This deep dive examines EBAS, a for-profit disciplinary assessment company wholly owned by the NBCE, and raises serious concerns about transparency, conflicts of interest, and regulatory capture. Licensees ordered into EBAS remediation may pay repeated fees, face anonymous graders, and receive no appeal rights. The transcript highlights contradictions between NBCE tax filings and audited reports, EBAS’s nearly $5 million debt to NBCE, and the role of figures such as Dr. Jason Jaeger. It argues that the proposed NBCE/FCLB merger could consolidate exams, discipline, continuing education, specialty recognition, and regulatory reporting into one private monopoly.
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Chapter 1: The Nightmare Scenario for Licensed Professionals
Timestamp: 00:00:00–00:01:18
Topic: The episode opens by asking listeners to imagine facing a state licensing board inquiry after years of education, debt, and exams. It introduces the idea that a mandatory ethics remediation course may not be state-run, but controlled by a private company tied to the same national testing apparatus that helped gatekeep entry into the profession.
Chapter 2: Introducing EBAS and the Hidden Machinery of Discipline
Timestamp: 00:01:19–00:02:27
Topic: The hosts introduce EBAS and explain that it is a Delaware limited liability company wholly owned by the National Board of Chiropractic Examiners. They establish the structural relationship between EBAS and NBCE, including shared location in Greeley, Colorado.
Chapter 3: The Disciplinary Toll Booth
Timestamp: 00:02:28–00:04:47
Topic: This chapter explains how licensees ordered into EBAS assessments must pay out of pocket, directly to EBAS, at $400 per scenario. It describes how boards may order multiple scenarios, how failed assessments require repayment, and how the process includes anonymous graders, no published fee cap, and no appeal process.
Chapter 4: Beyond Chiropractic: EBAS Markets Across Professions
Timestamp: 00:04:48–00:06:09
Topic: The discussion shifts to EBAS’s broader marketing to professions outside chiropractic, including physicians, nurses, dentists, social workers, engineers, cosmetologists, and financial professionals. This raises questions about whether EBAS fits within NBCE’s stated nonprofit purpose of administering chiropractic examinations.
Chapter 5: Two Financial Stories: IRS Filings vs. Annual Reports
Timestamp: 00:06:10–00:08:01
Topic: The hosts examine alleged discrepancies between NBCE’s Form 990 filings and its audited annual reports. The podcast claims EBAS revenue was reported to the IRS as unrelated business income while annual reports presented the opposite impression to boards and the public.
Chapter 6: Why State Boards May Miss the Red Flags
Timestamp: 00:08:02–00:09:08
Topic: This section explains how underfunded and understaffed state boards may rely on polished annual reports and trusted advisory bodies rather than forensic accounting. The result is a regulatory environment where boards may accept representations without independently verifying underlying financial records.
Chapter 7: Jason Jaeger and the Concentration of Power
Timestamp: 00:09:09–00:10:31
Topic: The episode uses Dr. Jason Jaeger as a case study in overlapping roles. It identifies him as NBCE vice president, Nevada State Chiropractic Board secretary-treasurer, investigating board member in disciplinary cases, FCLB Bylaws Committee member, and ICA board member.
Chapter 8: The Email Trail and Conflict-of-Interest Questions
Timestamp: 00:10:32–00:12:24
Topic: This chapter focuses on a September 5, 2025 email exchange in which EBAS sought a testimonial from Jaeger, who then forwarded the request to the Nevada board while referring to “our director” for the EBAS program. The podcast contrasts this with Nevada’s response of “none” to conflict-of-interest disclosure requests.
Chapter 9: The Atlanta Merger Vote and the Buried Debt
Timestamp: 00:12:25–00:13:56
Topic: The podcast turns to the April 30 Atlanta vote on the proposed NBCE/FCLB merger. It highlights a reported footnote in NBCE’s 2025 audited annual report showing EBAS owes NBCE nearly $5 million and argues that this debt was absent from primary merger communications.
Chapter 10: FCLB’s Silence and Financial Dependence
Timestamp: 00:13:57–00:14:50
Topic: This section examines the FCLB’s role as an advisory body to state boards. The hosts argue that FCLB’s filings do not mention EBAS despite EBAS’s relevance to disciplinary remediation and despite NBCE allegedly providing more than 60 percent of FCLB’s annual budget.
Chapter 11: The Post-Merger Monopoly Pipeline
Timestamp: 00:14:51–00:15:45
Topic: The episode lays out the concern that a merged NBCE/FCLB entity could control the entire professional lifecycle: initial licensing exams, continuing education, specialty recognition, disciplinary reporting, and EBAS remediation. The hosts describe this as controlling the “entry gate,” “maintenance fees,” “permanent record,” and “penalty box.”
Chapter 12: State Action Immunity and Legal Exposure
Timestamp: 00:15:46–00:17:35
Topic: The discussion explains state action immunity and the requirement that private regulatory arrangements be actively supervised by the state. The podcast warns that boards delegating disciplinary power to a private, opaque vendor without meaningful oversight could risk losing antitrust immunity and expose individual board members to liability.
Chapter 13: Why This Matters to Professionals, Students, and the Public
Timestamp: 00:17:36–00:18:41
Topic: This chapter broadens the implications beyond chiropractic. It argues that professionals’ livelihoods, students’ federal loan-backed exam costs, and the public’s trust in licensed professionals are all affected when state authority becomes entangled with private vendors.
Chapter 14: The Final Question: Who Is Regulating Whom?
Timestamp: 00:18:42–00:19:24
Topic: The closing chapter asks whether the state is truly regulating the profession or whether a private corporate ecosystem has effectively become the regulator. It frames the issue as a warning for every state delegate, licensed professional, and citizen concerned about accountability.
