NBCE Declares Itself Above Transparency

Anatomy of a Brush-Off: NBCE refuses to answer, FCLB stays silent, CCE says don't look at us, students are screwed and the liability falls on the state boards

When asked to explain the legal basis for centralizing a licensure exam embedded in state law, NBCE refuses to answer, while FCLB stays silent, CCE says don't look at us and the liability falls on the state boards

The Coalition Asked the Questions. NBCE Refused to Answer.

On June 26, 2025, the Chiropractic Freedom Coalition (CFC) representing thousands of concerned chiropractors and students sent a formal request to the National Board of Chiropractic Examiners (NBCE). In the spirit of transparency claimed by NBCE, the letter asked direct, regulatory questions about NBCE’s plan to centralize Part IV, a licensure exam referenced in law or regulation across dozens of states, from regional testing centers to a single site in Greeley, Colorado.

CLICK HERE for a copy of the letter

The questions were not rhetorical. They asked for transparent facts:

• Did state boards approve the change?

• Was it reviewed by legal counsel?

• Were public stakeholders consulted?

• What authority supports the shift?

NBCE’s response came not from its CEO or board, but from an anonymous “Communications Team.” The reply offered no answers and no transparency. Instead, it stated that NBCE would not respond point-by-point, and would issue public statements instead, purportedly to provide “clarity for all stakeholders.”

“Your message reads less like a defense of due process and more like a brush-off cloaked in bureaucratic euphemism. It seems the NBCE has adopted a new communications strategy: Answer questions by refusing to answer them, then declare it transparency.”

CFC's Response: This Is Not a Private Preference, It’s a Public Regulatory Matter

In response, the Coalition issued a sharply worded follow-up, stating:

“While you’ve made it clear you won’t be responding ‘directly or on a point-by-point basis,’ we must respectfully remind you that your unilateral decision to centralize a licensure gatekeeping exam, one embedded in state law, rules and regulations, is not a private operational preference. It is a public regulatory matter that materially affects the rights of licensure candidates and the lawful obligations of state boards.”

The Coalition noted that NBCE had yet to cite a single legal authority, state agency directive, or statutory provision supporting the centralized format. It asked plainly:

“If you intend to speak ‘to all stakeholders,’ perhaps start with answering whether your current model violates state laws, rules and regulations.”

The CFC also highlighted NBCE’s lack of transparency in hiding behind an unidentified “Communications Team”:

“For a body that claims to champion transparency, hiding behind an anonymous signature is a curious way to build trust among stakeholders.”

And perhaps most importantly:

“Issues of law, access, and equity are not rhetorical, they are real. And your refusal to engage substantively only sharpens the legal and ethical questions you appear so determined to avoid.”

FCLB: Funded by NBCE, Silent on Oversight

This episode mirrors the response (or lack thereof) from the Federation of Chiropractic Licensing Boards (FCLB). The CFC sent a nearly identical inquiry to the FCLB asking whether any member state boards had reviewed or approved NBCE’s new format. The FCLB hasn’t responded. Follow-up requests to Jon Schwartzbauer FCLB’c Executive Director have been ignored.

So much for transparency at the FCLB.

And that’s no surprise. The FCLB’s operating budget is largely funded by the NBCE. Its leadership and board rosters are interwoven with those of the NBCE. In effect, the very organization tasked with helping state boards navigate licensure changes is financially dependent on the entity making those changes unilaterally.

“We are not asking for spin. We are asking for documentation, legal rationale, and accountability. The basic ingredients of governance in a professional licensure context.”
—Chiropractic Freedom Coalition

State Boards: You’re Now Holding the Bag

Let’s be blunt: State boards are on the hook for this.

Most states explicitly name NBCE exams in their licensing laws and regulations. But the laws were passed when Part IV was a decentralized, accessible, and regionally administered exam. The new format, requiring travel to Colorado, is a different product, with new cost barriers and no legal authorization in most jurisdictions.

By continuing to enforce Part IV under its new, unapproved format, state boards risk:

• Violating due process

• Acting outside their statutory authority (ultra vires)

• Triggering lawsuits from disadvantaged candidates

The NBCE will not defend your statute in court. The FCLB will not write your AG opinion. But you, state board members and attorneys, will be the ones facing the consequences.

The Chiropractic Cartel Has Closed Ranks

This is how regulatory capture works:

• A private corporation (NBCE) controls licensure access.

• An accreditor (CCE) enforces monopoly testing through Policy 56.

• A licensing board federation (FCLB) is financially tethered and silent.

• And no one, not one, will answer questions from stakeholders.

This is not governance. This is control.