Facts: KJ hired firm after receiving a complaint from a former patient. The patient filed the complaint with the Board and alleged that KJ failed to assess the patient’s status, allowed the unlicensed practice by technicians and committed fraudulent billing practices.
Outcome: The firm provided a response to the complaint, breaking down each allegation. Regarding the failure to assess the patient’s status, the firm provided evidence of all the treatment records for the patient. The records included the referral, the evaluation and all SOAPs for each of the 4 sessions the patient had. The firm provided legal argument based on the language of the statutes as to why certain conduct committed by KJ during these sessions was skilled PT work contrary to the patient’s contentions. Next, regarding the unlicensed practice, the firm provided a witness statement by the alleged actor of the unlicensed practice detailing how KJ supervises her during all sessions with patients. Further legal argument was provided based on the statute detailing how and when a technician needs to be supervised. Lastly, regarding the fraudulent billing, evidence of all invoices provided to the patient were submitted along with a witness statement from KJ’s office manager detailing the instructions she provides all patients related to their insurance and cost. Based on the evidence provided and legal arguments made, the Board dismissed the complaint and took no action against KJ’s license.
