultaneously. EBAS’s own website recommends assigning “one essay in at least three topics for increased reliability of scores” and notes that “boards that assign four or more often see stronger results.” Each domain is a separate $400 charge to the licensee.

If a licensee fails, they must retake. Each retake generates additional revenue.

On its website, EBAS describes itself as serving “professionals in healthcare, law, financial services, and more” and claims to have partnered with “over 150 clients across healthcare and non-healthcare professions.” Profession-specific examinations exist for chiropractors, medical doctors, nurses, dentists, and social workers, along with general healthcare and non-healthcare exams for professions that do not have dedicated versions. EBAS markets its assessments to cosmetologists, engineers, financial consultants, marriage therapists, and corporate executives.

NBCE’s 501(c)(3) exempt purpose is the preparation and administration of chiropractic licensing examinations.

The distance between those two descriptions is the legal problem at the center of this story.

“EBAS has been at the forefront of ethical assessment, partnering with over 150 clients across healthcare and non-healthcare professions.” — EBAS website, ebas.org/about-us, 2025

Twelve Years in Nevada: No Contract, No Oversight, No Records

The Nevada FOIA production, thirty-seven documents obtained through a public records request to the Chiropractic Physicians Board of Nevada, is the most complete documented case study of how EBAS operates in practice.

The picture it reveals is this: from at least 2013 through 2025, Nevada’s chiropractic regulatory board ordered licensees to complete EBAS assessments as a condition of disciplinary action. Over that span, eleven documented cases are confirmed in produced records, with a twelfth, appearing in the April 2026 board packet but not produced in response to the FOIA request. In none of these twelve-plus years did the Nevada board:

• Execute a contract with EBAS

• Take a formal authorization vote to adopt EBAS as a mandatory vendor

• Conduct a competitive procurement

• Require a conflict-of-interest disclosure regarding the board member most closely associated with NBCE

• Produce a single financial record documenting what licensees paid

The cases span the full range of disciplinary scenarios. Some licensees passed on the first attempt. Others did not. In the matter of one licensee, two modules were failed on the first attempt, requiring a retake. In another case, the Fraud module was failed and required a second attempt. In neither case were financial records produced documenting the additional charges.

This is not a minor vendor relationship that escaped notice. Nevada’s use of EBAS spans more than a decade, encompasses at least a dozen disciplinary matters, and involves a company that shares its address, telephone exchange, and organizational parentage with NBCE, the private corporation whose Secretary-Treasurer sits on Nevada’s board, who simultaneously serves as an investigating board member on active disciplinary cases, and who on September 5, 2025 received an email from EBAS’s VP of Operations, Greg Hirschi, asking him for a testimonial for the EBAS website.

Jaeger’s reply to Hirschi: “I’d be happy to.” He paused only to check whether he was “allowed” as a regulatory board member to do so. He forwarded the request to Nevada’s executive director using his NBCE email address, identifying Hirschi as “our director for the EBAS program with the NBCE.”

Nevada answered “None” to every conflict-of-interest disclosure question in the FOIA response.

The Pipeline Problem

The structural conflict at the core of the EBAS arrangement is not subtle, and it does not require a law degree to understand.

Jason Jaeger, DC holds several roles simultaneously:

1. NBCE Vice President — a compensated officer position at the organization that wholly owns EBAS

2. Nevada Secretary-Treasurer — a voting member of the state regulatory board

3. Investigating Board Member — the person on the Nevada board assigned to lead investigation of active disciplinary cases

4. He serves on the FCLB’s Bylaws Committee

5. He is on the Board of Directors of the International Chiropractors Association (ICA)

If an investigation Jaeger leads results in a disciplinary order that includes an EBAS requirement, the licensee pays $400 per section, minimum, to a company that is, in Jaeger’s own words, “the for-profit portion of the NBCE.” The organization that compensates Jaeger as Vice President profits from the disciplinary referral. No conflict-of-interest disclosure was ever filed.

At the April 16, 2026 meeting of the Nevada board, the final board meeting before the Atlanta Merger vote, a member of the public made this observation on the record:

“Jason Jaeger, who’s about to speak, is also the vice president of the NBCE. He is compensated by that company and he simultaneously serves on the Nevada state board as your secretary treasurer. He was also on the bylaws committee for the FCLB resolutions, the committee that drafted the merger bylaws that you are being asked to vote on. This is for your board to decide, but it looks like a conflict of interest from outside viewers.”

Jaeger did not dispute any of these facts.

Nevada’s ethics statutes require public officials to disclose conflicts of interest before participating in decisions in which they have a financial or organizational stake. Whether the full pattern of conduct described above required disclosure and recusal, not merely from individual votes Jaeger chose to absent himself from, but from the entire framework of EBAS referrals generated by investigations he led, is a question the Nevada Attorney General is now positioned to examine.

Seven Years of Contradictions: The IRS vs. The Public

The most documented anomaly in NBCE’s relationship to EBAS is not the Nevada pipeline. It is a seven-year pattern of mutually exclusive sworn representations, one set made to the IRS, one set made to the public.

On NBCE’s Form 990 for every fiscal year from FY2018 through FY2024, EBAS revenue is reported as unrelated business income. The amounts are not trivial:

In those same years, NBCE’s own audited annual reports, the documents sent to state boards, posted on NBCE’s website, and distributed at annual meetings, stated, in Note 1 of every report from FY2020 through FY2025:

“The Organization has no income from business unrelated to its exempt purpose.”

These are not ambiguous statements capable of reconciliation. NBCE cannot simultaneously have declared $1.3 million in unrelated business income to the IRS and have had no income from unrelated business activities. One representation is false. Both were made under penalty of perjury. The discrepancy has persisted, without correction or explanation, for a minimum of seven consecutive fiscal years.

The forensic financial audit conducted by the Chiropractic Freedom Coalition, reviewed against primary source documents including NBCE’s complete Form 990 filings for FY2018 through FY2024 and six consecutive audited annual reports, identifies this as the highest-severity finding in the NBCE analysis: a material misrepresentation maintained simultaneously in IRS filings and public financial disclosures for seven years.

“NBCE has no income from business unrelated to its exempt purpose.” — NBCE Audited Annual Report, Note 1, FY2020–FY2025

“Net income unrelated to NBCE’s mission is subject to Unrelated Business Income (’UBI’) tax to be reported on Form 990-T.” — NBCE Form 990, Schedule D, FY2018–FY2019

Both sworn. Both signed. Mutually exclusive.

The $4.9 Million Debt No One Mentioned

EBAS has never turned a profit.

In every fiscal year of its existence, EBAS has operated at a net loss, with NBCE advancing funds to keep it operational. As of December 31, 2025, the cumulative amount NBCE has advanced to EBAS, essentially the total subsidy required to sustain a perpetually money-losing subsidiary, was $4,912,318.

That figure appears in exactly one location in NBCE’s public disclosures: a footnote in the FY2025 audited annual report, Note 11.

It does not appear in NBCE’s consolidated balance sheet. It was not disclosed in any of the three merger town halls. It does not appear in any FCLB communication to delegates. It has not been addressed in the proposed merger bylaws.

The trajectory makes the silence harder to explain. EBAS revenues are growing, from $105,910 in FY2021 to $353,300 in FY2024. But expenses are growing faster. EBAS’s direct expenses in FY2025 reached approximately $1,360,000 against revenues of $267,600, for a single-year operating loss of roughly $1,092,000. The cumulative debt grew by approximately $1.1 million in FY2025 alone.

This is the year, FY2025, with EBAS posting its largest-ever annual loss, in which NBCE also posted its first-ever operating deficit, a $1,290,661 shortfall before investment returns. It is also the year in which NBCE committed $10,101,925 from reserves to new construction, described in the balance sheet as “Construction in Progress.” No merger communication discloses what happens to the $4.9 million EBAS debt post-merger, or how the combined entity’s finances are expected to sustain a loss-generating subsidiary while absorbing FCLB’s operations.

Delegates voting April 30 have not been given this information.

Beyond Chiropractic: The Exempt Purpose Problem

NBCE’s 501(c)(3) tax exemption rests on a declared purpose: the preparation and administration of chiropractic licensing examinations. It is a narrow purpose, as such exemptions tend to be. NBCE pays no federal income tax on its examination fee revenue, approximately $15–16 million per year, derived largely from chiropractic students paying with federal Title IV student loans, because those activities serve that exempt purpose.

EBAS is a for-profit LLC. Its revenue is already classified by NBCE as unrelated business income, meaning NBCE’s own IRS filings acknowledge that EBAS activities fall outside the chiropractic examination mission. That alone raises UBIT exposure and private benefit concerns. But the IRS exposure deepens substantially when the full scope of EBAS’s operations is understood.

EBAS does not serve only chiropractic boards.

According to EBAS’s own website, the company offers profession-specific examinations for medical doctors, nurses, dentists, and social workers, in addition to chiropractors. It offers general healthcare assessments usable across professions. It offers non-healthcare assessments for legal professionals, financial services workers, engineers, cosmetologists, and corporate executives. The website describes “662+ domains available” across all industries.

The CRDTS connection, Central Regional Dental Testing Service, a nationally recognized dental licensing examination organization with over fifty years of history, documents EBAS’s active penetration of dental board disciplinary programs. CRDTS’s own remediation program materials explicitly list “EBAS Ethics Testing” as a partner. An EBAS representative appeared in the organization’s “Board Insights, Episode 1” marketing newsletter sent to Nevada’s executive director, a newsletter that Nevada’s board received on EBAS’s commercial HubSpot mailing list, alongside dental regulatory contacts.

NBCE’s 501(c)(3) exempt purpose has no connection to dental licensing, nursing regulation, social work, financial services, engineering, or cosmetology. Operating a for-profit subsidiary that markets mandatory disciplinary assessments to regulatory boards across those professions generates no income that can be described as related to NBCE’s exempt chiropractic mission, by definition.

The IRS’s private benefit doctrine prohibits a 501(c)(3) from operating primarily for the benefit of private interests. The question of whether a perpetually loss-making for-profit LLC, wholly owned by a tax-exempt organization, generating revenue from mandatory disciplinary referrals across multiple professions, with no disclosed relationship to the parent’s exempt testing mission, satisfies that standard is one that NBCE’s auditors have, apparently, not raised. It is one that the IRS Exempt Organizations Division may find worth examining.

“Our assessments are designed for professionals in healthcare, law, financial services, and more.” — EBAS website, ebas.org

Tennessee Knew. Did Anyone Listen?

At the Tennessee chiropractic board’s April 16, 2026 meeting, the same day Nevada’s board met to hear public comment on the merger, a board member made an observation that deserves wider attention.

During discussion of the NBCE-FCLB consolidation, one member stated plainly on the public record:

“EBAS is good. We’ve used it in the past. We’ve had problems with it though and we stopped using it for probably three or four years because they didn’t provide us with what we needed.”

This is a direct, on-record acknowledgment from a sitting state board member that EBAS had quality and performance problems serious enough to cause a state board to discontinue it as a vendor. The board member did not specify what those problems were. The record does not indicate whether they were resolved before Tennessee resumed use. No public investigation appears to have been conducted.

What the comment does confirm is that Tennessee’s regulatory experience with EBAS, including the period of non-use, occurred entirely outside any public procurement framework. There is no indication that Tennessee executed a contract, conducted a competitive review upon resuming use, or sought independent validation of any claimed improvements to EBAS’s product.

The grading pool that evaluates these assessments, determining whether a chiropractor, or a dentist, or a nurse retains the ability to practice their profession, operates without publicly disclosed credentials, without independent audit rights, and without any formal appeals process. EBAS’s own FAQ states plainly:

“There is no appeal process. All score reports issued have undergone multiple review and are considered final.”

A licensee who fails, who pays $400 per section, sits in a Prometric testing center, writes essays evaluated by an undisclosed pool of graders at a for-profit company, and receives a failing score, has no recourse. They pay again.

What the FCLB Never Told Its Own Members

The forensic financial analysis of FCLB’s own sworn IRS filings confirms what NBCE’s filings suggested: EBAS does not exist in FCLB’s organizational universe.

Across seven years of FCLB Form 990 filings, FY2017 through FY2024, and ten years of FCLB audited financial statements, EBAS appears nowhere. Not in Part III program descriptions. Not in Schedule R related-organization disclosures. Not in Schedule O narrative explanations. Not in any footnote to any audited statement.

This is significant for a specific reason: FCLB’s member boards, the same state regulatory bodies whose delegates vote on April 30, are the boards that have been using EBAS. They have been ordering their licensees to complete EBAS assessments as conditions of disciplinary action. They have been doing so, in Nevada’s documented case, without contracts, without conflict-of-interest disclosures, and without financial records.

FCLB has never told those boards what EBAS is. FCLB has never disclosed to its member boards that EBAS is a for-profit LLC owned by NBCE. FCLB has never disclosed the $4.9 million cumulative debt. FCLB has never disclosed the seven-year pattern of contradictory IRS and public representations about EBAS’s revenue classification.

Delegates from those boards are being asked to ratify a merger with the entity that owns EBAS, carries its nearly $5 million accumulated deficit, and has made contradictory sworn representations about its revenue for seven consecutive years. They are being asked to do this without having been informed that EBAS exists.

Whether FCLB’s leadership is unaware of EBAS, making genuine informed consent to the merger impossible, or has chosen not to disclose it, which compounds the governance failure, cannot be determined from available public documents. Either answer is deeply troubling for a regulatory body whose member boards bear responsibility for public protection.

What the Merger Actually Consolidates

The merger framing presented to delegates describes an efficiency: two organizations combining to eliminate redundancy, reduce costs, and streamline service to state boards. The framing is not false, exactly. It simply omits the most commercially significant element of what is being combined.

Consider what a post-merger NBCE would control over the career of every licensed chiropractor in every state:

• Pre Chiropractic Testing - Chiropractic Education Readiness Assessment (CERA)

• Initial licensure: NBCE examination scores are required for licensure in every U.S. jurisdiction. LIFE University has already made them required to pass in order to graduate.

• Continuing education approval: FCLB’s PACE program, transferring to NBCE under the merger

• Specialty recognition: FCLB’s RCSP program, transferring to NBCE. Diplomates, certifications etc all will need approval from RCSP

• Disciplinary reporting: FCLB’s CINBAD database, the system that tracks violations across state lines, transferring to NBCE

• Disciplinary remediation: EBAS, already NBCE’s for-profit arm, the commercial vendor called upon when a licensee is ordered to remediate

Every leverage point over a licensed chiropractor’s career would flow through a single private entity. The entry gate (licensing exams), the maintenance requirements (CE approval), the specialty credentials (RCSP), the disciplinary record (CINBAD), and the remediation revenue (EBAS) would all be consolidated under one organization, operating as a 501(c)(6) business league, with no 501(c)(3) charitable accountability structure, in a structure the U.S. Department of Education’s National Advisory Committee on Institutional Quality and Integrity described, in 2006 and again in 2013, as a “virtual cartel.”

EBAS is not incidental to that picture. EBAS is the commercial monetization of the disciplinary pipeline, the for-profit mechanism that generates revenue at precisely the point in a practitioner’s career when they are most vulnerable, most legally exposed, and least able to refuse.

The merger doesn’t just consolidate two administrative organizations. It entrenches the revenue model.

The Legal Questions No One Is Answering

The forensic analysis identifies legal questions that no merger communication, not a single town hall, not the proposed bylaws, not any correspondence from NBCE or FCLB leadership, has addressed.

On NBCE’s 501(c)(6) status and FCLB’s 501(c)(3) status: FCLB is a Wyoming public benefit nonprofit corporation organized under Section 501(c)(3) of the Internal Revenue Code. Its assets are dedicated permanently to charitable purposes. Wyoming’s Nonprofit Corporation Act requires that upon dissolution of a public benefit corporation, assets transfer to a qualifying 501(c)(3) organization or to a governmental entity. NBCE is a 501(c)(6) business league, not a public charity. The merger dissolves FCLB into NBCE. FCLB’s $3,464,272 in charitable net assets would transfer to a non-charitable entity. Wyoming law and IRS regulations may prohibit this. No merger communication has addressed it.

On delegate authority: NBCE confirmed under oath to the IRS, in identical language for seven consecutive fiscal years, that “the State Delegates must approve both the Bylaw Changes and Dissolution of the Corporation upon the recommendation from the Board of Directors.” The merger requires fundamental bylaw changes. NBCE cannot credibly treat the delegate vote as advisory.

On the auto-installation of FCLB officers: The proposed bylaws contain three Provisos — P2, P3, and P4 that would install the sitting FCLB President, Vice President, and Administrative Fellow Director into NBCE board seats automatically, by virtue of their FCLB titles, the moment the new bylaws are ratified. These seats are currently filled by delegate election. A delegate who votes to ratify the bylaws simultaneously surrenders the right to elect those three seats, to the people who stood to gain the most from the merger’s passage.

On FCLB’s private foundation risk: FCLB’s public support percentage was 12.07% in FY2023 and 13.08% in FY2022 — far below the 33-1/3% threshold for public charity status under the standard IRS test. FCLB qualifies only under the more lenient “facts-and-circumstances” test, which requires at minimum a 10% public support level. Continued growth in NBCE’s contractual payments, or any decline in member board dues, could push FCLB below that floor, triggering reclassification as a private foundation with mandatory distribution requirements and excise taxes. The merger permanently eliminates that exposure. This financial motive for the merger has not been disclosed in any communication to delegates.

On the dual characterization of NBCE’s payments to FCLB: NBCE calls the annual payment (approximately $825,000 in FY2024) a grant in its Schedule I filing. FCLB calls NBCE a “related organization” and discloses the same payment as a related-party transaction in its Schedule R. For FY2023, NBCE and FCLB submitted mutually contradictory sworn characterizations of the identical financial relationship to the same federal agency in the same filing year. The IRS received both.

None of these questions have been answered. Some of them may determine whether the April 30 vote, and the transaction it ratifies, is legally valid at all.

What Delegates Are Actually Voting For

When delegates assemble in Atlanta on April 30, 2026, they will be asked to approve amendments to the NBCE bylaws. The materials they have received describe a governance consolidation, a merger of two nonprofit organizations that have long operated in parallel, eliminating duplication and creating administrative efficiency.

What the materials do not describe is EBAS.

They do not describe a for-profit LLC operating out of NBCE’s headquarters, generating revenue classified by NBCE as unrelated business income, sustaining itself on nearly $5 million in NBCE advances, and expanding its client base across healthcare professions that have no relationship to NBCE’s chiropractic testing mission.

They do not describe the twelve-year mandatory vendor relationship with Nevada’s board that unfolded without a contract, without a conflict-of-interest disclosure, and without financial records.

They do not describe the structural pipeline through which the person investigating disciplinary cases on a state board is simultaneously an officer of the organization whose for-profit subsidiary profits from the mandatory remediation orders those investigations produce.

They do not describe the seven consecutive years of contradictory sworn representations, one account told to the IRS, a different account told to the public, about whether NBCE has income from unrelated business activities.

They do not describe what happens to $4.9 million in intercompany debt, or what the post-merger entity’s financial position will look like after absorbing FCLB’s operations in a year when NBCE posted its first-ever operating deficit.

They do not describe what it means for every point of leverage over a chiropractor’s career, licensure, continuing education, specialty recognition, disciplinary reporting, and now disciplinary remediation — to flow through a single private organization, answerable to no state, audited by no regulator, governed by bylaws that can be changed by the very directors whose auto-installation those bylaws provide for.

The New Mexico Attorney General’s office has formally concluded, in a memorandum issued December 30, 2025, that a vote on corporate dissolution is beyond the scope of what state chiropractic board delegates can be authorized to do under state licensing board statutes. Multiple state boards have declined to send delegates, or have instructed their delegates to abstain. The governance problems documented in this report, and in the broader forensic financial audit from which they are drawn, have been placed on the record of state board meetings from Nevada to California to Tennessee.

But the vote is still scheduled.

The documents are public. The IRS filings are public. The Nevada FOIA production is public. The town hall transcripts are public. The proposed bylaws are public.

What has not been public until now, is EBAS.

A Victory Against Organized Suppression

The chiropractic profession has faced existential threats before. The most famous, and most consequential, was the antitrust case brought by Chester Wilk against the American Medical Association.

In Wilk v. AMA, chiropractors proved in federal court that organized medicine had engaged in a systematic conspiracy to eliminate the profession. The AMA’s Committee on Quackery explicitly sought to contain and eliminate chiropractic, using boycotts, professional isolation, and institutional control.

“The AMA conspired to contain and eliminate the chiropractic profession.”

The ruling was not merely symbolic. It established that professional monopolies can violate antitrust law, credentialing systems can be weaponized, and control over education and access to practice is a form of market power.

The Wilk decision affirmed a principle that reshaped the profession, healthcare professions cannot be governed by a closed system designed to suppress competition.

The Irony, A New Monopoly From Within

Fast forward to today, and the profession faces a different, but strikingly similar, threat.

This time, the consolidation of power is not external. It is internal.

At the center of this controversy are the National Board of Chiropractic Examiners, the Federation of Chiropractic Licensing Boards, and the Council on Chiropractic Education.

Together, these entities form a tightly interwoven regulatory structure. NBCE controls testing, CCE ties accreditation to NBCE exams, and FCLB coordinates licensure and board influence.

The proposed merger between NBCE and FCLB represents the logical endpoint of that structure.

According to NBCE’s own reporting, the organizations are actively pursuing a unified governance model to coordinate licensure and regulation across the profession .

“NBCE and FCLB are evaluating the potential to unite under a shared governance structure.”

A System Built on Interlocking Control

The comparison to Wilk becomes unavoidable when examining how this system operates.

The NBCE is not simply an exam provider. It is embedded within the regulatory framework itself.

State boards rely on NBCE exams for licensure. Those same boards send delegates who vote on NBCE governance. The FCLB appoints members directly to the NBCE Board of Directors .

“Two seats are filled by FCLB appointments.”

This creates a closed loop. Regulators help design the exams, the exam entity influences regulators, and accreditation enforces compliance with the system.

This is not theoretical. It is documented structure.

Follow the Money, Follow the Influence

Financial relationships further complicate the independence of this system.

The NBCE provides significant financial support to organizations within the same regulatory ecosystem, including direct funding to FCLB .

“$772,596, Annual Support to the Federation of Chiropractic Licensing Boards.”

This raises fundamental questions about independence and influence. Can an entity that funds regulators remain neutral. Can a licensing requirement tied to a private organization be considered objective. At what point does coordination become control.

FOIA, The Modern-Day Discovery Process

In Wilk, the truth emerged through discovery in federal court.

Today, it is emerging through Freedom of Information Act requests across the country.

Documents obtained from state boards reveal coordinated messaging, minimal deliberation on consequential votes, acknowledged legal uncertainty, and participation by individuals with overlapping roles and potential conflicts.

“What Wilk uncovered through litigation, today is being uncovered through public records.”

This is the modern equivalent of exposing internal strategy documents. It is slower, more fragmented, but no less revealing.

Centralization as the New Mechanism of Control

The AMA used boycotts to isolate chiropractors but today, control is exercised through infrastructure.

Centralized testing, particularly the consolidation of Part IV, combined with accreditation mandates and standardized licensure pathways, creates a system where participation is effectively mandatory.

NBCE’s own materials describe the move toward centralized testing facilities and expanded control over clinical competency evaluation .

What appears on the surface as modernization also functions as consolidation.

“The profession that once fought a cartel is now confronting one of its own making.”

The Legal Parallels Are Unavoidable

The Wilk decision established that control over education, licensing, and access to practice can constitute restraint of trade. It also made clear that coordination among organizations can rise to the level of antitrust violation.

The current structure raises parallel concerns.

Is the merger a consolidation of market power. Are state boards operating independently or as extensions of private entities. Does the system limit competition in education, testing, and pathways to licensure.

These are not rhetorical questions. They are legal ones.

A Profession at a Crossroads

The chiropractic profession once stood unified against external suppression.

Today, it is divided over internal consolidation.

Some view these changes as necessary modernization. Others see them as the culmination of a decades-long shift toward centralized control, where diversity of thought and approach is replaced by institutional uniformity.

“Wilk was about freedom from external control. This battle is about freedom from internal consolidation.”

Conclusion, History Is Not Repeating, It Is Rhyming

The Wilk victory was more than a legal win. It was a statement about professional freedom.

It affirmed that no profession should be governed by a closed system that controls entry, standards, and practice through coordinated power.

Today, the chiropractic profession must confront a difficult question. Has it recreated the very system it once fought.

If so, the next chapter will not be written in history books about the AMA. It will be written in real time, through board decisions, public records, and the growing recognition that the fight for professional autonomy is not over.

It has simply changed sides.

CLICK HERE to review NBCE/FCLB Merger related documents including:

1. NBCE Financial Audit

2. FCLB Fianancial Audit

3. Delegate Memo

4. Institutional Risk Advisory

5. NBCE 990’s

6. NBCE Annual Reports

7. FCLB 990’s

8. FCLB Annual Reports

There is something deeply moving, and deeply unsettling, about seeing the handwritten notes of Herbert Ross Reaver, one of chiropractic’s most persecuted early practitioners, laying out arguments against racial segregation in a prison mess hall.

Reaver was not writing from a university boardroom. He was not writing from a nonprofit headquarters. He was not writing from the comfortable offices of a regulatory agency or testing corporation. He was writing as a chiropractor who had been repeatedly imprisoned for practicing chiropractic without surrendering to the medical monopoly of his time. And in those notes, he appears to be arguing that the prison’s segregated mess-hall line-ups were inconsistent, unnecessary, troublesome, harmful to discipline, and contrary to the real purpose of the institution.

That matters.

Because Reaver understood something many modern chiropractic leaders have apparently forgotten: systems that are unjust do not become legitimate simply because they are orderly. They do not become moral because they are traditional. They do not become acceptable because those in authority say they are necessary.

“Herbert Ross Reaver did not go to jail so future chiropractic leaders could build a private monopoly over chiropractic education, testing, licensing, and regulation.”

A Chiropractor in Prison, Arguing Against Institutional Control

The notes are practical, not sentimental. Reaver was not merely appealing to abstract ideals. He was making an institutional argument. Segregation in the mess-hall lines, he argued, was inconsistent with other prison practices. Men were already intermingled in other settings. The system created unnecessary guard duties. It encouraged cliques, tension, congestion, talking, disorder, and conflict. It made mealtime, already a crucial period in prison administration, more difficult to manage. It worked against discipline. It worked against respect. It worked against the stated purpose of the institution.

That is the genius of the document. Reaver was not only saying the system was wrong. He was saying it was irrational, inefficient, destructive, and indefensible even on its own terms.

That same kind of analysis is urgently needed in chiropractic today.

The profession is being told that consolidation is modernization. It is being told that centralization is efficiency. It is being told that the proposed NBCE-FCLB merger is merely a sensible administrative step. But when one examines the structure honestly, the same questions Reaver raised apply again.

Is the system consistent?

Is it necessary?

Is it creating unnecessary burdens?

Is it decreasing respect for the institution?

Is it contrary to the real purpose of the profession?

The answer, increasingly, is yes.

The Old Monopoly Was Medical. The New Monopoly Is Internal.

The early chiropractors fought an external monopoly. They fought a medical establishment that wanted to determine who could practice, what could be taught, what theories were acceptable, and which healing professions were legitimate. Many went to jail rather than submit to that system.

Today, the threat is different. It is no longer only the medical monopoly outside the profession. It is the monopoly structure inside the profession.

The Council on Chiropractic Education, the National Board of Chiropractic Examiners, and the Federation of Chiropractic Licensing Boards have created, over time, a closed-loop system of education, accreditation, testing, regulation, continuing education approval, specialty recognition, and board coordination. CCE controls accreditation. NBCE controls the national exams. FCLB coordinates state boards and regulatory programs. These entities then overlap through personnel, funding, governance, policy, committees, and state-board relationships.

NBCE’s own annual reports acknowledge the embedded role of state boards in its governance structure. States that use NBCE exams may name delegates and alternates to attend NBCE meetings, district delegates nominate directors, the full assembly votes on district nominees, and two NBCE board seats are filled by appointment from FCLB. NBCE also states that boards in every U.S. jurisdiction accept or require NBCE examinations as part of licensing criteria, while state board members participate in NBCE test development, standard-setting, Part IV administration, and governance.

That is not a loose professional relationship. That is an infrastructure of dependency.

“The profession that once resisted monopoly has allowed private corporations to become embedded in the machinery of public licensure.”

The Merger Will Not Fix the Problem. It Would Complete It.

The proposed NBCE-FCLB merger is being framed as coordination. But coordination is not the same thing as consolidation. Collaboration is not the same thing as absorption. Efficiency is not the same thing as monopoly.

NBCE’s 2025 Annual Report states that NBCE and FCLB are evaluating the possibility of uniting under a shared governance structure, describing it as part of a vision of coordinated licensure and regulation. The same report states that the proposal would require approval from the boards of both organizations and from the regulatory boards that comprise FCLB members and NBCE voting delegates.

That means the same regulatory ecosystem already intertwined with NBCE and FCLB is being asked to approve the consolidation of the very entities that shape its own regulatory world.

This is the irony. The people who claim to be protecting the public are now being asked to bless the most significant concentration of private chiropractic regulatory power in modern history.

The profession should not be fooled by language about efficiency, modernization, public protection, or nonprofit stewardship. The question is not whether NBCE and FCLB can produce polished reports, host webinars, or describe their work in reassuring institutional language. The question is whether one private entity should control the practical realities of chiropractic licensure testing, regulatory board coordination, continuing education approval, specialty recognition, ethics-related assessments, model regulatory influence, and the infrastructure through which state boards interact with the profession.

The answer should be obvious.

No profession committed to freedom should accept that.

Part IV Centralization Shows the Pattern

The Part IV centralization project is not separate from the merger issue. It is a preview of the same mindset.

NBCE describes its new centralized Assessment Center in Greeley, Colorado as a purpose-built facility designed to provide a standardized experience, expanded testing opportunities, and a modern clinical-skills assessment model. Its 2025 report states that the redesigned Part IV exam will include seven case-management stations and one chiropractic technique station, with encounters recorded using multiple cameras and microphones.

But from the perspective of students, schools, and the profession, centralization also means something else. It means a once-distributed practical examination, hosted across chiropractic college campuses, becomes physically and operationally controlled at NBCE’s headquarters. It means students must travel to Greeley. It means the final practical gate to licensure becomes even more dependent on one private corporation. It means chiropractic schools, which already educate, train, evaluate, and graduate students, are pushed further into a subordinate role under a testing monopoly.

And because CCE Policy 56 ties accreditation pressure to NBCE exam performance, NBCE’s control over exam structure does not merely affect students. It affects schools. It affects accreditation. It affects institutional behavior. It affects curriculum. It affects the entire educational marketplace.

That is not academic improvement. That is structural leverage.

“When a private testing corporation can alter the practical pathway to licensure and accrediting pressure forces schools to conform, education is no longer free. It is captured.”

The Abysmal State of Chiropractic Education Is Not an Accident

Across the profession, there is a growing recognition that chiropractic education is failing too many students. Graduates leave with crushing debt. Many question the value of the degree. Many believe their education did not adequately prepare them for practice. Many would not recommend chiropractic school based on value alone. Schools struggle with enrollment, identity, cost, outcomes, and public confidence.

This did not happen in a vacuum.

It happened inside a captured structure.

When accreditation is monopolized, testing is monopolized, state board pathways are monopolized, and professional legitimacy is filtered through the same interlocking entities, schools stop innovating for students and start complying for survival. They become increasingly concerned with satisfying CCE standards, NBCE outcomes, and regulatory expectations rather than building diverse, affordable, philosophically coherent, clinically excellent programs that serve the full breadth of chiropractic.

That is why the profession cannot fix this by consolidating the existing system.

You do not solve regulatory capture by giving the captured structure more power.

You do not solve monopoly by merging monopolists.

You do not solve educational failure by strengthening the entities that helped create the conditions for that failure.

You dismantle the structure. You restore competition. You remove private corporate names from statutes and regulations. You create alternate pathways. You separate accreditation from testing monopolies. You stop allowing state boards to function as transmission belts for private organizations. You return authority to the profession, the schools, the states, and the public.

Reaver’s Lesson for Today

Herbert Ross Reaver’s prison notes matter because they show a chiropractor thinking clearly about institutional injustice from inside the belly of the institution itself.

He saw that a bad system creates contradictions. He saw that it imposes unnecessary burdens. He saw that it produces disorder while claiming to maintain order. He saw that it undermines the very purpose it claims to serve.

That is exactly what the chiropractic cartel has done.

It claims to protect the public, while creating barriers that burden students and restrict entry.

It claims to promote educational quality, while presiding over a profession in which many graduates question the value of their education.

It claims to support regulatory consistency, while embedding private organizations into state licensing systems.

It claims transparency, while state boards across the country are now being scrutinized for entanglements, conflicts, delegate authority questions, and regulatory capture.

It claims modernization, while consolidating power into fewer hands.

It claims stewardship, while using student-funded examination revenue to expand institutional control.

“The issue is not whether chiropractic needs standards. The issue is who controls those standards, who benefits from them, and whether the profession has any meaningful freedom left.”

A Profession Built by Prisoners Should Not Be Ruled by Gatekeepers

There is a moral obscenity in watching modern chiropractic leaders invoke public protection, excellence, transparency, and professionalism while pushing a governance model that would have horrified the chiropractors who sacrificed their freedom for this profession.

The pioneers did not go to jail so that a private testing corporation could become the unavoidable gatekeeper of licensure.

They did not go to jail so that an accreditor could use that testing corporation’s exams as leverage over schools.

They did not go to jail so that a federation of licensing boards could coordinate regulatory culture across the states and then merge into the testing monopoly.

They did not go to jail so that students could borrow federal money, pay excessive exam fees, graduate underprepared, and enter a profession whose leaders tell them the answer is more centralization.

And Herbert Ross Reaver certainly did not go to jail so that chiropractic’s own leadership could reproduce the very logic of monopoly, exclusion, and institutional control that early chiropractors resisted.

The Vote Is a Line in the Sand

The upcoming NBCE-FCLB merger vote is not a routine governance matter. It is a referendum on the future of chiropractic freedom.

Every state board, every delegate, every school, every association, every chiropractor, and every student should understand what is at stake. This is not merely about two organizations combining administrative functions. It is about whether the profession will tolerate the consolidation of testing, regulatory coordination, continuing education influence, specialty recognition, and disciplinary assessment infrastructure under one private corporate umbrella.

The chiropractic profession does not need a stronger cartel.

It needs liberation from the one already built.

“The only honest path forward is not consolidation. It is dismantling the captured structure and restoring freedom in chiropractic education, licensing, regulation, and practice.”

Herbert Ross Reaver’s Warning

Reaver’s handwritten prison notes should haunt the profession.

They remind us that chiropractic was not born from comfort. It was not built by bureaucrats. It was not handed down by accrediting agencies, testing corporations, or licensing federations. It was built by people who endured prosecution, humiliation, imprisonment, and professional persecution because they believed the right to practice chiropractic was worth defending.

The question now is whether modern chiropractic still believes that.

If the profession allows NBCE and FCLB to merge, if it allows CCE, NBCE, and FCLB to continue tightening their grip, if it allows state boards to be captured by the very private entities they are supposed to evaluate independently, then chiropractic will have betrayed its own history.

Herbert Ross Reaver did not go to jail for that.

He went to jail for freedom.

And the least this profession can do is stop handing that freedom back to a monopoly dressed up as progress.

“The merger’s defenders are not offering a legal defense. They are offering an appeal to habit.”

The memo at the center of this debate cuts through the fog with unusual clarity. It argues that the repeated claim that delegates and state boards have done similar things “for decades” does not establish legality, ethical propriety, or statutory authority. Historical practice, it says, is not legal authority. Private bylaws do not expand public power. And when public regulators are asked to participate in an extraordinary restructuring of private entities intertwined with licensure and regulation, the answer has to come from state law, not institutional habit.

That is the heart of the story here, and it is the point every delegate should focus on before a single vote is cast.

CLICK HERE to review the memo

This is not a routine vote

NBCE’s own materials describe state delegates as part of the governance machinery of a private Texas nonprofit. States that use NBCE exams may send delegates and alternates to the annual meeting, district delegates nominate directors, the full delegate assembly votes on those nominations, and state boards serve as an important constituency in the process. The 2025 annual report then confirms that NBCE and FCLB moved forward with a formal proposal to combine and that the plan would ultimately require approval by the regulatory boards that comprise FCLB members and NBCE voting delegates.

The memo argues that merger proponents are trying to blur the distinction between ordinary governance and an extraordinary corporate restructuring. That distinction is everything. The proposed transaction is described not as housekeeping, but as structural consolidation, involving the merger or absorption of functions, elimination of organizational separation, reallocation of governance authority, and deeper consolidation of control over entities already embedded in the licensure system.

That is why this is not “just another vote.”

“State boards derive their authority from statute, not from the bylaws of private entities and not from longstanding custom.”

The sales pitch is not the same as legal protection

This is where the role of lawyers matters.

If NBCE and FCLB counsel, including figures such as Dale Atkinson for FCLB and Jennifer Semko for NBCE, are out in front reassuring delegates that this is ordinary, familiar, or something boards have long done, delegates should understand exactly what that reassurance is worth. According to the memo, the operative legal question is not whether a private organization’s governing documents permit a vote. The real question is whether state law authorizes a public board or delegate to cast it.

That is not a small distinction. It is the whole case.

Lawyers advising the organizations are there to protect the organizations. They are not necessarily the ones who will defend an individual delegate, an individual board member, or an individual state board when an ethics complaint, open meetings challenge, procurement issue, conflict-of-interest allegation, or ultra vires claim lands on their desk. The memo expressly says the inquiry requires examination of statutory text, administrative law principles, ethics rules, conflict-of-interest requirements, vendor and procurement relationships, and the precise legal nature of the vote itself.

That means any delegate being told to relax should ask a simple, devastating question: Will you represent me when this blows back on me personally?

And then a second one: Will you put that in writing?

The one document that matters most

The memo says the burden is on merger proponents to provide specific, comparable, and legally reviewed examples. It goes further, stating that if proponents want to rely on past practice, they should identify which boards participated, what was voted on, what state law governed, and whether board counsel or an attorney general reviewed the action.

That point cannot be overstated.

The single most important thing any delegate should know before acting is whether there is a written opinion from the state attorney general, or some equivalent formal written state legal opinion, concluding that the delegate’s participation is lawful under that state’s governing law. Not a verbal assurance. Not a wink and a nod from organization counsel. Not a hand-wave to tradition. A written opinion.

Because if no such opinion exists, then the delegate is not standing on law. The delegate is standing on confidence. And confidence evaporates quickly when litigation starts.

“The correct inquiry is straightforward… Does this board, under its governing law, possess authority to engage in this act now?”

Custom is not a defense

The memo’s most important contribution is that it demolishes the lazy argument that repetition cures defect. It says plainly that a practice may be longstanding and still unlawful, common and still beyond statutory authority, normalized and still infected by conflict. “This has been done for decades,” the memo says, is not a legal defense. It is an appeal to habit.

That matters because the merger advocates appear to be leaning heavily on the psychology of familiarity. They want delegates to think: Boards vote. Delegates vote. These organizations have always worked together. Nothing unusual here.

But the memo warns that this kind of argument may actually prove the opposite of what proponents intend. The more they insist that public regulators and private licensure bodies have been intertwined for decades, the more they risk proving longstanding structural entanglement rather than legitimacy. In the memo’s words, what is described as tradition may be longstanding normalization of conflict.

That should alarm every honest regulator in chiropractic.

Delegates should ask these questions publicly

Before any vote is cast, every delegate should ask, on the record:

Do I have written authority under my state’s law to cast this vote?

Has my state attorney general, board counsel, or other authorized state legal officer issued a written opinion saying so?

If not, why am I being told to proceed anyway?

If NBCE or FCLB counsel believe this is lawful, will they represent me, my board, and my state if the legality of my participation is challenged later?

If they will not, why should their reassurance be enough for me now?

Those are not hostile questions. They are the minimum questions that serious fiduciaries and public officials should ask before participating in a consequential restructuring of private entities that sit at the center of chiropractic licensure and regulation. The memo specifically says that state-specific legal analysis is indispensable and that what other boards may have done elsewhere is not enough.

The deeper problem

There is an additional irony here. NBCE’s own reports repeatedly celebrate collaboration with state boards, describe delegates as part of its governance structure, and present the coming combination with FCLB as a strategic institutional advance. But the memo forces a much harder question: at what point does “collaboration” become entanglement, and at what point does entanglement become legal exposure?

That is not academic. It goes to the heart of whether public regulatory power is being exercised independently under state law or informally absorbed into the governance expectations of private corporations.

Final word

Delegates should not be bullied by momentum, reassured by custom, or impressed by polished legal talking points delivered on behalf of NBCE and FCLB. If Dale Atkinson, Jennifer Semko, or any other lawyer wants delegates to treat this merger vote as safe and ordinary, they should answer the only questions that matter.

Where is the written state legal authority?

Where is the written attorney general opinion?

And when the complaints, subpoenas, and lawsuits come, will you be the one representing the delegates who relied on your advice?

Until those questions are answered in writing, no delegate should confuse a sales pitch for a legal shield.

“A state board’s authority must come from law, not tradition, and no amount of repeated conduct can turn an unexamined custom into a lawful public act.”

The Nevada Chiropractic Physicians’ Board is no longer facing a single conflict problem. It is facing a conflict structure.

What first appeared to be a troubling but limited controversy involving Jason Jaeger, Julie Strandberg, and the April 16 board meeting has now widened into something much more serious. According to publicly available data on the FCLB website the President of the Board Benjamin S. Lurie has been assigned to serve as an FCLB delegate and that Adam L. Ingles DC the Vice President of the Board has also been designated as a delegate for the upcoming merger meeting between the NBCE and FCLB.

At this point, the public is entitled to ask whether Nevada’s merger process was ever independent at all.

Because by this point the pattern is no longer incidental. It is systemic.

The conflict net keeps expanding

The public already knew that Jason Jaeger sat at the center of the merger controversy. He serves on the Nevada board as Secretary Treasurer while also holding senior leadership roles in NBCE as its Vice President, and he was directly named during public comment on April 16 as a figure whose overlapping positions “look like a conflict of interest from outside viewers.”

The public also now knows that Julie Strandberg, the Executive Director responsible for Nevada’s notices, records, and administrative process, is listed on two FCLB committees in 2026: the PACE Committee and the RCSP Committee. That means the official charged with helping Nevada oversee outside frameworks was simultaneously seated inside the private federation structure advancing them.

And the public saw Louis Ling, Nevada’s longtime board counsel, halt the April 16 meeting after conflict questions were raised, citing an apparent open meeting law posting issue. That intervention came only after the public had begun pressing on merger power, institutional overlap, and Jaeger’s role. Ling also has a history with the FCLB.

Now come the additional questions involving Ben Lurie and Adam Ingles.

If Lurie and Ingles were delegates, the picture changes dramatically

If Lurie and Ingles had already been designated as delegates in connection with the FCLB-NBCE merger process, then the problem is no longer limited to one conflicted board member or one compromised executive director. It reaches into the leadership core of the Nevada board itself.

Lurie was not some detached observer. He chaired the April 16 meeting. He heard the conflict-of-interest concerns raised by members of the Chiropractic Freedom Coalition. He dismissed those concerns in broad terms rather than addressing the facts one by one. And the meeting then came apart immediately afterward.

Ingles was not peripheral either. He was part of the Nevada board leadership team and appears prominently on the meeting notices and board agenda structure. The same agendas that placed “FCLB/NBCE Matters” before the board also show Lurie and Ingles in positions of authority over the process.

If the people chairing, administering, and controlling the state board’s merger discussion were also the same people participating in delegate channels tied to that merger, then Nevada was not acting as an independent state regulator. It was functioning as a node inside the merger apparatus.

“At some point, ‘overlapping roles’ stops sounding accidental and starts sounding structural.”

Nevada’s public process now looks compromised from every angle

The April 16 meeting should have been the moment when the public finally got answers. Instead, it became the moment when the state’s process itself came under suspicion.

The meeting opened. Public comment began. Serious concerns were raised about NBCE, FCLB, Part IV centralization, Jaeger’s dual roles, and the tightening of power under the proposed merger. The board then approved the agenda. Only after that did counsel step in and stop the proceeding.

Afterward, the board treated the meeting as “cancelled,” even though the transcript shows it had already opened and taken action. Then it reposted the matter on a new agenda that identified April 25, 2026 as a Thursday even though April 25 is a Saturday.

This is the context in which the questions about Lurie and Ingles become so important. Nevada’s process was already unstable. It was already under a cloud. If, on top of all that, the board’s own chair and another top official were also tied into the delegate structure surrounding the merger, then the public has every reason to question whether the April 16 and April 25 proceedings were ever designed to provide impartial state-level review in the first place.

The real questions Nevada now has to answer

The burden is now on Nevada to answer questions that should have been addressed before any merger matter ever appeared on the agenda.

How and when were delegates assigned?

Did the full Nevada board vote in an open meeting on those assignments?

Did anyone obtain a legal opinion regarding whether Lurie, Ingles, Jaeger, or Strandberg had disqualifying or disclosable conflicts in relation to the merger?

Were any recusals considered?

Were any written conflict disclosures filed?

Were the public and other board members told, on the record, who was wearing which hat at the time the merger issue was being discussed?

These are not side issues. They go directly to whether Nevada’s board was capable of exercising independent judgment at all.

“When the same handful of people are staffing the board, shaping the agenda, sitting inside FCLB structures, leading NBCE, and potentially serving as delegates, the line between regulator and participant begins to disappear.”

Jaeger, Strandberg, Ling, Lurie, Ingles: this is the same story

It is tempting to treat each name as a separate controversy. That would be a mistake.

Jaeger represents the NBCE-state board overlap. Strandberg represents the FCLB-state board administrative overlap. Ling represents the legal gatekeeping function that shut the meeting down the moment the conflict questions, including his, hit the room.

Lurie and Ingles now raise the question of whether the Nevada board’s own leadership was also tied into the delegate side of the same merger they were supposed to address in a neutral state proceeding.

Taken together, this is not merely a messy meeting. It is an emerging portrait of a board whose leadership, counsel, and administration may all have been entangled in the very network they were supposed to scrutinize.

Nevada’s two consumer members, Christian L. Augustin, Esq., and Reza R. Ayazi, Esq., may now become especially important to whether this board can regain its footing. As attorneys serving in consumer seats, they are uniquely positioned to insist on what the public should have been able to expect from the start: accurate notice, lawful process, real conflict disclosures, and independent judgment free from institutional entanglement. If this board is going to stop spiraling deeper into procedural failure and credibility damage, these may be the members best situated to demand that Nevada’s chiropractic regulation start functioning like a public body again instead of a captured insider network.

Why this matters beyond Nevada

The merger is not an ordinary housekeeping matter. It is a proposed consolidation of power inside chiropractic testing and regulation and involves the merger of a private corporation with $50 million dollars in assets and secret for profit subsidiaries hidden under the non profit that owe the non-profit millions of dollars. It comes at a time when more states are asking harder questions, withholding support, or refusing to treat the merger as a foregone conclusion.

Who controls EBAS? Why does it owe the NBCE nearly $5 million dollars and where did that money go?

If the Nevada Board argues that its is a member of the FCLB and that board members have voting rights as NBCE delegates then the Nevada board had better be asking to see where all the money is related to the merger it is voting on.

That is exactly why Nevada matters.

If Nevada cannot show that its leadership handled this issue with full transparency, full disclosure, and genuine independence, then the board has become an example of the very thing critics have been warning about: a state regulatory body operating less like an outside check and more like an internal partner in the cartel structure.

The public deserves the paper trail

At this point, Nevada should not expect trust. It should expect demands.

The state should immediately disclose any delegate designations involving Lurie and Ingles, any legal opinions obtained on conflicts, any recusals considered or rejected, any written disclosures filed, and any communications concerning how Nevada’s representatives were selected for the merger process.

Because the question is no longer whether there was one conflict too many.

The question now is whether Nevada’s merger proceedings were conflicted from the top down.

CLICK HERE for previous stories about Nevada

The proposed merger of the National Board of Chiropractic Examiners and the Federation of Chiropractic Licensing Boards is being presented by critics not as a routine corporate reorganization, but as a profession-defining event with consequences that could reach from chiropractic students taking exams all the way to college presidents, financial officers, state delegates, and practicing doctors. That is why the April 30, 2026 vote matters. It is not merely a question of efficiency or modernization. It is a question of power, accountability, legal exposure, and who ultimately controls the educational, licensing, and regulatory pipeline of an entire profession.

“It is a watershed moment.”

At the heart of the concern is a simple but deeply unsettling idea. If one private structure controls accreditation pressure, exam performance, board advisory influence, continuing education pathways, specialty recognition, and even certain disciplinary assessment functions, then the profession is no longer dealing with separate institutions that can at least theoretically check one another. It is dealing with a consolidated system. The materials reviewed describe that system as an already tightly interconnected arrangement among CCE, NBCE, and FCLB, and warn that the merger would remove what little organizational separation still exists on paper.

This Is Not Just an Internal Fight

Many chiropractors may be tempted to view this as a dispute among insiders, board officials, and organizational leadership. That would be a mistake. The argument laid out in the advisory and explored in the podcast is that the risk does not stay at the top. It travels down the chain. It begins with private governance decisions and flows through accreditation standards, licensure requirements, student loan funding, school policy, and state board authority until it reaches ordinary people whose careers and livelihoods depend on the system working lawfully and transparently.

CLICK HERE to listen

That is why this issue deserves the attention of everyone, not just lawyers. A student may think this is about organizational politics. A college administrator may think it is about accreditation strategy. A practicing chiropractor may think it concerns only future graduates. But if the structure itself is legally unsound, then each participant in the chain may be carrying risk they did not create, did not fully understand, and may not be able to avoid once the consolidation is complete.

“If you are listening right now, you are not a bystander.”

The Students at the Bottom of the Pipeline

The most vulnerable people in this system may be the students, because they are the entry point for both money and dependency. The materials argue that students finance NBCE exam fees through federal Title IV loans and that those exam costs are built into institutional cost-of-attendance calculations. In plain English, that means federally backed student loan dollars help fund the examination structure at the center of this controversy. The arrangement has been described bluntly: students pay thousands of dollars in exam fees, those fees generate substantial revenue, and that revenue helps sustain the broader governance loop.

That matters because students are not simply paying for a test. According to the critics, they may be funding a system that then governs their education, graduation, licensure path, and future professional obligations. If that system is later challenged successfully on antitrust, conflict-of-interest, or ultra vires grounds, students could become not only victims of the burden, but also key plaintiffs in future legal actions. The possibility is raised that students denied graduation or forced to absorb higher costs under a potentially unlawful structure could have standing to sue.

The Schools Caught in the Middle

Chiropractic institutions are in an especially dangerous position because they sit in the middle of the pipeline. They are not merely observers. They certify costs, administer aid, answer to accreditors, and in some cases adopt internal academic policies designed to survive under mounting pressure. The advisory specifically warns that schools are exposed through Title IV certifications, cost-of-attendance calculations, and their dependence on CCE Policy 56, which uses NBCE outcomes as the practical measure of student achievement.

This is where the legal danger becomes easier to understand. If a school signs federal certifications that treat NBCE exam fees as legitimate educational costs inside a lawful framework, and if that framework is later shown to be tainted by unlawful regulatory capture or unauthorized board conduct, those certifications could come under scrutiny. The advisory frames this as potential False Claims Act exposure, with possible qui tam whistleblower suits brought by insiders or students. The point is not that every school has done something wrong knowingly. The point is that good-faith participation in a flawed system does not automatically erase legal consequences once the public record is developed and the risk becomes harder to deny.

“Good faith is a defense, not an immunity.”

The danger becomes even sharper when schools change their own internal rules to accommodate the system. An even deeper concern are that some institutions are making NBCE passage a graduation requirement in order to protect their pass-rate metrics and stay in compliance with accreditation expectations. That may look like a practical administrative decision, but legally it collapses the distance between a school and a disputed private examination mandate. In that scenario, the school is no longer merely reacting to state licensure requirements. It is embedding the private exam directly into its own degree-granting authority.

The Officers Whose Names Are on the Paper

The risk to institutions is often discussed abstractly, but the advisory does not describe it that way. It identifies specific people whose signatures appear on the relevant documents: the president or chief executive officer, the chief financial officer, the director of financial aid, and even independent auditors in certain contexts. These are not faceless offices. They are individuals who sign program participation agreements, management representation letters, and financial aid certifications. If those documents are later alleged to contain false or materially misleading statements, the exposure does not belong only to the institution as an entity. It may reach the people who signed.

This is one of the most sobering aspects of the entire matter. A merger pitched publicly as an organizational improvement could, if the underlying allegations gain traction, create downstream exposure for people who never designed the structure and may not even support it. That is why the advisory repeatedly urges immediate review by legal counsel and compliance teams before the vote. It is also why no college leader should dismiss this as somebody else’s fight.

The Delegates and Board Officials Near the Top

The danger does not end with schools. It rises back up to the delegates and board officials who are directly involved in the April 30 vote. One of the most important legal arguments in the advisory is that state board delegates may lack statutory authority to vote on the corporate dissolution of one private entity into another. If that is true in a given jurisdiction, then a delegate who votes anyway may be acting outside lawful authority. The materials cite state-level legal concerns in places such as Vermont and New Mexico, while also noting that Texas’s counsel flagged serious issues surrounding post-merger legality and board participation.

This is not a technicality. In a regulated profession, authority matters. If the law grants a board or delegate power to regulate licensure, that does not automatically mean it grants power to restructure private corporate governance. When the line between public authority and private organizational control becomes blurred, the legitimacy of the action itself can come into question. Critics argue that a “yes” vote under those circumstances could do more than change the profession’s governance. It could expose participants to claims that they acted beyond the law.

“The structural dependencies of your entire profession are quite literally on the ballot.”

The Practicing Chiropractors Who May Think They Are Safe

Many licensed chiropractors may assume that once they are out of school and already in practice, the merger has little direct effect on them. But the materials say otherwise. The proposed consolidation would bring under one structure not only licensure examinations, but also continuing education pathways, specialty recognition systems, and certain ethics-related assessment functions. That means the merger would not just shape entry into the profession. It could shape maintenance of status within the profession from beginning to end.

The issue is therefore not simply whether one approves of one organization or another. The issue is whether a single private structure should sit at so many controlling points in the professional life cycle. Once that concentration is normalized, challenging it later becomes harder, not easier. Critic’s make this point repeatedly: today’s formal merger could become tomorrow’s corporate monolith, one with influence over who enters the profession, how they remain in it, what continuing education counts, what specialties matter, and possibly even what professional identity survives.

The Larger Fear Beneath the Legal Arguments

The legal issues are grave enough on their own. But beneath them lies a broader fear: that control over structure becomes control over ideology. The memorandum points to what they describe as a long-running campaign by a narrow academic and regulatory elite to reshape chiropractic through accreditation, board capture, faculty pressure, and doctrinal gatekeeping. Whether one agrees fully with that account or not, the warning is clear. When one governance system controls the toll booths, it has power not only over compliance, but over definition. It can influence what is taught, what is tested, what is rewarded, and what is pushed to the margins.

That is why this controversy cannot be dismissed as an esoteric debate over bylaws. The fight is about governance, but governance is never just procedural. Governance determines who decides, who pays, who bears the risk, and what future options remain open once the decision is made.

“Maybe this merger isn’t just about corporate efficiency at all. Maybe it’s about ideological eradication.”

Why the Urgency Is Real

The urgency is real because consolidation is usually much easier to approve than to unwind. Once a merged structure is in place, the political, financial, and legal barriers to dismantling it become far greater. The advisory warns that the current system is already deeply embedded in statutes, rules, accreditation standards, and funding mechanisms. A merger would not create that entrenchment from scratch, but it could harden it. In the words of the podcast, silence, confusion, and inaction benefit the consolidation of power.

That is the message every person in the chain should hear. Students should understand what they are financing. School officials should understand what they are certifying. Delegates should understand what authority they may or may not possess. Practitioners should understand what kind of professional structure they may be locking in for decades. And the public should understand that private concentration inside a licensed health profession is never a minor matter.

Final Warning

There are moments when a profession must decide whether it is witnessing a routine administrative change or a structural turning point. By every account presented in these materials, this merger vote is the latter. It presents a serious question: whether the chiropractic profession will move toward greater concentration of authority in one private structure at the precise moment when legal, ethical, and institutional concerns about that structure are becoming more visible, not less.

The people at risk are not limited to the usual power players. They include the student paying the exam bill, the school officer signing the certification, the delegate casting the vote, the practitioner living under the continuing education regime, and the profession that may one day discover that what was marketed as consolidation was, in fact, surrender.

The deeper the profession looks into the proposed NBCE-FCLB merger, the harder it becomes to ignore what is really being revealed. This is not simply a governance dispute. It is a money story, a conflict-of-interest story, and a story about a closed system in which the same insiders who control testing, influence regulation, and are shaping the NBCE/FCLB merger documents are also being paid from the very pipeline they helped build.

At the center of that story are Karlos Boghosian, Jason Jaeger, and Leroy Otto.

What emerges from the record is not merely bad optics. It is a pattern. Students are forced into a private, corporate licensing and testing structure by the NBCE monopoly. Those fees, backed by student loan debt, do not simply fund basic exam administration. They also fund executive compensation, board stipends, unnecessary construction of new buildings, influence networks, grants to friendly cartel diaspora, international travel, and even first-class international airfare for board insiders.

The students pay. The insiders fly.

The numbers are stark.

The NBCE’s own FY2024 Schedule J disclosed that in 2024, three board members received reimbursement for first-class airfare for business travel: Dr. Leroy Otto, Dr. Karlos Boghosian, and Dr. Jason Jaeger. The total cost was $21,944. The publicly available tax records also show that in 2023 Boghosian flew Delta One, international business class, to Australia at a cost of $14,430. All of it, according to the same memorandum, was paid from unnecessary but mandatory student examination fees.

That is the kind of detail that strips away the usual nonprofit rhetoric. The profession is constantly told these organizations exist to protect standards, public safety, and the public trust. Yet the money trail tells a different story. Students borrow heavily to enter the profession. They are then required to pay into a private testing monopoly. And from that same revenue stream, cartel leadership is flying first class around the world.

There is no serious way to frame that as sacrifice. There is no serious way to frame it as austerity. And there is certainly no serious way to frame it as serving struggling students.

Karlos Boghosian and the triplicate conflict

If one person symbolizes the structural conflict at the heart of this system, it is Karlos Boghosian.

Boghosian is the poster child for conflicts of interest “serving” simultaneously as chair of the Connecticut State Board of Chiropractic Examiners, President of NBCE, Immediate Past President of FCLB, and a member of the FCLB Resolutions and Bylaws Committee that drafted the very merger bylaws he will benefit from. In other words, he is not just participating in the process. He is sitting in multiple seats at once inside it and orchestrating it.

The compensation history is just as telling. According to the tax records, Boghosian’s NBCE compensation went from $10,980 in 2022 to $60,333 in 2023 and then to $71,657 in 2024, a two-year increase of 553 percent. All the while he has been conducting the behind the scenes machinations necessary for the most historic takeover of chiropractic in its history. The same document states that his average hours per week at NBCE were disclosed as 12, which works out to roughly $115 per hour.

That alone would raise eyebrows. But the conflict deepens when one considers what happened at the March 26 Connecticut board meeting. Boghosian presided over the meeting that designated Connecticut’s delegates for the April 30 merger vote. During that meeting Boghosian resisted public comment , even claiming whine confronted that there was no public comment period on the agenda - Board staff had to give him the bad news that it was in fact on the agenda.

CLICK HERE to see the Agenda

Unfortunately Boghosian ignored the agenda and led the vote on the delegate designation despite being NBCE President and a direct beneficiary of the merger process.

It should also be noted that NBCE’s own conflict policy says that if a conflict exists, the interested person shall not vote and shall leave the room during the final discussion and vote. Boghosian did not such thing. He remained, presided, and voted.

Even worse, Garrick Campbell, lay member of the Connecticut Board who was nominated to take Boghosian’s place as the delegate also voted or himself.

We are not making this up. Its all on video.

That is not merely a perception problem. It is the kind of fact pattern that causes reasonable people to ask whether the cartel’s rules are only for everyone else. Keep in mind that these Connecticut Board members pass judgement and sanction chiropractors in the state for unethical behavior. Yet here they are using the state of Connecticut for their own purposes without batting an eye.

Jason Jaeger and the Nevada-NBCE pipeline

Jason Jaeger serves as another example of how deeply intertwined the regulatory and financial structure of the Chiropractic Cartel has become.

Jaeger is Secretary-Treasurer of the Nevada State Board of Chiropractic Examiners, Vice President of NBCE, a Past President of NBCE, a member of the same FCLB Resolutions and Bylaws Committee that drafted the merger documents and a member of the Board of Directors of the International Chiropractor’s Association (ICA). Jaeger’s NBCE compensation was $35,661 in 2022, $27,033 in 2023, and $46,896 in 2024. He was also reimbursed for first-class airfare in 2024.

(Pictured Left to Right: Jason Jaeger, William Morgan, Norman Ouzts Together at a meeting of the NBCE with The World Federation of Chiropractic. The WFC along with the NBCE intend on taking control of chiropractic education and licensing internationally)

But the most revealing issue may be his own admission to the Nevada board. According to a Nevada Board meeting transcript Jaeger told the Nevada Board that EBAS is “the for-profit arm of the NBCE” and that its revenue “has doubled,” while the Nevada Board refers licensees to EBAS for disciplinary assessments. FOIA records reveal his multiple roles was not disclosed as a conflict.

That matters enormously. It suggests a regulator sitting in a government role while acknowledging growth in a for-profit arm of the same private corporation to which the regulatory system is connected. That is exactly the kind of overlap that destroys public confidence and feeds the growing concern that chiropractic regulation has become captive to private corporate interests and those who run them and benefit from them.

Leroy Otto and the luxury-travel question

Leroy Otto was one of the three NBCE board members reimbursed for first-class airfare in 2024.

Otto represents a textbook example of long-term entrenchment within the chiropractic cartel’s leadership structure. His tenure spans more than a decade across overlapping roles within the Federation of Chiropractic Licensing Boards and the National Board of Chiropractic Examiners, including service as an FCLB Appointed Director from 2011 to 2015, At-Large Director from 2015 to 2016, District II Director from 2016 to 2024, and Vice President from 2019 to 2023.

He also served as NBCE Secretary and, according to the 2024 tax records, was paid $55,733 that year alone fir a few hours a week. His receipt of the 2017 Tullio Award and the 2025 NBCE Lifetime Achievement Award is not merely ceremonial. It reflects institutional endorsement of a career spent advancing and maintaining the same consolidated power structure now under increasing scrutiny.

In the context of documented conflicts of interest, financial entanglements, and the proposed NBCE-FCLB merger, Otto’s decorated career illustrates how the cartel rewards longevity, loyalty, and service to the system, reinforcing a closed network in which the same insiders shape policy, benefit financially, and are then honored by the institutions they helped entrench.

Even without the additional biographical detail Otto’s inclusion is important for a simple reason: it shows that this was not a one-off indulgence attached to a single individual or trip. It was a broader practice. Boghosian was not alone. Jaeger was not alone. Otto was part of the same first-class reimbursement pattern.

And that pattern is what matters.

Because once the profession accepts that student debt can be funneled this way, the issue is no longer one traveler or one itinerary. It becomes a cultural, ethical and moral question. What kind of organization believes it is appropriate to extract mandatory fees from indebted students and then use those funds to underwrite luxury travel for its leadership?

And that’s without even touching on the legality of any of this.

The merger is also a money rescue

These personal conflicts are tied to the larger merger story.

FCLB’s own FY2024 Form 990 disclosed that 62 percent of FCLB’s annual support in 2024 came from NBCE, and that for the 2020–2024 period, 63 percent of FCLB’s support came from NBCE. It further states that NBCE transferred $868,468 to FCLB in 2024 alone and that without that funding, FCLB cannot survive. The memorandum’s conclusion is blunt: the merger is a financial rescue, not a modernization as the Cartel leadership would like us to believe.

That financial dependence casts the luxury travel in an even darker light. This is not a picture of healthy, independent institutions collaborating for the public good. It is a picture of a private corporate ecosystem kept afloat by state sanctioned monopolies and examination revenue, now moving to formalize and lock in a relationship that has long been sustained through shared money, shared leadership, and shared control.

The same document also states that NBCE distributed more than $1.13 million in grants in 2024 across the chiropractic ecosystem to Cartel friends and paid Baker & McKenzie LLP $202,081 while spending $65,033 in travel to East Asia and the Pacific. These trips are apparently related to the NBCE’s efforts to control chiropractic education internationally along with the World Federation of Chiropractic. These are not incidental details. They show the scale of the financial network built on the backs of mandatory testing fees.

This is what cartel behavior looks like

Cartels do not always announce themselves with a sign on the door. Often they reveal themselves through structure.

They reveal themselves when the same people rotate between regulator, officer, committee member, and beneficiary. They reveal themselves when the entity that “advises boards” is largely funded by the entity whose exams the boards require. They reveal themselves when the bylaws are drafted by insiders who stand to benefit from the outcome. And they reveal themselves when leadership treats student-financed revenue as a slush fund for executive pay, influence, and premium travel.

That is why the issue here is bigger than first class seats. The airfare matters because it is visible. It is concrete. It is easy to understand. But the real scandal is what those seats represent: a ruling class inside chiropractic that appears to believe the money will keep flowing, the conflicts will keep being ignored, and the profession will keep accepting the arrangement as disgusting as it is.

The question the profession should now ask

Every student, every doctor, and every state board member should now be asking a very simple question.

Why should a profession that says it cares about access, ethics, and public trust tolerate a system in which private corporate insiders with overlapping regulatory power can collect compensation, steer institutional change, and fly first class on revenue extracted from students who had no real choice but to pay?

That is not stewardship. That is entitlement.

And the more the record comes into view, the more it looks like the chiropractic profession is not dealing with isolated excesses. It is dealing with an institutional culture that has confused monopoly power with permission.

There is a natural instinct, when examining something as complex and entrenched as the chiropractic cartel, to focus on its architecture. The formal relationships between the National Board of Chiropractic Examiners, the Federation of Chiropractic Licensing Boards, and the Council on Chiropractic Education. The policies that bind them. The financial and operational ties that connect education, examination, and licensure into a single, interdependent, monopolistic system.

That analysis is necessary, but it is incomplete.

Because systems like this are not sustained by structure alone. They are sustained by people. More specifically, they are sustained by a class of individuals whose commitment to the system transcends evidence, scrutiny, and even self-interest.

They are ideologues.

An ideologue, in this context, is not simply someone with strong opinions or professional preferences. It is someone whose identity is so closely tied to a system that questioning the system becomes indistinguishable from questioning themselves. Evidence that challenges the structure is not weighed on its merits, it is dismissed as misguided, uninformed, or even dangerous.

This mindset is not confined to a single chiropractic organization or role. It is distributed across the entire chiropractic ecosystem, from state regulatory boards to national testing bodies, from accreditation leadership to academic institutions and professional associations. It is not always obvious. In fact, it rarely is. More often, it presents as professionalism, experience, or institutional loyalty.

But its effects are unmistakable.

At the state level, this dynamic reveals itself in the quiet acceptance of profound change without meaningful inquiry. Board members who are entrusted with protecting the public and upholding statutory authority often speak in the language of continuity. They emphasize consistency, national standards, and administrative efficiency. Yet beneath that language lies a refusal to engage with the substance of what is actually occurring.

A licensure pathway that is being materially altered through centralized examination and control is treated as if it were unchanged. Ongoing financial and operational relationships with private corporations that influence licensure policy are accepted without rigorous examination of authority or conflict. Participation in private corporate governance by agents of the state, including delegate voting on matters that shape regulatory outcomes, is framed as routine rather than consequential.

This is not oversight. It is rationalization.

“The ideologue does not need to prove the system works. Only that it must be preserved.”

At the national level, the same mindset becomes more visible, not because it is more extreme, but because it is more embedded. The National Board of Chiropractic Examiners advances centralization under the premise of standardization and efficiency. The Federation of Chiropractic Licensing Boards promotes alignment through model acts and coordinated policy frameworks. The Council on Chiropractic Education reinforces accreditation standards that, through mechanisms such as CCE Policy 56, tether educational legitimacy to participation in NBCE-administered examinations.

Each component, viewed in isolation, can be defended. Each can be explained as a practical response to complexity.

But taken together, they form a system in which the traditional separation between education, examination, and licensure begins to collapse. What emerges is not merely coordination, but consolidation. Not simply cooperation, but control.

And yet, those operating within this system often do not perceive it as such. The ideologue does not see the pattern because they are invested in the premise.

If the inner circle of the system is sustained by ideologues, its stability depends just as much on those who operate in its outer orbits. These are the individuals who do not sit on boards, who do not draft policy, and who do not directly participate in the governance structures that define the cartel. They are practicing chiropractors, educators, consultants, and stakeholders who intersect with the system indirectly.

They attend the same conferences. They collaborate on projects. They maintain professional and personal relationships with those inside the system.

When confronted with evidence of restraint of trade, anticompetitive consolidation, or conflicts of interest, their response is rarely outright denial. More often, it is hesitation.

The hesitation is not rooted in uncertainty about the facts. It is rooted in the consequences of acknowledging them.

“To confront the system is, in many cases, to confront the people you know.”

And so, the response becomes silence, minimization, or delay. Not an active defense of the system, but a passive reinforcement of it. In this way, the outer orbit becomes just as critical to the system’s persistence as its core.

What makes the current moment so striking is not that these dynamics exist, but that they are increasingly visible, and yet still treated as ordinary. State boards maintain relationships with private corporations that shape licensure policy. Board members occupy overlapping roles that influence both examination development and regulatory enforcement. Structural changes to licensure pathways are implemented without corresponding statutory reconsideration. A merger is proposed that would further consolidate already intertwined spheres of influence.

None of this is hidden.

It is discussed in meetings, reflected in records, and acknowledged in public forums.

“When systemic conflicts of interest become routine, the issue is no longer concealment. It is normalization.”

This normalization is precisely what the nationwide investigation undertaken by the Chiropractic Freedom Coalition seeks to expose. Through coordinated open records requests, legal analysis, and sustained engagement across multiple states, the investigation has revealed a pattern that is difficult to ignore. The same organizations appear repeatedly. The same justifications are offered across jurisdictions. The same resistance emerges when foundational questions are asked.

What initially appears as a collection of independent decisions begins to reveal itself as a coherent structure, maintained not only by formal relationships, but by shared assumptions and mutual reinforcement.

This is not merely a structural problem. It is a cultural one.

It would be far easier if the challenge were limited to policy reform or legal intervention. Structures can be changed. Rules can be rewritten. Authority can be clarified.

But belief systems are more resilient.

They persist because they are internalized. They shape how individuals interpret information, how they respond to criticism, and how they justify inaction. They allow individuals to participate in a system that raises serious legal, ethical, and professional concerns while continuing to view that participation as normal, or even necessary.

“Structures can be dismantled. Belief systems must be abandoned.”

The chiropractic profession now finds itself at a point where the evidence is no longer in question. The concerns related to restraint of trade are not speculative. The antitrust implications are not theoretical. The conflicts of interest are not hidden. They are documented, observable, and increasingly difficult to dismiss.

What remains uncertain is not what is happening, but how the profession will respond to it.

Will it continue to accept these conditions as the cost of maintaining order and uniformity? Will it defer to established institutions without examining the extent of their influence? Or will it recognize that the preservation of professional autonomy requires more than passive acceptance of existing structures?

“All values must be fought for and vigorously defended.”

That principle does not apply only to philosophy. It applies to governance, to education, to licensure, and to the very framework within which the profession operates.

The chiropractic cartel is not sustained by secrecy. It is sustained by belief, by those who defend it, by those who benefit from it, and by those who are unwilling to confront it.

Until that changes, nothing else will.

The question is no longer whether the evidence exists. It is whether enough people are willing to see it clearly, and act accordingly.

A Word That Appears Everywhere

If there is one word that repeatedly appears in the messaging coming from chiropractic’s national regulatory organizations, it is “modernization.”

The term appears in presentations, white papers, and legislative discussions. It is used to justify statutory revisions tied to accreditation language. It appears in discussions surrounding the centralization of the NBCE Part IV examination. It surfaces again in conversations about the proposed merger between the National Board of Chiropractic Examiners and the Federation of Chiropractic Licensing Boards. It also appears in debates about expanding scope of practice to include drugs, injections, and other procedures historically outside the chiropractic paradigm.

In each case, the argument is framed in the same way: the profession must modernize.

But a closer look reveals something important.

In many instances, the changes described as modernization are not about modernization at all. They are about consolidating control.

“Real modernization expands choice, transparency, and competition. What we are seeing instead is deeper consolidation of power.”

The Oklahoma Example

Recent records obtained from the Oklahoma Board of Chiropractic Examiners provide a vivid example of how the modernization narrative operates.

The original issue was narrow. Oklahoma’s statute referenced graduation from an “accredited chiropractic college,” language that reflects older educational terminology. Today, chiropractic accreditation is programmatic rather than institutional.

That kind of wording problem can be solved easily.

But the discussion that followed quickly expanded beyond a technical statutory correction. Presentations circulated through the Federation of Chiropractic Licensing Boards identified Oklahoma as one of several states whose statutes needed to be changed. Emails show the head of the Council on Chiropractic Education helping draft the proposed language.

What began as a minor terminology update evolved into a proposal that would embed the accrediting body more firmly within state law.

That is not modernization. That is institutional entrenchment.

“A drafting fix became a vehicle for strengthening the position of the very organizations pushing for the change.”

The Pattern Across the Profession

The Oklahoma episode is not isolated. Similar patterns appear across several initiatives currently reshaping the profession.

The push to centralize the NBCE Part IV examination is described as a modernization of assessment standards. In reality, the proposal removes clinical testing from the chiropractic colleges themselves and transfers it to a national testing apparatus controlled by the same organization that administers the written examinations.

Likewise, the proposed merger between the National Board of Chiropractic Examiners and the Federation of Chiropractic Licensing Boards has been framed as a step toward efficiency and modernization of governance.

But combining the national testing authority with the federation that represents licensing boards would effectively consolidate two of the most powerful regulatory corporations in the profession under a single organizational structure.

It would merge the entities responsible for testing and regulatory coordination into a unified power center.

“When the organizations that design the examinations and the organizations that influence licensing boards become the same institution, the result is not modernization. It is concentration.”

Scope Expansion and the Language of Progress

The modernization narrative also appears in scope-of-practice debates.

Proposals to allow chiropractors to prescribe drugs, perform injections, or adopt other procedures borrowed from medical practice are frequently described as necessary steps for the profession to remain relevant in modern healthcare.

Some chiropractors support these changes. Others oppose them. That debate will likely continue.

But one point deserves attention.

Even if chiropractors ultimately decide to pursue those procedures, that discussion has nothing to do with the regulatory consolidation currently occurring in education, testing, accreditation, and licensure.

Scope-of-practice debates are about what chiropractors do in clinical practice.

The modernization initiatives emerging from the profession’s regulatory organizations are about who controls the gateways into the profession.

Those are two entirely different questions.

What Real Modernization Would Look Like

If modernization were truly the goal, the profession would likely be moving in a very different direction.

Real modernization would focus on removing barriers to entry and reducing monopoly structures, not strengthening them.

It would mean eliminating statutory language that grants exclusive authority to private corporations over licensure eligibility. It would mean allowing states to recognize multiple accreditation pathways rather than hard-coding a single accreditor into law. It would mean separating testing bodies from regulatory coordination organizations rather than merging them.

It would also mean addressing the financial architecture that currently sustains the chiropractic regulatory system.

Student loan debt finances the majority of chiropractic education in the United States. Those federal funds flow into institutions whose accreditation status determines eligibility for federal financial aid. Accreditation standards shape the structure of educational programs, which in turn determine eligibility for national examinations. Those examinations are required for licensure, which is overseen by state boards influenced by national regulatory organizations.

The result is an interconnected system that spans education, accreditation, testing, licensure, postgraduate certification programs, and continuing education approval systems.

Organizations such as CCE, NBCE, FCLB, the Recognized Chiropractic Specialty Program, and the PACE continuing education approval system occupy key positions throughout that pipeline.

“The same network that defines educational standards also influences testing, licensing, specialty certification, and continuing education.”

That is not modernization. It is vertical integration.

The Direction of State and Federal Reform

Ironically, the modernization rhetoric used by chiropractic’s national organizations is increasingly at odds with broader regulatory trends.

Across the country, governors and legislatures are examining how licensing structures can become overly dependent on private organizations.

States such as Oklahoma, Texas, and Montana have begun reviewing regulatory frameworks with an eye toward reducing barriers, improving transparency, and preventing regulatory capture.

Executive actions in several states now encourage licensing boards to remove unnecessary monopolies and avoid embedding private entities directly in statute.

At the federal level, accreditation itself is undergoing renewed scrutiny. Policymakers are exploring ways to allow alternative accrediting models, restore greater authority to states, and increase competition among accreditation bodies recognized by the U.S. Department of Education.

Even regional efforts are emerging in the southern United States to create new accreditation structures that expand institutional choice.

In other words, many parts of the regulatory world are moving toward decentralization and competition.

Meanwhile, the chiropractic profession’s leadership appears to be moving in the opposite direction.

“While regulators across the country are looking for ways to reduce monopolies, chiropractic’s national institutions are doubling down on them.”

The Real Question Facing the Profession

None of this means the profession should resist change. Healthcare evolves. Educational systems evolve. Licensing structures evolve.

But modernization should expand opportunity, transparency, and professional autonomy.

It should not concentrate authority in a small number of private organizations operating behind closed doors.

The question chiropractors and policymakers now face is not whether the profession should modernize.

The question is what kind of modernization is actually taking place.

Is the profession moving toward a more open system where states retain control over licensing standards and multiple institutions compete to provide education, assessment, and professional development?

Or is it moving toward a vertically integrated regulatory structure where the same small group of organizations controls every stage of the pipeline from student enrollment to continuing education?

Those two futures look very different.

Only one of them deserves to be called modernization.

For chiropractors who recognize the vitalistic roots of the profession, reflection on our philosophical foundations is not an academic exercise. It is a reminder of what chiropractic was intended to be and why it was deliberately constructed as something distinct from medicine.

Principled chiropractic, centered on the detection and correction of vertebral subluxation so that Innate Intelligence can express life through the nervous system, was never meant to be simply a technique or a therapeutic method. From the beginning it was a worldview, a system of thought, and a professional identity that separated chiropractic from the allopathic model of disease management.

Daniel David Palmer, the founder; Bartlett Joshua Palmer, the developer; and RW Stephenson, the systematizer of chiropractic philosophy, each contributed to building that identity. Their writings make it clear that chiropractic was not intended to blend with medicine, nor to evolve into a derivative of medical therapeutics. It was designed as a separate discipline grounded in principles that explained health in terms of life, organization, and the body’s innate capacity for self-regulation.

Yet preserving that vision requires more than admiration for the Green Books or reciting the 33 Principles. The preservation of chiropractic has always depended upon those willing to defend it. And today, the threats to chiropractic’s identity increasingly come from philosophical disagreement and institutional forces seeking control over chiropractic education, licensure, and the very definition of the profession itself.

D.D. Palmer: Establishing a Science Based on Cause, Not Effects

Daniel David Palmer (1845–1913) is remembered for the historic adjustment of Harvey Lillard in 1895, but his true contribution to chiropractic lies in the philosophical framework he articulated in the years that followed. Palmer did not view chiropractic as simply another healing method among many alternatives. Instead, he described it as a new science grounded in the relationship between the nervous system and the expression of life within the body.

Drawing on his experiences as a magnetic healer, Palmer developed the concept of tone, the normal tension within nerves that allows Innate Intelligence to coordinate the body’s functions. In his view, disturbances in this normal tone, produced by vertebral subluxations interfering with nerve transmission, were responsible for the conditions that medicine labeled disease.

Palmer defined chiropractic in unmistakable terms:

“The philosophy, art, and science of things natural; a system of adjusting the segments of the spinal column, by hand only, for the correction of the cause of dis-ease.”

This definition was intended to distinguish chiropractic from allopathic medicine at its most fundamental level. Medicine sought to treat disease by addressing symptoms and effects. Chiropractic, Palmer insisted, was concerned with correcting the cause of dis-ease by removing interference to the body’s innate regulatory mechanisms.

“There is a vast difference between treating effects and adjusting the cause.”
— D.D. Palmer

“Chiropractic is founded upon different principles than those of medicine.”
— D.D. Palmer

“Do not forget that chiropractors did not treat diseases. They adjust causes, whether acquired, spontaneous, or the result of accident.”
— D.D. Palmer

Palmer understood that language itself shaped professional identity. He cautioned chiropractors against adopting medical terminology such as “treat,” “manipulate,” or “operate,” warning that such language would inevitably lead the public, and eventually chiropractors themselves, to misunderstand the purpose of the profession.

His insistence on these distinctions was not theoretical. Chiropractic’s early history included intense legal battles over the right to practice, culminating in Palmer’s own imprisonment in 1907 for practicing without a medical license. The struggle to establish chiropractic as a distinct profession was fought in courtrooms, legislatures, and public debates long before it was ever debated in classrooms.

B.J. Palmer: Defending Chiropractic’s Identity

When Bartlett Joshua Palmer assumed leadership of the Palmer School of Chiropractic in 1902 at the age of twenty, the profession was still fragile and poorly understood. Over the following decades he transformed chiropractic from a small educational enterprise into a global movement.

Under B.J.’s leadership, the Palmer School grew into the largest chiropractic institution in the world. He authored dozens of volumes known collectively as the Green Books, pioneered the use of X-ray analysis in chiropractic, established the B.J. Palmer Research Clinic, and broadcast chiropractic philosophy across the country through his powerful radio station, WOC.

Equally important was B.J.’s role as chiropractic’s most outspoken defender. He recognized that the profession faced pressure not only from medicine but also from within. Many chiropractors sought to incorporate therapies, physiotherapeutic modalities, and medical concepts into their practices in an effort to gain legitimacy.

B.J. famously described this conflict as the struggle between “straights” and “mixers.”

Straights practiced chiropractic according to its foundational principles, focusing on the correction of vertebral subluxation. Mixers attempted to blend chiropractic with medical treatments and therapies, creating a hybrid that B.J. believed diluted the profession’s identity.

“Medicine is the study of disease and what causes man to die. Chiropractic is the study of health and what causes man to live.”
— B.J. Palmer

“Chiropractic is specific or it is nothing.”
— B.J. Palmer

“I am a Chiropractor working with the sciences of the universe by TURNING ON THE LIFE IN MAN through the art of the ADJUSTMENT. I do not prescribe, treat, or diagnose conditions… I AM A PRINCIPLED CHIROPRACTOR.”
— Attributed to B.J. Palmer

B.J. believed that once chiropractic surrendered its distinct principles, it would inevitably become subordinate to medicine. The profession would no longer stand on its own intellectual foundation but would instead function as a minor therapeutic specialty within a medical framework.

For B.J., preserving chiropractic meant preserving its identity as a unique system centered on the restoration of nervous system function and the expression of Innate Intelligence.

R.W. Stephenson: Organizing Chiropractic Philosophy

RW Stephenson provided chiropractic with the intellectual structure necessary to teach and defend its principles.

A graduate of the Palmer School in 1914 and later a faculty member, Stephenson synthesized the philosophical ideas of D.D. and B.J. Palmer into a deductive framework in his 1927 Chiropractic Textbook. That work, endorsed by B.J. Palmer in its foreword, presented chiropractic philosophy through the now famous 33 Principles.

Stephenson’s framework began with universal laws governing the organization of matter and progressed logically to the specific application of chiropractic adjustments. In doing so, he reinforced the profession’s vitalistic perspective, which held that life is governed by organizing intelligence rather than mechanical processes alone.

Among the central ideas contained in Stephenson’s principles were the concepts of Universal Intelligence, Innate Intelligence, and the role of vertebral subluxation in interfering with the body’s ability to coordinate its functions.

“The Major Premise: A Universal Intelligence is in all matter and continually gives to it all its properties and actions, thus maintaining it in existence.” (#1)

“The Causes of Dis-ease: Interference with the transmission of Innate forces causes incoordination or dis-ease.” (#30)

“Subluxations: Interference with transmission in the body is always directly or indirectly due to subluxations in the spinal column.” (#31)

Stephenson’s work ensured that chiropractic philosophy could be taught systematically rather than merely transmitted through anecdote or tradition. By organizing the profession’s principles into a coherent framework, he provided chiropractors with the intellectual tools necessary to defend their discipline.

The Modern Challenge: Control of the Profession

While debates about philosophy continue within the profession, the most consequential battles facing chiropractic today are fundamental philosophical disputes entwined with institutional struggles over control.

Across the United States and internationally, powerful organizations with a monopoly increasingly shape chiropractic education, testing, accreditation, and licensure. Accreditation bodies determine the standards chiropractic colleges must follow. National testing organizations control the examinations required for licensure. Regulatory entities influence how chiropractic is defined in statutes and practice acts.

These structures profoundly influence what chiropractic students are taught, how chiropractors are trained, and what chiropractors are legally permitted to do in practice.

If chiropractic education is governed by institutions and private corporations that reject or marginalize the profession’s foundational principles, future generations of chiropractors may graduate without ever encountering the ideas articulated by D.D. Palmer, B.J. Palmer, and R.W. Stephenson. Indeed this is happening today.

If licensure systems are structured in ways that reinforce a narrow medicalized version of chiropractic, the profession’s distinctive identity will continue to gradually disappear, not through open debate, but through quiet administrative changes.

Philosophy Alone Will Not Preserve Chiropractic

Within the profession there remains a tendency to treat philosophy as something to be admired rather than defended. Many chiropractors proudly display Green Books in their offices or quote B.J. Palmer in online discussions. They speak passionately about the principles of chiropractic.

Yet when the structural battles that determine the future of the profession arise, legislative fights, accreditation disputes, regulatory conflicts, many remain silent.

The contradiction is difficult to ignore. Chiropractors who claim to value the philosophy often do little to defend the institutional conditions necessary for that philosophy to survive. Some even justify their absence from these battles by claiming that politics is beneath them, or that involvement in legislative or regulatory issues somehow distracts from practicing “pure” chiropractic.

That view misunderstands the nature of philosophy itself.

Politics is not separate from philosophy. It is one of its practical expressions. Political systems reflect the values, principles, and assumptions about human life and society that people choose to organize themselves around. When chiropractors refuse to engage in the political and regulatory arenas that determine how chiropractic is defined, taught, and practiced, they are effectively allowing others to impose their philosophy on the profession.

The motivational speaker Jim Rohn captured the underlying reality succinctly:

“All values must be fought for and vigorously defended.”
— Jim Rohn

Values that are not defended eventually disappear. The same is true for professional principles.

D.D. Palmer defended chiropractic in the courts and ultimately went to jail for practicing it. B.J. Palmer spent decades building institutions and confronting opposition from both medicine and within the profession itself. Stephenson devoted his career to organizing and explaining the philosophical foundation of chiropractic.

They did not simply believe in chiropractic. They fought for it.

The Responsibility of Today’s Chiropractors

If the profession truly values the principles articulated by its founders, then those principles must be defended in the arenas where the future of chiropractic is being decided.

Protecting the freedom of chiropractic education is essential so that chiropractic colleges remain able to teach the philosophy, science, and art that define the profession. Defending fair and open licensure pathways ensures that chiropractors can practice according to chiropractic principles rather than conforming to a medicalized model imposed from outside.

Addressing regulatory capture and institutional consolidation is equally critical, because when a small number of private corporations gain control through monopoly over accreditation, testing, and licensure standards, they effectively determine the direction of the entire profession.

Philosophy matters. The Green Books matter. The 33 Principles matter.

But unless chiropractors are willing to defend the institutions and freedoms that allow those principles to be taught and practiced, the philosophy itself will gradually become little more than historical literature.

The pioneers of chiropractic did not establish this profession so that future generations could admire it from a distance.

They established it so that each generation would take responsibility for protecting it.

Understanding Corruption in Professional Governance

When discussions about corruption arise, many people immediately think of criminal conduct, bribery, or overt fraud. Yet corruption within professional governance systems rarely manifests in such obvious ways. In regulated professions, corruption more often takes the form of structural conflicts of interest, regulatory capture, institutional self-dealing, and the consolidation of authority within a closed network of organizations.

In these situations, the system itself begins to operate in a way that protects institutional power rather than serving the profession or the public.

“Corruption in professional regulation rarely appears as a crime. More often it appears as a structure.”

Within chiropractic, the convergence of several developments has exposed a governance structure that deserves serious scrutiny: the proposed merger between the National Board of Chiropractic Examiners (NBCE) and the Federation of Chiropractic Licensing Boards (FCLB), the centralization of the NBCE Part IV clinical examination, ongoing efforts to expand chiropractic scope to include drugs and injectable therapies, and a little-discussed but critically important policy within the Council on Chiropractic Education known as Policy 56.

The Architecture of Control

Three institutions occupy central positions in the governance of the chiropractic profession:

The Council on Chiropractic Education (CCE) accredits chiropractic colleges.
The National Board of Chiropractic Examiners (NBCE) administers the licensing examinations used by most state boards.
The Federation of Chiropractic Licensing Boards (FCLB) serves as the primary policy organization advising state regulators.

Individually, each organization performs a function that exists in many healthcare professions. The problem arises when their governance structures become interconnected and when policies create structural dependencies between them.

Over time, a tightly integrated ecosystem has emerged in which accreditation requirements, licensing examinations, and regulatory guidance reinforce one another in ways that concentrate authority within a small institutional network.

“When the same network influences accreditation, licensure, regulatory policy, and professional direction, the system ceases to function as an independent regulatory framework.”

Instead, it begins to resemble what legal scholars describe as regulatory capture by active market participants.

The Hidden Significance of CCE Policy 56

At the center of this structural relationship lies CCE Policy 56, a policy that has received surprisingly little public attention given its profound implications.

Policy 56 ties chiropractic educational accreditation to the taking and passing of NBCE examinations. While framed as a mechanism for ensuring student readiness for licensure, the policy effectively embeds NBCE examinations within the accreditation framework governing chiropractic colleges.

The practical result is that accredited institutions are placed in a position where alignment with the NBCE examination system becomes unavoidable.

“Policy 56 quietly links accreditation and licensure through a single examination vendor.”

This connection creates a powerful structural feedback loop:

Students must take NBCE examinations to obtain licensure.
Colleges must prepare students for those examinations to maintain accreditation expectations.
State boards rely on those examinations because they have become the universal credentialing standard.

The policy does not merely recognize NBCE exams as one possible pathway. It reinforces their position as the default national licensure standard embedded within accreditation itself.

The NBCE–FCLB Merger: A New Layer of Consolidation

The proposed merger between NBCE and FCLB threatens to deepen this structural consolidation.

NBCE generates revenue through the administration of licensing examinations. FCLB serves as the principal advisory body for state licensing boards and develops model regulatory policies.

If the two organizations merge, the entity responsible for selling the licensing examinations would also control the organization responsible for advising regulators on how those examinations should be used.

“The organization selling the exam would also control the body advising regulators to require the exam.”

In such a system, the separation between examination vendor and regulatory policy advisor effectively disappears.

CCE Policy 56 would remain in place after the merger, meaning the accreditation system would continue to reinforce the same examination structure while regulatory policy becomes further integrated with the exam vendor itself.

The result would be an unprecedented level of institutional alignment across accreditation, licensure testing, and regulatory guidance.

Part IV Centralization and the Economics of Licensure

The push to centralize the NBCE Part IV clinical examination must be understood within this broader governance context.

Historically, chiropractic colleges played a meaningful role in assessing student clinical competency. Centralization shifts that authority away from educational institutions and consolidates it within the national examination system.

Centralization therefore does more than standardize testing procedures. It strengthens the institutional role of the NBCE within the licensing process while weakening the autonomy of chiropractic educational institutions.

“Centralizing clinical competency evaluation within a single examination vendor increases both structural dependency and financial concentration.”

Students, meanwhile, bear the financial burden of these examinations, paying thousands of dollars in testing fees throughout their educational careers.

What makes this development particularly notable is that other major healthcare professions have moved in the opposite direction. Both medical doctors and osteopathic physicians once utilized high-stakes national clinical skills examinations similar to chiropractic’s Part IV. In recent years, however, both professions eliminated those exams after determining that the cost, logistical burden, and limited additional value did not justify their continuation. Clinical competency is now assessed primarily within the educational environment of accredited medical schools and residency programs.

“While chiropractic leadership is moving to expand and centralize its clinical licensing exam, medicine has already concluded that such exams are unnecessary.”

When licensing examinations become economically central to the regulatory system, incentives inevitably emerge that encourage expansion rather than restraint.

Scope Expansion and the Pharmaceutical Question

At the same time that governance consolidation is occurring, certain segments of the profession are aggressively promoting expansion of chiropractic scope of practice to include pharmaceuticals and injectable therapies.

These proposals are often framed as necessary modernization that will allow chiropractors to compete with other healthcare providers.

Yet scope expansion cannot be considered independently of governance structures.

If pharmaceutical competencies become part of chiropractic practice, new educational standards, examinations, and certification mechanisms will inevitably follow. The question then becomes: who will control those standards and examinations?

“Whoever controls the examinations ultimately controls the profession.”

In a system already dominated by a tightly interconnected institutional network, the addition of pharmaceutical competencies could further expand the authority of the same organizations that currently control licensure and accreditation pathways.

The Risk of Institutional Self-Preservation

None of these developments necessarily imply that individuals involved in these organizations are acting with malicious intent. Institutional actors frequently believe they are advancing the best interests of the profession.

Yet governance systems must be evaluated not only by the intentions of their leaders but by the incentives created by their structure.

Organizations that depend on examination revenue, regulatory authority, or expanded jurisdiction naturally develop incentives to protect and expand those functions.

Over time, these incentives can reshape the regulatory landscape.

“When institutional survival becomes the primary incentive, structural integrity becomes the first casualty.”

This dynamic is well documented in regulatory theory, where it is known as institutional self-preservation.

A Profession at a Governance Crossroads

The chiropractic profession now stands at an important crossroads.

CCE Policy 56 has already created a structural bridge between accreditation and a single national examination system. The proposed NBCE–FCLB merger threatens to extend that bridge into regulatory policy itself. The centralization of Part IV strengthens the economic and operational authority of the exam vendor, while scope expansion proposals introduce additional layers of regulatory control that may be administered through the same institutional network.

Taken together, these developments represent a profound shift in how power is distributed within the profession.

“Professional independence is not lost overnight. It erodes gradually as authority becomes concentrated within fewer institutions.”

The core question facing chiropractic today is therefore not simply about exams, mergers, or scope of practice. It is about governance.

Will chiropractic remain a profession characterized by distributed authority, institutional diversity, and open debate? Or will it evolve into a system where accreditation, licensure, regulatory policy, and professional direction are controlled by a single interconnected structure?

The answer will determine not only the future of chiropractic governance, but the long-term credibility of the profession itself.

When James Mason, DC rose to speak at commencement at Palmer College of Chiropractic on February 27, 2026, he did not deliver the kind of speech audiences typically expect on graduation day. There were no lighthearted stories about exams or sleepless nights. Instead, he spoke with urgency about the future of chiropractic and the responsibility resting on his generation’s shoulders.

His message was clear: the greatest threat to chiropractic is not external opposition, but internal division.

“Our beloved profession… is under attack, not from the outside, but from within.”

Dr. Mason described a profession divided between two fundamentally different visions. One sees chiropractic as an adjunct within the medical system, focused largely on symptom management and integration. The other sees it as a distinct discipline centered on the analysis and correction of vertebral subluxation, grounded in principles articulated by its founders.

Whether one agrees with his framing or not, the clarity of his conviction is undeniable.

CLICK HERE to listen to his speech

A Voice From the Front Lines of Education

Students are often described as the future of the profession. What is less often acknowledged is that they are also present-day stakeholders. They commit years of their lives and assume significant financial burden based on their understanding of what chiropractic is and what it will be.

Dr. Mason’s speech reflected a frustration that many students quietly share: confusion about identity. In one classroom exercise, he noted, students were asked a simple question: What is chiropractic? The wide range of answers revealed something troubling. A profession cannot thrive if it cannot clearly define itself.

“No profession can survive if there’s 150 different answers on what it is we do.”

This is not merely a philosophical concern. Identity shapes curriculum, examination standards, public perception, and legislative direction. When those foundations shift without broad agreement, tension follows.

Leadership and Listening

For decades, influential organizations and regulatory bodies have advanced policies aimed at integration, expanded scope, and alignment with mainstream healthcare models. Many leaders view these efforts as pragmatic and necessary for long-term viability.

But Dr. Mason’s speech suggests that a significant portion of the emerging generation sees those same efforts as dilution rather than advancement.

This raises an important question: how often are students meaningfully included in conversations about the direction of the profession? When policies are developed that will define their careers for the next forty years, are their perspectives sought, or assumed?

When students showed up at the headquarters of the National Board of Chiropractic examiners with questions about Part IV centralization Norman Ouzts refused to speak with them citing “safety and security concerns”

CLICK HERE for that story

“Chiropractic is the analysis of the spine for vertebral subluxations and the correction of those vertebral subluxations so that the body’s innate intelligence may express itself wholly through the nervous system. Nothing more and nothing less.”

For Dr. Mason, the issue is not nostalgia. It is definition. If chiropractic becomes indistinguishable from adjacent professions, what remains uniquely its own?

A Generational Reality

There is an unavoidable truth at play. The leaders shaping accreditation standards, licensure requirements, and national policy today will not be practicing decades from now. Dr. Mason and his classmates will.

That reality does not diminish the experience or contributions of current leadership who really are servants of the future. It does, however, underscore the importance of intergenerational dialogue. A profession cannot remain healthy if its future stewards feel unheard.

Dr. Mason concluded by urging his classmates to master their craft, engage in governance, and defend what they believe chiropractic to be.

“This profession will not be saved by silence… and it will not survive by compromise.”

His words were not delivered in anger, but in conviction. They reflect a generation that is not apathetic, not disengaged, and not indifferent.

If leadership chooses to dismiss that voice, it does so at its own peril. If it chooses to listen, there is still an opportunity for clarity, alignment, and renewal.

The speech was more than a commencement address. It was a reminder that the future of chiropractic is not an abstract concept. It is already seated in the audience, waiting to inherit what today’s leaders choose to pass on.

On February 10, 2026, the American College of Physicians published a policy paper in the Annals of Internal Medicinetitled “Physicians Are Not Providers: The Ethical Significance of Names in Health Care.” The paper is more than a semantic debate. It is a reflection on what happens to a profession when its language begins to mirror the marketplace rather than its mission.

The ACP argues that calling physicians “providers” is not merely imprecise. It signals a shift in how medicine understands itself. The term flattens distinctions in training and responsibility, reduces the patient-physician relationship to a transactional exchange, and reinforces the corporate vocabulary of managed care. In doing so, it subtly reshapes expectations about loyalty, authority, and professional duty.

“Referring to physicians as ‘providers’ contributes to the commercialization and deprofessionalization of medicine.”

For medicine, this is a moment of self-examination. For chiropractic, it should be as well.

The Language of Commerce and the Erosion of Professional Identity

The ACP Ethics, Professionalism and Human Rights Committee traces the rise of the term “provider” to the growth of corporate health care systems and insurer-driven policy language. In that environment, clinicians become interchangeable units within networks, accountable primarily to reimbursement structures and utilization metrics. Words such as “covered lives” and “patient leakage” follow naturally from that worldview. When human beings are described in actuarial terms, care begins to look like a commodity.

“The term ‘provider’ lacks precision and transparency for patients.”

The ACP is effectively reclaiming the word “physician” as a boundary marker. It is asserting that professional identity carries ethical obligations that cannot be collapsed into generic terminology without consequence.

Chiropractors should pay close attention to this move, because for years many within our profession have been pressing in the opposite direction.

The Chiropractic Pursuit of Primary Care Status

Within chiropractic, there has been a sustained effort to secure recognition as “primary care physicians” or “primary care providers.” The motivation is understandable. The label promises cultural authority, parity in policy discussions, inclusion in federal programs, and expanded access within insurance systems. It appears to be a path toward legitimacy in the broader health care hierarchy.

Yet the ACP paper forces us to ask whether that hierarchy is worth emulating.

Primary care in contemporary health care is not a realm of autonomy and prestige. It is the most administratively burdened sector of medicine. Primary care physicians coordinate referrals, manage chronic disease across multiple systems, absorb extensive liability, and serve as the first line of responsibility for complex patient populations. At the same time, they are often the least compensated physicians in the medical structure relative to their breadth of obligation.

“Primary care providers are the least paid and carry the greatest responsibility in the health care system.”

This is not a criticism of primary care physicians. It is a recognition of structural reality. The question for chiropractic is whether striving to be absorbed into that structure strengthens or weakens our professional identity.

Inclusion or Absorption?

There is a powerful psychological pull in being recognized as part of the mainstream. When chiropractors refer to themselves as primary care providers, the language signals equivalence. It suggests equal standing in the health care ecosystem. It promises a seat at the table.

But language does not merely reflect identity; it shapes it. When a profession adopts the terminology of a system, it also begins to accept that system’s assumptions. The more chiropractic defines itself within the primary care framework, the more it aligns with disease management models, pharmaceutical authority debates, and bureaucratic reimbursement structures.

“When you adopt the language of the system, you adopt the assumptions of the system.”

This is precisely the dynamic the ACP is resisting within medicine. It recognizes that commercialization does not only occur through policy; it begins with vocabulary.

If calling physicians “providers” erodes their professional distinctiveness, what happens when chiropractors voluntarily position themselves under the same label?

The Specialist Alternative

Historically, chiropractic has not been organized around broad disease management or pharmaceutical oversight. Its distinctive contribution has centered on the analysis and correction of vertebral subluxation and the restoration of neurological integrity. Whether one frames this philosophically or biomechanically, the model is specific rather than generalist.

Specialists in any field derive authority from clarity. Their value lies in depth, not breadth. They are consulted precisely because their focus is narrower and more refined than that of a generalist. In most health care systems, specialists command higher compensation, clearer referral pathways, and stronger identity cohesion because their role is sharply defined.

“Specialists command value because they are focused.”

If chiropractic abandons that focus in pursuit of primary care designation, it risks becoming a diluted generalist competing in a space already saturated with practitioners whose training pathways and regulatory authority are deeply entrenched.

The ACP is drawing a line to protect medicine’s professional integrity. Chiropractic must decide whether its future lies in imitation or differentiation.

The Cost of Borrowed Titles

There is an understandable belief that adopting the title of primary care physician elevates chiropractic’s status. Yet borrowed titles often come with borrowed constraints. Federal definitions, insurer regulations, scope debates, and administrative oversight accompany the recognition many seek. With those constraints comes increasing pressure to conform to prevailing medical paradigms.

“A profession without a clear boundary becomes indistinguishable from the system that absorbs it.”

The irony is that in seeking cultural authority through inclusion, chiropractic may undermine the very distinctiveness that gives it value. If everything becomes primary care, nothing remains unique.

The ACP’s policy paper is a reminder that professional language is not cosmetic. It is structural. Medicine is attempting to reclaim its identity from commercial terminology that blurs responsibility and erodes ethical clarity. Chiropractic should take the opportunity to reflect on its own trajectory.

“In the pursuit of recognition, we must not abandon distinction.”

Chiropractors must ask whether the path to long-term strength lies in chasing primary care recognition or in confidently defining themselves as specialists in the correction of vertebral subluxation. One path seeks validation from an existing system. The other builds authority from internal coherence.

The ACP has decided that words matter. Chiropractic should reach the same conclusion, and choose its words, and its identity, with care.

A Polished Message That Explains Everything Except the Cause and the Solution

Dr. Joe Betz’s recent video message to ICA members is rhetorically polished, emotionally resonant, and structurally empty. It correctly describes the symptoms of a profession under strain, declining enrollment, rising costs, regulatory confusion, identity drift, and institutional instability, but it never once confronts the causes of those conditions. And because it avoids the causes, it also avoids the solutions.

This omission is not accidental. It is the defining feature of the message.

What Betz delivers is not an analysis of why chiropractic finds itself at a crossroads, but a carefully managed narrative designed to reassure members that the ICA is “at all the tables” and “in all the rooms” while the profession continues to deteriorate under cartel control, regulatory capture, and monopolized education and testing systems.

What Betz Gets Right: The Profession Is in Trouble

To his credit, Betz accurately outlines many of the pressures facing chiropractic today.

He notes declining chiropractic college enrollment despite rising public demand for non pharmaceutical care. He acknowledges escalating tuition, student debt, reimbursement compression, regulatory complexity, scope confusion, and uncertainty around accreditation and student loans. He recognizes that the profession is being pulled between maintaining its distinct identity and dissolving into a generic musculoskeletal service line inside a pharmaceutical driven healthcare system.

These observations are not wrong.

But they are also not new. The Chiropractic Freedom Coalition, independent state associations, researchers, educators, and dissident members inside the ICA have been warning about these exact dynamics for years.

The question is not whether these problems exist. The question is why they exist.

The Missing Diagnosis: Regulatory Capture and Monopolies

What Betz never says, and what his entire message is structured to avoid, is the central truth facing chiropractic:

The profession is not struggling because it lacks vision. It is struggling because it is structurally captured.

Chiropractic education, accreditation, testing, licensure, and regulation are controlled by a closed loop cartel of monopolistic institutions that suppress innovation, limit competition, and punish deviation from approved ideology.

That cartel, which includes accrediting bodies, testing organizations, regulatory boards, and aligned trade groups, has made chiropractic education more expensive, less flexible, less attractive to students, and less capable of competing in a modern healthcare education marketplace.

By refusing to name regulatory capture, Betz also refuses to confront the monopolies that drive tuition inflation, restrict educational diversity, enforce ideological conformity, and block new delivery models that could actually reverse enrollment decline.

Avoiding the Cause Means Avoiding the Solution

Because Betz never names the cartel, he never proposes dismantling it.

There is no call for:

• Competition in accreditation

• Alternatives to centralized testing monopolies

• Educational innovation outside cartel-approved models

• Structural reform of licensure gatekeeping

• Antitrust scrutiny or legal challenge

Instead, the solution offered is the same one ICA leadership has repeated for years.

Be at the table. Be in the room. Trust us, we are there.

“At All the Tables” While Everything Gets Worse

Betz repeatedly emphasizes that the ICA is “at all the tables where ideas are discussed and decisions are made.” This phrase is presented as reassurance, proof of relevance, and justification for continued support.

But it raises a devastating question that the video never addresses.

If the ICA has been at all the tables, in all the rooms, for years, then why is chiropractic in this condition?

• Why are enrollments down?

• Why are costs up?

• Why is identity weaker, not stronger?

• Why is scope increasingly medicalized?

• Why are students voting with their feet?

Perhaps they will argue it would be worse if they were not there.

Presence without power is not leadership. Access without outcomes is not influence.

Being “in the room” and “at the table” has become a substitute for results, and worse, a shield against accountability.

Values Language as Governance Cover

Betz anchors his message in ICA’s stated values, including respect, equitability, empowerment, collaboration, and transparency. These words sound reassuring, but in modern governance they often function very differently than members assume.

Take equitability.

Equitability does not mean equal voice. It means outcome managed fairness, where leadership decides who gets influence, access, or representation based on what they believe serves the organization’s goals.

In practice, equitability often justifies:

• Reduced member voting power

• Governance committee dominance

• Unelected decision making

• Suppression of dissent framed as “disruptive”

When equitability replaces equality, democracy quietly disappears.

This helps explain why ICA leadership can speak at length about transparency while turning off comments on videos, censoring member forums, and centralizing control inside governance structures that members cannot meaningfully challenge.

The Silence on Governance, Elections, and Accountability

Perhaps the most telling omission in Betz’s video is what he does not mention at all.

There is no reference to:

• The Georgia election interference and fraud allegations

• The governance committee’s expanding power

• The CEO appointment controversy

• Conflicts of interest involving ICA leadership

• Member and leader resignations

• Affiliate withdrawals

Betz’s video comes on the heels of one of the most significant resignations from ICA leadership - that of Brian Moriarity DC long time ICA Board member, ICA Treasurer and current President of the Florida Chiropractic Society (a state affiliate of the ICA).

CLICK HERE for more on that story

These are not peripheral issues. They are the reason the ICA is hemorrhaging trust.

By framing the crisis as external complexity rather than internal failure, Betz absolves ICA leadership of responsibility and reframes dissent as misunderstanding rather than legitimate concern.

The Seat at the Table Fallacy

The core flaw in Betz’s message is philosophical.

It assumes that being present inside cartel controlled institutions will somehow reform them from within. This “seat at the table” theory has been tested for decades in chiropractic.

It has failed. Not just failed but utterly failed.

The cartel did not loosen its grip. Accreditation did not diversify. Testing did not decentralize. Education did not become more affordable. Innovation did not accelerate.

What changed instead was chiropractic itself, slowly reshaped to fit the cartel’s preferences. Being in the room did not protect the profession. It normalized its erosion.

“Oh, the ICA is in the room so everything must be okay”

Clarity Without Courage Is Not Leadership

Dr. Betz is correct about one thing.

Demand is not the problem. Direction is. But direction will never change as long as ICA leadership refuses to name the forces steering the ship, refuses to confront regulatory capture, and refuses to challenge the monopolies strangling chiropractic education and practice.

A message that diagnoses everything except the disease is not leadership.

It is management of decline.

Until the ICA is willing to stop celebrating its proximity to power and start challenging the structures that abuse it, no amount of polished rhetoric, values language, or vision statements will reverse the profession’s trajectory.

If you have truly been at all the tables, and chiropractic is still in this condition, then the problem is not access.

The problem is complicity.

The Way Forward, and the Question That Will Not Go Away

There is a path out of this crisis, and it does not run through more closed door meetings, more symbolic seats at cartel tables, or more platitudes about being “in the room.” The solution is structural, not rhetorical. It runs through the work of the Chiropractic Freedom Coalition and the over 60 allied organizations that are confronting restraint of trade head on, challenging monopolized accreditation, testing, and licensure systems, and restoring a free and competitive marketplace in chiropractic education and practice.

Freedom, innovation, affordability, and philosophical diversity do not emerge from managed consensus, they emerge from open competition and accountable governance. Ending regulatory capture is not a threat to chiropractic, it is the only way to save it no matter what “side” you are on. Which leads to the question that now sits squarely before the profession, and especially before ICA leadership, if this is the solution, if it restores freedom, lowers barriers, invites innovation, and protects chiropractic’s core principles, why is the ICA opposed to it, Dr. Betz?

For too long, parents of children with autism have been dismissed, silenced, and treated as though our lived experience means nothing. We’ve watched our children regress, struggle, and suffer while the medical-pharmaceutical establishment insists that nothing is wrong with the system, and that we should simply accept autism as a random, genetic inevitability.

No more.

With Robert F. Kennedy Jr.’s bold overhaul of the Interagency Autism Coordinating Committee (IACC), parents and caregivers finally have real representation at the table.

The Old Guard Failed Us

For years, the IACC was dominated by academics, bureaucrats, and researchers with deep ties to the pharmaceutical industry. The committee focused almost exclusively on genetics, despite the explosion in autism rates from 1 in 10,000 in the 1970s to 1 in 36 today, while refusing to seriously investigate environmental triggers, including the dramatic increase in childhood medical interventions.

“We’ve been told to shut up and accept that our children’s injuries don’t matter. We’ve been called anti-science for daring to ask questions. Enough is enough.”

Parents who watched perfectly healthy toddlers lose speech, eye contact, and bowel function after routine interventions were dismissed as “hysterical” or “misinformed.” Support services were underfunded. Early intervention was gatekept. Any discussion of recovery or biomedical treatment was branded pseudoscience.

Meanwhile, autism quietly became a lifelong profit center, and the pharmaceutical industry continued to rake in billions.

A Committee That Actually Listens to Families

On January 28, 2026, Secretary Kennedy appointed 21 new public members to the IACC, many of them parents who have lived this reality, alongside physicians who actually treat affected children and autistic individuals who communicate in their own ways.

This is historic.

For the first time, the committee includes:

• Parents who navigate the daily realities of severe autism

• Clinicians practicing integrative and functional approaches

• Advocates who refused to stop asking hard questions

• Non-speaking autistic individuals offering authentic lived experience

These are not distant experts theorizing from ivory towers. These are people who change diapers, manage meltdowns, fight for school accommodations, and stay up all night searching for ways to help their children heal.

“This isn’t about politics. This is about finally having a government that listens to mothers and fathers who have been screamed down for decades.”

The Outrage Reveals How Threatened They Are

The backlash from the old guard was immediate and vicious.

Mainstream media outlets and pharma-funded advocacy groups rushed to label the new members “anti-vaccine” and “unqualified.” The response revealed fear, not concern, because parents asking real questions threaten a narrative that has protected liability-free profits for decades.

When parents and doctors who actually treat autism are labeled “dangerous,” while researchers who have never sat with a severely affected child dictate national policy, that isn’t science.

That’s control.

What Comes Next: Real Answers, Real Help

The reconstituted IACC has committed to transparency, public input, and rigorous investigation into all plausible contributors, including environmental toxins, metabolic dysfunction, immune dysregulation, and the possible role of medical interventions.

For the first time, recovery will be discussed alongside acceptance.

Services, supports, and treatments that families have found helpful will no longer be dismissed out of hand, they will be studied seriously.

“We don’t need more genetic dead ends. We need answers that help our children speak, toilet, learn, and live fuller lives.”

To every parent who has felt alone, gaslit, or exhausted, your voice matters. Your experience matters. Your children matter.

This committee is just the beginning.

We are not going back to silence.

For more than a century, chiropractic held a strategic position no other health profession could legitimately claim: the focused identification, reduction, and correction of vertebral subluxations as a central determinant of human health. That position was not merely philosophical. It offered a coherent biological model, a preventive framework, and a salutogenic orientation aligned with nervous system integrity and adaptive capacity.

And yet, modern chiropractic has steadily walked away from that advantage.

In its place, the profession has tried to compete on ground already occupied by physical therapy, pain management, and rehabilitation medicine, namely, short-term neck and back pain relief delivered through manual therapy. Two recent papers, one examining how physical therapists conceptualize manual therapy, and the other evaluating its effectiveness for chronic low back pain, unintentionally expose just how costly that trade has been.

Chiropractic did not lose ground because its central idea failed.
It lost ground because it abandoned the very thing no one else could offer.

Manual Therapy Has Become Everyone’s Game

The 2025 paper Perceptions and beliefs of physical therapists regarding the mechanisms of manual therapy offers a revealing snapshot of how physical therapists now understand hands-on care. Surveying nearly 600 clinicians in Germany, the authors found that contemporary physical therapy has largely abandoned biomechanical explanations in favor of neurophysiological ones.

Manual therapy, in this view, works not because it corrects structural or segmental dysfunction, but because it modulates pain perception, activates endogenous pain inhibition, engages the brain, and leverages contextual and placebo effects.

The brain was rated as the most important anatomical structure involved. Placebo effects ranked almost as high as endogenous pain modulation. Cervical joints, the very structures chiropractors historically emphasized, were considered secondary.

Manual therapy is no longer about correcting anything.
It is about influencing perception.

From a physical therapy standpoint, this evolution makes sense. PT has no historical claim to vertebral subluxation, no professional obligation to explain health beyond pain and function, and no need to articulate long-term biological adaptation. Pain modulation is sufficient. Short-term improvement is success.

But here is the problem for chiropractic.

This is now exactly the same terrain chiropractic has chosen to fight on.

The Outcomes Reflect the Framework

The 2026 umbrella review The effectiveness of manual therapy in people with chronic non-specific low back painconfirms what decades of outcomes research have already suggested. Manual therapy, broadly defined to include spinal manipulation, mobilization, massage, and myofascial techniques, produces modest, short-term improvements in pain and disability.

On a 100-point pain scale, average improvements hover around 10 points in the short term. Disability scores show moderate short-term changes. By the medium and long term, those effects largely disappear.

This pattern is not unique to manual therapy. It mirrors the broader chronic low back pain literature almost perfectly.

When the goal is symptom suppression,
symptom recurrence should not be surprising.

The authors are careful and methodical. They note high heterogeneity, low certainty of evidence, and significant risk of bias across the included reviews. They call for better trials, longer follow-up, and standardized protocols.

But the deeper issue is not methodological. It is conceptual.

Manual therapy aimed at pain modulation can only deliver pain-modulation outcomes.

Chiropractic’s Strategic Error

When chiropractic reframed itself primarily as a treatment for neck and back pain, it accepted several constraints that were never inherent to the profession.

First, it accepted pain as the primary outcome of interest, marginalizing broader health effects by definition. Second, it accepted short-term improvement as success, even when long-term change was absent. Third, it entered a crowded marketplace where physical therapy, massage, acupuncture, and pharmacologic care already dominated guidelines, reimbursement structures, and institutional legitimacy.

In doing so, chiropractic voluntarily surrendered its differentiation.

You cannot out-compete another profession
by becoming a less-established version of it.

The research now routinely used to “support chiropractic” is the same research used to justify physical therapy, and it produces the same underwhelming conclusions. Manual therapy helps, a little, for a while. Then it doesn’t.

Those limitations are then attributed to chiropractic itself, rather than to the narrow framework it adopted.

What the Research Does Not Measure

What is striking in both papers is not what they find, but what they never attempt to study.

Neither paper meaningfully addresses vertebral subluxation as a biological phenomenon. Neither evaluates nervous system integrity beyond pain pathways. Neither explores immune modulation, adaptive capacity, developmental outcomes, or long-term health trajectories.

This absence is not accidental. Those outcomes only make sense if vertebral subluxation is taken seriously as a public-health problem rather than dismissed as an outdated metaphor.

And yet, a growing body of basic science, clinical observation, and epidemiologic research suggests that vertebral subluxation, understood as a state of altered neurobiomechanical integrity with systemic consequences, has implications far beyond pain.

Pain is not the problem.
It is the signal.

By fixating on the signal, the profession abandoned the system.

Salutogenesis Was the Missed Opportunity

Chiropractic’s original contribution was not symptom relief. It was a salutogenic model centered on nervous system organization, adaptability, and resilience.

Reducing vertebral subluxations was never about chasing pain scores. It was about restoring communication, improving regulation, and supporting the body’s capacity to heal and adapt over time. That orientation aligns naturally with immune function, stress physiology, developmental health, and chronic disease prevention.

Ironically, modern health care is now rediscovering these ideas under different names, resilience, adaptability, neuroimmune regulation, while chiropractic struggles to justify itself using pain outcomes it was never designed to optimize.

The profession did not fail to prove its value. It failed to measure the right thing.

The Way Forward Is Not Backward

Reclaiming chiropractic’s strategic advantage does not mean rejecting evidence or romanticizing the past. It means aligning research questions with the profession’s unique clinical intent.

As long as chiropractic defines itself as manual therapy for pain, it will be judged by pain outcomes, and it will continue to look average at best. As soon as it reasserts vertebral subluxation reduction as a central public-health intervention, the research agenda necessarily changes.

Different outcomes. Different timelines. Different relevance.

And, crucially, a different competitive landscape.

No other profession is positioned to do this work. Chiropractic simply has to decide whether it still wants to.

For decades, chiropractors have been told they belong to a profession rooted in freedom, innovation, and independence. Many embrace that identity wholeheartedly. Yet at the same time, the profession continues to defend regulatory structures that quietly undermine all three. That contradiction did not happen by accident. It was learned, reinforced, and normalized over time.

To understand why chiropractic often feels constrained, stagnant in key areas, and increasingly marginalized, it is necessary to step back and speak plainly about monopolies, cartels, and how they operate within professional regulation. This is not abstract economics or political theory. It is the lived reality of chiropractic education, testing, licensure, and governance.

What a Monopoly Actually Is

A monopoly exists when a single organization controls access to a market and blocks meaningful competition. This control does not arise because the organization is necessarily the best option or because consumers freely chose it, but because alternatives are excluded by law, rule, or institutional force. In healthy systems, ideas compete, innovation is rewarded, and choice exists. In monopolies, rules replace innovation, compliance replaces creativity, and power replaces accountability.

What is often missed in these conversations is that monopolies do not have to be government agencies. Some of the most powerful and harmful monopolies are private organizations whose authority is enforced by the state. When regulatory power is delegated in this way, those organizations gain extraordinary influence while remaining largely insulated from accountability. History shows that systems built on this model rarely serve the professions they claim to protect.

Why Monopolies Suppress Innovation and Freedom

Monopolies behave very differently from organizations operating in competitive environments. They do not need to improve, listen, or adapt because they are shielded from consequences. When students are required to pass through the same gate to graduate, test, license, and practice, that gatekeeper becomes insulated from feedback and correction. Over time, educational models stagnate, standards become rigid and uniform, dissent is discouraged, and innovators are treated as threats rather than contributors.

Eventually, regulatory capture takes hold. This occurs when the system being regulated begins serving the regulator instead of the profession or the public. This pattern is not unique to chiropractic. It is a predictable outcome of monopoly control across industries. However, chiropractic does not stop at monopoly. It moves further into a more complex structure.

From Monopoly to Cartel

A cartel is more sophisticated than a monopoly. Rather than a single organization acting alone, a cartel consists of a network of organizations that coordinate control while appearing independent. Each entity plays a distinct role, but together they reinforce one another’s authority, align policies, share leadership or incentives, and eliminate alternative pathways. Cartels thrive on complexity and confusion. They depend on professionals being too busy, too conditioned, or too fatigued to question how the system actually works.

This is why phrases like “this is just how it works” or “there is no alternative” are so common. These statements do not reflect professionalism or consensus. They reflect managed dependency. Once this framework is understood, the structure of chiropractic regulation looks very different.

The Closed Loop in Chiropractic

Chiropractic is often described as having three separate systems: accreditation, testing, and licensure. On paper, these systems appear independent. In practice, they function as a closed loop. Accreditation determines eligibility for testing, testing determines eligibility for licensure, and licensure rules then reinforce the same accreditation requirements. A small group of organizations dominates all three functions.

When one accreditor controls access to education, one testing body controls graduation and licensure eligibility, and state boards defer responsibility rather than exercising independent judgment, the profession ceases to be governed primarily by outcomes or public interest. Instead, it becomes a self-reinforcing system that resists change. Closed-loop systems do not evolve. They contract.

The Misuse of “Standards” as a Defense

Whenever these structures are questioned, a familiar defense appears: the claim that strict monopoly control is necessary to protect the public through standards. While this argument sounds responsible, it hides an important distinction. Standards are not the problem. Monopoly control is.

Standards can and do exist without monopolies. In many professions, they function better that way. Medicine operates with multiple accreditors. Law is actively moving away from a single accrediting authority. Engineering, accounting, and higher education operate under pluralistic oversight. Competition does not lower standards. It raises them by exposing bad actors, allowing strong models to spread, and making innovation visible. Monopolies do not primarily protect the public. They protect themselves.

What This System Has Cost Chiropractic

The costs of this structure are substantial and ongoing. Chiropractic has lost educational diversity, philosophical breadth, scientific exploration, institutional courage, and long-term sustainability. It has contributed to declining student enrollment, rising debt burdens, narrowing scope debates, and increasing external hostility.

The most damaging cost, however, is cultural. The profession has been conditioned to equate obedience with legitimacy. Professions that confuse obedience with legitimacy eventually lose credibility, relevance, and public trust.

Why This Moment Matters

Across the United States, professional regulation and higher education are being reexamined. Antitrust law is receiving renewed attention. Regulatory capture is being openly discussed. The delegation of authority to private monopolies is being challenged. Chiropractic is not outside this moment. It is at the center of it and may be one of the clearest examples of why reform is necessary.

Boards, educators, and practitioners are now facing a choice, whether they consciously acknowledge it or not. They can defend monopolies because they are familiar, or they can defend freedom, innovation, and accountability because they are essential.

The Bottom Line

This conversation is not about tearing chiropractic down. It is about removing the restraints that have prevented it from growing. Innovation requires competition. Freedom requires choice. Integrity requires accountability. Professional regulation that functions like a cartel is not regulation. It is control.

The future of chiropractic depends on whether the profession is willing to confront that reality.

Response to Karlos Boghosian’s arguments regarding the proposed NBCE–FCLB consolidation.

During the NBCE–FCLB Town Hall, Karlos Boghosian attempted to neutralize concerns about the proposed consolidation by invoking a familiar refrain: that other licensed professions already operate under similar arrangements, and that chiropractic is simply catching up to an established and uncontroversial model.

CLICK HERE for more on the “Town Hall”

Physical therapy, nursing, psychology, massage therapy, and social work were offered as examples, with the clear implication that questioning this merger reflects misunderstanding rather than due diligence. That framing is strategically important because it shifts the burden of proof away from those advocating for consolidation and onto those raising legal, regulatory, and structural concerns.

A Maneuver, Not an Analysis

Before that premise is accepted, however, it must be examined carefully. The professions cited operate under materially different accreditation, licensure, and governance frameworks, and none replicate the tightly coupled system now being constructed for chiropractic. Boghosian’s reliance on “other professions” is not a serious argument, it is a conversational maneuver. It is designed to create the impression that the question has already been answered elsewhere and that anyone who continues to ask it is wasting everyone’s time.

Naming other professions is not analysis, and it certainly is not a substitute for justifying a radical restructuring of chiropractic’s governance, testing, and regulatory ecosystem on its own terms.

The Problem of False Equivalency

The first and most fundamental problem is that Boghosian never establishes why comparisons to other professions should carry any weight at all. He simply asserts that because other professions have federations of boards that administer national exams and promote regulatory uniformity, chiropractic should accept the same model without further scrutiny.

That is not how law, governance, or public accountability work. Each profession exists within its own statutory framework, accreditation environment, historical context, and market structure. The legality and propriety of one arrangement in one profession says nothing, by itself, about the legality or prudence of a different arrangement in another.

The “Three-Layer Lock”: Chiropractic’s Unique Pipeline

More critically, the analogy collapses because it ignores the defining feature of the chiropractic system: the tight coupling of accreditation, examination, licensure, and regulatory policy. In chiropractic, accreditation policy has been used to bind educational institutions to participation in a single examination ecosystem. That fact alone makes chiropractic fundamentally different from the professions Boghosian cites. When accreditation pressure, exam access, and licensure requirements are aligned around a single private system, the result is not merely a national exam, it is a closed pipeline. None of the professions he references operate under that same three-layer lock.

Deconstructing the Specific Professional Comparisons

• Physical Therapy: Boghosian omits that physical therapy’s accreditor is not structurally intertwined with exam participation in the same way, nor is there a proposal to eliminate the board federation as an independent corporate entity and absorb it into the exam body.

• Nursing: This is a vastly larger profession with multiple accrediting bodies. Nursing is not being used to justify a merger that collapses exam control and regulatory policy into a single private structure while telling state boards they are “not acting as regulators.”

• Massage Therapy & Social Work: These are even weaker comparisons. Both operate in far more fragmented regulatory environments. The existence of a national exam in a fragmented system is not analogous to a centralized, tightly coupled pipeline.

• Psychology: Ironically, this undermines Boghosian’s point. Psychology demonstrates that exam centralization is not universally accepted. When psychology’s exam authorities attempted to expand gatekeeping, states pushed back. This is evidence that such consolidation attracts scrutiny due to questions about authority and restraint of trade.

The Comparisons That Were Omitted: Medicine and Osteopathy

Notably absent from Boghosian’s comparison list are medicine and osteopathy, the two professions most structurally analogous to chiropractic in terms of scope, educational rigor, historical development, and role within the broader healthcare system. That omission is not incidental. It is consequential. Especially since the Cartel has long used comparisons to medicine that chiropractic should emulate.

Here, such comparisons are suddenly absent.

Both medicine and osteopathy once relied on centralized, high-stakes, hands-on practical examinations that functioned as final licensure gatekeepers, the functional equivalent of chiropractic’s Part IV. Over time, both professions deliberately moved away from those models. They did so not because of declining standards, but because experience demonstrated that such exams were costly, duplicative of accredited educational assessment, of questionable incremental value to public safety, and increasingly susceptible to becoming barriers to entry rather than safeguards of competence.

Today, in both medicine and osteopathy, clinical competence is assessed primarily within accredited educational programs, where longitudinal evaluation, supervised clinical experience, and demonstrated proficiency are integrated into graduation requirements. National examinations remain part of licensure, but they focus on knowledge, clinical reasoning, and decision-making, not centralized, one-time practical bottlenecks administered by a single private entity. This is not deregulation. It is modern regulatory design.

Just as important is how these professions structure authority. In both medicine and osteopathy, accreditation, examination, and licensure are institutionally separated. Accreditation bodies exist to evaluate educational quality. State boards retain exclusive licensure authority. Examination entities function as asynchronous, non local, computerized assessment tools, not as governance hubs. No single organization controls all three layers, and no private entity claims de facto regulatory power by collapsing testing, policy guidance, and board coordination into one system.

Crucially, neither medicine nor osteopathy uses accreditation as leverage to coerce participation in a specific examination ecosystem. Educational programs are not threatened with loss of accreditation based on graduate exam performance in the way chiropractic programs have been. Exams are not weaponized against schools, and testing bodies do not function as enforcement arms of accreditation. That separation exists precisely to avoid conflicts of interest, restraint-of-trade concerns, and undue concentration of private power over professional entry.

This is where chiropractic’s situation diverges sharply. Chiropractic has been subjected to a three-layer lock in which accreditation policy, examination participation, and licensure requirements are tightly coupled around a single private system. That structure is not mirrored in medicine or osteopathy. It is rejected by them.

Had Boghosian included medicine or osteopathy in his analysis, he would have been forced to confront an inconvenient truth: mature professions move away from centralized practical gatekeeping exams and toward program-based competency assessment, while preserving institutional separation and resisting consolidation of authority. Those examples undermine the inevitability narrative he was advancing.

Instead, he chose to compare chiropractic to smaller, more fragmented professions operating in fundamentally different regulatory environments, where the existence of a national exam does not carry the same coercive effect. That selectivity is telling. It is not comparative analysis. It is rhetorical triage.

The omission of medicine and osteopathy is therefore not a neutral oversight. It is a deliberate narrowing of the comparison set to avoid examples that demonstrate that consolidation is neither necessary, inevitable, nor aligned with how serious professions safeguard competence while preserving autonomy, competition, and public accountability.

The Rhetoric of “Uniformity”

Underlying all of these comparisons is a deeper flaw: Boghosian treats “uniformity” and “consumer protection” as magic words that end the conversation. They do not. Uniformity can just as easily be the language of market control as of public safety. In a free system, those claims are tested, not assumed.

What Is Missing: Specificity and Transparency

Most telling is what Boghosian does not do:

1. He does not provide a chiropractic-specific legal analysis.

2. He does not address the accreditation–exam coupling that makes this merger uniquely coercive.

3. He does not explain why dissolving an independent board federation into an exam-centric entity does not magnify antitrust concerns.

4. He does not invite independent review.

Conclusion: Containment vs. Education

What makes Boghosian’s strategy particularly troubling is that it was delivered alongside an explicit effort to delegitimize those who questioned it. It is one thing to argue for consolidation and invite scrutiny; it is another to substitute analogy for analysis while dismissing dissent as ignorance. When reassurance is paired with ridicule, the intent is not education. It is containment.

The January 29, 2026 NBCE–FCLB “Town Hall” was billed as a moment of transparency. What it revealed instead was something far more troubling: a coordinated effort by a small group of senior chiropractic officials to consolidate accreditation, testing, licensure, and regulatory influence into a single, self-reinforcing system, while openly denigrating anyone who questions the legality, wisdom, or ethics of that consolidation. Yet this small group of self appointed power brokers attempt to get the spotlight off themselves and onto those asking questions.

“Some of your boards are being subject to scare tactics or fear mongering by these very small outside groups…” Karlos Boghosian - NBCE President

Listening carefully to the recording, one hears not just policy advocacy, but a worldview. A worldview in which centralized control is treated as inevitable, dissent is treated as ignorance, and legal concerns are waved away with rhetorical sleight of hand rather than answered on their merits.

This is not merely an internal profession dispute. It is a case study in how monopolies are rationalized, how freedom is rebranded as “misinformation,” and how American principles of competition, autonomy, and limited power are quietly subordinated to administrative convenience and institutional self-interest.

“This question seems to be a little misguided and seems to reflect a misunderstanding of what’s going on here.” Jennifer Semko - NBCE Legal Counsel

The People at the Center of This Project

The Town Hall was not an abstract discussion. It was led and shaped by identifiable individuals holding extraordinary overlapping roles within chiropractic’s power structure:

• Karlos Boghosian, President of the National Board of Chiropractic Examiners and Chair of the Connecticut Board of Chiropractic

• Bob Dashner, President of the Federation of Chiropractic Licensing Boards

• John Schwarzbauer, Executive Director of FCLB

• Norman Ouzts, Chief Executive Officer of NBCE

• Dale Atkinson, Outside Counsel to FCLB

• Jennifer Semko, Outside Counsel to NBCE

These are not fringe actors. They are the stewards of the institutions that now seek to merge into a single locus of authority over chiropractic education, testing, licensure, and regulatory policy, not just in the United States, but increasingly abroad.

That concentration of power is not accidental. It is the goal.

“So we’ve asked Jennifer and Dale to maybe share their thoughts on this again one more time to bring clarity and to ensure that this fear mongering or the scare tactics are not affecting your decision making process” - Karlos Boghosian - NBCE President

The Merger Is Not the Endgame, It Is the Mechanism

Throughout the Town Hall, speakers repeatedly emphasized “one board, one staff, one infrastructure.” That language matters because it describes elimination of institutional independence, not cooperation.

When this consolidation is viewed alongside the role of the Council on Chiropractic Education, the full architecture becomes visible.

CCE Policy 56 ties accreditation to NBCE examination participation and performance. That means schools must align with NBCE to remain accredited. Students must comply with NBCE to graduate. State boards, in turn, rely on NBCE results to license.

The proposed NBCE–FCLB merger does not merely streamline governance. It completes a loop:

• Accreditation pressure through CCE

• Examination control through NBCE

• Regulatory “guidance,” model acts, and board coordination through FCLB

This is vertical and horizontal integration across the entire professional pipeline.

That is not unity. That is capture.

“Consolidated power is always justified in the name of efficiency, and almost always exercised at the expense of liberty.”

Puffery in Place of Law

What makes the Town Hall so revealing is not just what was said, but how it was said.

When delegates raised concerns about statutory authority, antitrust exposure, improper delegation, or personal liability, they were not met with written opinions, jurisdiction-specific analysis, or acknowledgments of complexity.

They were met with rhetoric.

“This question seems to be a little misguided and seems to reflect a misunderstanding of what’s going on here.”

“Some of your boards are being subject to scare tactics or fear mongering by these very small outside groups…”

“Misinformation being shared…”

These are not legal arguments. They are dismissals.

They rely on classic logical fallacies:

• Conclusory assertions (“there is no issue here”) without proof

• Circular reasoning (“it’s permissible because we say it is”)

• Appeal to authority without disclosure of conflicts

• False dichotomies that frame consolidation as the only rational option

This is legal puffery, not legal analysis.

And it is especially troubling when delivered by counsel who represent the merging entities themselves, not the public boards whose delegates are being coached to vote.

“When accreditation, testing, and regulation are controlled by the same private actors, choice becomes theoretical and competition becomes impossible.”

Denigrating Dissent as a Strategy

Perhaps the most ethically revealing aspect of the Town Hall was the tone directed toward critics.

Rather than acknowledging that questioning concentrated power is a healthy and necessary function in a free profession, dissenters were portrayed as:

• “outside individuals”

• “very small groups”

• people who “don’t seem to understand”

• sources of “fear-mongering” and “misinformation”

This language matters because it reveals intent. It is not engagement. It is delegitimization.

When leaders dismiss principled objection rather than answer it, they are not protecting the profession. They are protecting a project.

Making matters worse is that the Coalition of people and organizations that is asking these questions is larger than any group[ that is pushing for the changes. With over 60 international trade associations, state and national organizations, foundations, schools, student groups, and technique organizations, there ahs never been a more organized or larger group of chiropractors that have come together on a chiropractic issue.

But they won’t speak to the Coalition or answers it’s questions.

CLICK HERE for more about the Coalition

Why This Is Un-American in the Most Literal Sense

Chiropractic was born in resistance to centralized medical authority. It grew precisely because it challenged monopolies, rejected enforced orthodoxy, and defended the right of practitioners and patients to choose.

The arguments made in this Town Hall cut directly against those values.

They normalize consolidation, minimize competition, treat autonomy as a nuisance and reframe freedom as disorder.

Most importantly, they invert accountability. State boards are told they are “not acting as regulators” while being urged to take actions that reshape licensure infrastructure nationwide. Public authority is stripped of its public character by labeling it “private membership activity.”

That’s not legal theory it’s a logical fallacy known as equivocation - specifically definitional retreat.

That is not how a free society works.

Betrayal Is Too Strong a Word Until It Isn’t

None of the individuals involved need to be villains to do harm. Institutional capture rarely requires malice. It requires certainty, insulation from challenge, and a belief that “we know best.”

But when leaders of a profession dismiss legal accountability, ridicule dissent, and consolidate power while invoking “public protection” as a mantra, the result is the same.

The chiropractic profession does not belong to NBCE. It does not belong to FCLB.
It does not belong to CCE. It belongs to the public, the practitioners, and the principles of freedom that allowed it to exist at all. If this merger proceeds as designed, chiropractic will not be more unified. It will be more controlled.

And history shows that professions that trade freedom for administrative order eventually lose both.

Final Thought

The Town Hall was meant to reassure. Instead, it documented intent. For regulators, legislators, attorneys general, educators, and chiropractors themselves, the question is no longer whether this consolidation is happening.

The question is whether it will be allowed to happen unchallenged.