2018 Annual Conference Regulation Roundup: Lassoing the ...

2018 Annual Conference Regulation Roundup: Lassoing the ...

2018 Annual Conference Regulation Roundup: Lassoing the Opportunities to Collaborate Lets Start with Why Closing Plenary Session Friday, January 12, 2018, 1:30 pm 3:00 pm Dale J. Atkinson, Esq. About the Speaker

Dale J. Atkinson, Esq. Atkinson & Atkinson 1466 Techny Road Northbrook, IL 60062 847-714-0070 [email protected] About FARB Dale J. Atkinson, Esq.

Executive Director & General Counsel Federation of Associations of Regulatory Boards 1466 Techny Road Northbrook, IL 60062 847-559-3272 [email protected] Interesting Times.. Politically

Legally Practically Naruto v. Slater 2016 U.S. Dist. LEXIS 11041 (US District Ct ND CA 2016) United States District Court for the Northern District of California dismissed lawsuit filed by PETA on behalf of a monkey that took selfies with camera of

defendant photographer. 9th Circuit Court of Appeals Oral arguments https://www.youtube.com/watch?v=WufdT8HT6Uw By AIMEE PICCHI MONEYWATCH August 22, 2014, 12:55 PM U.S. says copyrighting a "monkey selfie" is Why the topic? Lets Start With Why

Perhaps the regulatory community does not spend enough time reflecting on basic concepts.. ..and too much time defending the status quo. Justify.dont defend! Why the topic? Lets Start With Why Is regulation doing what its supposed to be doing?

How do we know? Can we trust ourselves? Ask. Is the profession self-regulated? Is the Profession Self-Regulated? Change is Inevitable What are the biggest challenges facing your

boards/jurisdictions? Change is Inevitable What are the biggest challenges facing your boards/jurisdictions? Why are they challenges? How do we address these challenges?

Being informed Trained Knowledgeable Understand role of board Understand role of board member Separate trade from regulation! And moreand moreand more Embrace the Political Scrutiny Now is the time for the regulatory

community to shine Agenda Why How What Vicissitude..dude tone and core message Start with Why.

Why? Why is there government regulation? Why? Why is there government regulation? Somebodyanyonespeak up! Why? Why is there government regulation?

to protect society where they are unable to otherwise protect themselves Why? provides consumers with an assurance of the qualifications of licensees along with a means of enforcement for the benefit of the public.

Why Criminal-Civil-Administrative Processes Criminal Civil Administrative Commonalities

Differences Why Administrative Processes enforcement for the benefit of the public. Texas State Board of Examiners of Professional Counselors:

Mission ?????????? https://www.dshs.texas.gov/counselor/ -Cannot find mission statement -Currently under Texas State Department of Health Services per recent legislation (as of September 1, 2017) -Also currently under Sunset Review -Compare to psychology: https://www.tsbep.texas.gov/what-isthe-board-of-examiners-of-psychologists WhyAASCB Mission (from

http://www.aascb.org/aws/AASCB/pt/sp/about) AASCB is an association of bodies which are legally responsible for the registration, certification, or licensing of counselors within their jurisdictions in the United States of America. The organization is dedicated to the concept that individuals who have demonstrated competence to render counseling services are entitled to be licensed, certified or registered as counselors by its member boards. *** Accepting competent counselors in the arena of professional practice rather than excluding individuals based on arbitrary or unreasonable criteria is a goal of the

Association. While acknowledging that an appropriate educational and experiential foundation is necessary for professional counselors, diversity of training, focus of practice, and theoretical orientation is recognized as a major strength of the profession. AASCB Mission, contd (from http://www.aascb.org/aws/AASCB/pt/sp/about) The purposes of the Association include:

To facilitate communication among its Member Boards and provide a forum for the exchange of information and ideas among Member Boards concerning licensing, registration and certification of counselors. To encourage and aid collaborative efforts among Member Boards in developing compatible standards and cooperative procedures for the legal regulation of counselors in the several jurisdictions toward the goal of simplifying the licensing, registration and certification process. To represent the opinions of the Association in serving to protect the public in those matters related to the rendering of counseling services. Such opinions may be represented to other counseling organizations; to legislative, judicial, regulatory or executive governmental bodies; and to other groups and associations whose areas of interest may coincide with those of Member Boards. To provide assistance to Member Boards in fulfilling statutory, professional, public and ethical obligations in

legal regulation and enforcement. To engage in and encourage research in matters related to the legal regulation of counseling. To engage in any activities related to its purpose deemed appropriate by the Delegate Assembly of the Association. Why. About AASCB is the alliance of governmental agencies responsible for the licensure and certification of counselors throughout the United States. AASCB collects, interprets, and disseminates information on legal

and regulatory matters, and works to further cooperation among individuals and associations involved in providing counseling services to the public. Furthermore, AASCB publishes materials for training programs and member boards. http://www.aascb.org/aws/AASCB/pt/sp/about Are you able to articulate the WHY? How?

HowElevator Speech Elements of your elevator speech. Created by statute Standards set forth in law (law includes statutes AND rules/regs) Delegated with authority to enforce Oversight Authorized to promulgate rules/regulations Protect the public WRITE YOUR ELEVATOR SPEECH IN 113 WORDS OR LESS

Elevator Speech The _____ board is statutorily created and delegated with the authority to regulate the ______ profession in the interest of protecting the health, safety, and welfare of the public. With necessary oversight by government, the board enforces standards and criteria set forth in statute and adds specificity through the promulgation of regulations. The effectiveness and efficiencies of the board is enhanced by populating the board with a combination of consumer members as well as those with the expertise necessary to address the complexities of profession specific issues. An administrative regulatory system provides consumers with an

assurance of the qualifications of licensees along with a means of enforcement for the benefit of the public. What? What is government regulation? What? What is government regulation? Legislative Enacted statutes

Promulgated rules/regs Force of law Mandated Standards and criteria Government issued & renewed credential Creates legal rights Subject to enforcement Transparency State Based Regulatory

Framework State Rules and Regulations Intrastate overlapping scopes with other professions Embrace the overlapping scopes!! State Based Regulatory Framework State Licensure/Certification Statutes and Regulations Administrative Procedures Act ADA/Disabilities

Open Meetings, etc. Lets Reflect Upon the Challenges and Opportunities Legal Climate Political Climate State Regulatory Board Opportunities AASCB opportunities Legal Climate Notable Cases NC State Board of Dental Examiners v. FTC

FTC found NC Board not immune from antitrust liability due to lack of active state supervision over board comprised of active market participants Rodgers v. State of Louisiana Board of Nursing Student challenged termination of university nursing degree program; court held Nursing Board immune under 11th Amendment Ivy v. Texas Education Agency State not responsible for ADA compliance of private actor NC Acupuncture Licensing Board v. NC Board of Physical Therapy Examiners

Acupuncture Board filed suit seeking declaratory judgment that dry needling within scope of acupuncture and sought injunction against Physical Therapy Board. Henry v. NC Acupuncture Licensing Board Anticompetitive behavior in excluding physical therapists who perform dry needling; Injunction sought North Carolina State Board of Dental Examiners v. FTC (2015) United States Supreme Court affirmed the 4th Circuit Court of Appeals and held that the NCSBDE violated the antitrust laws

by interpreting the scope of practice within the practice act to include teeth whitening. The court held that a nonsovereign actor whether a state agency or private group must meet the two prong test of clearly articulated state policy AND active oversight by the state. Based upon the fact that the NCSBDE is comprised of market participants, the court held that it was a non-sovereign entity. Various perspectives State Boards

Justify existence Sunset actions Do more with less Public-private relationships Associations/federations of regulatory boards Uniformity Programs and services

Public-private relationships Public-Private Partnerships Delegation of Authority State board reliance on the private entitys program as a mandatory prerequisite to licensure State boards reliance on data held by private entity

Legal cases When are public entities deemed to be private? When are private entities deemed to be public? Recent Jurisprudence Rivera-Nazario v. Corporacion Del Fondo Del Seguro Del Estado -- A public corporation deemed a non-sovereign public actor

Dept of Transportation v. Association of American Railroads -- A statutorily identified private corporation deemed a government entity U.S. v. Ackerman -- A private, not-for-profit organization deemed to be a government entity for purposes of the 4th Amendment search and seizure clause

Ask in the Regulatory Arena and Relevant to Associations/Federations of Boards As additional association/federation programs and services are developed and deployed for the benefit of and use by state boards, these questions will become more and more relevant. Ivy v. Commr Williams, Texas

Education Agency (2016) United States Court of Appeals for the 5th Circuit reversed the district court and dismissed the putative class action case filed by deaf individuals seeking injunctive and declaratory relief to require the Texas Education Agency (TEA) to bring private sector driver education programs into compliance with the Americans with Disabilities Act (ADA). To obtain a drivers license, persons under the age of 25 must submit a driver education certificate (DEC) to the Texas Dept. of Public Safety. DECs are only available from private driver education programs that are licensed by the TEA.

Plaintiffs contacted numerous private education programs all of whom refused to provide accommodations for hearing impairments. Plaintiffs filed an action in District Court seeking to require the TEA to comply with the ADA. The District Court denied the TEA motion to dismiss and certified an interlocutory appeal. On appeal and after finding the Plaintiffs had standing, the 5th Circuit held that the plaintiffs case failed on the merits. Ivy v. Commr Williams, Texas Education Agency (2016) The court held in a close call, that driver education is NOT a service,

program or activity of a public entity under Title II of the ADA. The court held that in the absence of a contractual or agency relationship, courts have routinely held that a public entity is not liable for a licensed private actors behavior. While troubled by the fact that a DEC is mandatory and can only be obtained through a regulated private sector education program, the court held that state regulation of the education program does not transform such program into a TEA program or service. Appealed to the United States Supreme Court; U.S. Supreme Court initially agreed to hear the case. October 31, 2016, the U.S. Supreme Court vacated the decision as moot, thus rendering the 5th Circuit opinion of no precedential value.

Issue remains important to the regulatory community. Cary v. Bureau of Professional and Occupational Affairs (Pennsylvania, January 2017) The Commonwealth Court of Pennsylvania (Court) remanded this case to the Pennsylvania Board of Medicine (Board) with instructions to issue applicant a license as a behavioral specialist, which license had been denied by the Board based on failure to have a Master's Degree from an accredited institution. Applicant had received her Master's Degree from a defunct institution not accredited by CHEA or the U. S. Department of Education

(DOE), the organizations selected by the Board to determine accredited institutions. The school she attended, however, was accredited by two outside, accrediting organizations during its existence. Applicant, who was employed as a behavioral specialist, excelled in her work with autistic children but was terminated when her application for licensure was denied by the Board. It was the Board's policy, not a promulgated regulation, to accept a Master's Degree only from institutions accredited by CHEA or DOE. Cary v. Bureau of Professional and Occupational Affairs, contd (Pennsylvania, January 2017)

The Court found that a policy is a guide and has no binding, legal effect as would a regulation. The Court further opined that precedent provided a board, through discretion in its enabling statutes, could determine accreditation on a case by case basis. The Court avoided a determination of whether relying on an outside organization for accreditation was an unlawful delegation, but found that the Board's decision, based on policy, was arbitrary and capricious. A dissenting opinion stated that, while agreeing with the analysis, the Court should instead remand the case to the Board with instructions to investigate and determine whether the institution from which

Applicant received her Master's Degree was an accredited institution. To do otherwise, he reasoned, the Court is determining that the institution is accredited, a responsibility that is placed solely in the Board by statute. Contractors association, state board join forces to build new downtown office building (January 2017) https://www.businessreport.com/article/contractors-association-stat e-board-join-forces-build-new-downtown-office-building

(1/3/2017; last accessed 4/27/2017) Louisiana Associated General Contractors and the Louisiana State Licensing Board for Contractors are teaming up to develop a new four-story building in downtown Baton Rouge that will house offices for both entities. The state LBC is funding the building, and we are providing the property, says LAGC CEO Ken Naquin, who estimates the budget for the buildings construction at $6.5 million. Its a true public-private partnership.

Contractors association, state board join forces to build new downtown office building (January 2017) Some comments from readers posted to the article: So, a lobbying organization and a state board are joining forces to construct a four-story (small) downtown building at the public's expense. What could go wrong with that? Has this cleared the ethics commission? Can an entity that represents the regulated industry enter into an ongoing real estate transaction with the regulator (or the reverse it doesn't matter).

When a contractor has a potential licensing problem and seeks assistance from the Louisiana Associated General Contractors Association will the transaction be "lets just go down the hall and see what our land lord/tenant (sic) has to say, you know we are very close?" Contractors association, state board join forces to build new downtown office building (January 2017) As originally planned, LAGC would donate the land a vacant

parcel adjacent to its existing downtown headquarters and LSLBD was to develop the building, which the two organizations would share. Three bids in an invitation-only process came in 50% higher than the $6.5 million budgeted. Terms of the deal have changed LAGC no longer a part of the project and sold the land to the LSLBC for $2.25 million. Whats the point? Predictionsin the licensing arena Increased governmental emphasis on mobility and

portability Increased governmental emphasis on use of private sector.which will lead to Increased movement by private sector to provide services to public sector Opportunities for associations and federations to develop/enhance programs for the benefit of?? The Future. How might the future look? Is status quo acceptable?

What may change? Constituents? Membership? Programs & services? Other ideas?? Initiatives..Ideas Mobility/portability Examinations/competence assessments Pre-approval for exam E-profiles

Uniform applications Application processing CE/continued competence Renewal applications Renewal application processing Audits Are Associations/Federations State Actors? Yes. No..

Do we care? State Actor: Do we care? Yes. Imposition of rights to persons alleged to have been aggrieved State actors must comply with constitutional and statutory rights

Shift focus from contractual to due process Complicate legal positions taken by associations/federations Recent Judicial Activity Mattei v. International Conference of Funeral Service Examining Boards 2015 U.S. Dist. LEXIS 116009 (US Dist. Ct Western Dist. TX 2015) Kurbatsky v. International Conference of Funeral Service Examining Boards County Court, New York Index No. 8821-15 (January 23, 2017) On Appeal

Fox v. International Conference of Funeral Service Examining Boards 2017 U.S. Dist. LEXIS 38892 (US Dist. CT NY 2017) Lovece v. International Conference of Funeral Service Examining Boards Columbia County Court, New York, Index No. 9288015 (October 25, 2017) General Facts Association of boards Uniform exam program Passing exam accepted/mandated by states/member boards

Exam breach advance access to exam content Previously passing examinees, now licensees, exam scores invalidated No action by state boards.yet Invalidated score recipients (Plaintiffs) challenge actions of exam owner Plaintiffs allege exam owner is a state actor Legal Principles at Stake

Section 1983 Deprivation of federal right by entity acting under color of state law For a private actor to be amenable to a section 1983 action: there must be such a close nexus between the State and the challenged action that seemingly private behavior may be fairly treated as that of the State itself Additional Legal Principles

Federal courts have consistently held that private entities administering examinations relied upon by the state do not qualify under any of the aforementioned tests as state actors for purposes of section 1983 claims Additional Legal Principles an organization with public member institutions from a multitude of states does not act under color of state law because it is independent of any one

particular state. NCAA v. Tarkanian, 488 U.S. 179 (1988) Back to the cases. Not a State Actor Because the Conferences membership is comprised of public entities from all fifty states, the Conference does not act under color of state law of any one state, and is not a state actor for purposes of section 1983. Because the Conference is not a state actor, Plaintiffs section 1983 claims against the

Conference are properly dismissed. Mattei, (pages 10-11) Rights of Associations/Federations Who owns the exam scores and other data? Future exam score transfers Notice to relevant member boards Notice too all member boards Notice to others

Schools/programs Employers Media Others Additional Cases.

Case law that is shaping the legal and political views of the regulatory community Embrace the Overlapping Scopes NC Acupuncture Licensing Board v. NC Board of Physical Therapy Examiners (2016) Turf battle NC Acupuncture Board sued NC Board of Physical Therapy

Examiners Acupuncture Board alleged dry needling exclusive within scope of acupuncture practice Physical Therapy Board filed motions to dismiss. Court granted motions: Lack of subject matter jurisdiction Lack of personal jurisdiction Failure to exhaust administrative remedies NC Acupuncture Licensing Board v. NC Board of Physical Therapy Examiners

(2017) Update August 2, 2017 (North Carolina Superior Court, Wake County): Acupuncture Board subsequently challenged a Declaratory Ruling issued by the Physical Therapy Board finding that dry needling was within the scope of the physical therapy practice act. Notably, that Declaratory Ruling also stated that health professions are allowed to have overlapping scopes of practice. Court affirmed Declaratory Ruling Found that the Revised Position Statement issued by the Physical Therapy Board pursuant to an Attorney General advisory letter, did not violate rulemaking requirements Court affirmed the conclusion that dry needling fell within the statutory definition of physical therapy.

Acupuncture Board has appealed this decision to NC Supreme Court. Henry v. NC Acupuncture Licensing Board (2017) Physical therapists received cease and desist letters from Acupuncture Board re dry needling Physical therapists and patients filed lawsuit against NC Acupuncture Board in federal court Plaintiffs alleged antitrust violations

Significant facts alleged re relationship between Board and trade association Board argued that Federal Court should stay proceedings based upon state court case Court denied request. Case currently stayed pending outcome of appeal to North Carolina Supreme Court of NC Acupuncture Board v. NC Physical Therapy Board case. Texas State Board of Examiners of Marriage & Family Therapists v. Texas Medical Association (2017)

The Supreme Court of Texas (Court) reversed the court of appeals and upheld the Texas State Board of Examiners of Marriage and Family Therapists (Board) rule that permitted therapists to provide diagnostic assessment in the course of therapy. The Texas Medical Association had filed suit asserting the rule was invalid because only those licensed to practice medicine may provide a diagnostic assessment. The Association argued that permitting MFTs to provide diagnostic assessments is beyond the scope of the Therapists Act and solely within the scope of the Medical Practice Act because MFTs are making a diagnosis of a mental disease or disorder. The court of appeals agreed with the Association that the rule exceeded the scope of the Therapists Act. The Board appealed. After reviewing the relevant statutory authority in the Therapists Act and Medical Practice Act, the Court evaluated the ordinary meaning of the terms disease or disorder and

dysfunction finding that, contrary to the Associations purported distinction between the terms, there was no relevant difference. Texas State Board of Examiners of Marriage & Family Therapists v. Texas Medical Association, contd (2017) The Court also rejected the Associations argument that construction of the Therapists Act to permit diagnostic assessments would create an impermissible conflict with the Medical Practice Act and therefore as a matter of public policy, should not be allowed. The Court noted that such that statutory construction principles only apply where statutes are ambiguous and in this case, there was no ambiguity.

Finally, the Court held that every act that a physician may do is not automatically the unlawful practice of medicine when done by a non-physician, and terminology in one field may overlap with that of another. That the diagnosis of physical and mental diseases and disorders lies within the province of physicians does not preclude MFTs from making diagnostic assessments of emotional, mental, and behavioral problems as part of their efforts to evaluate and remediate mental dysfunctions within the marriage and family setting. The Court stated: Our diagnosis is that the diagnostic-assessment rule is valid. Political Climate Regulation vs. economic growth

Separation of trade/industry from regulation/public protection Legislative reform, executive orders Political Climate: Legislation Virginia HB 1566 Creates a new agency: Division of Supervision of Regulatory Boards Mississippi HB 1425 Requires active supervision by the Governor of certain regulatory boards to provide antitrust immunity Arizona SB 1437-Right to Earn a Living Act restricts issuance of regulations which limit in the entry into a profession or trade,

unless they can be shown necessary to the health and safety. Does not address state oversight issue. Political Climate: Executive Orders Arizona Executive Order 2017-03 (March 2017) Each board must review processes, fees, licensure requirements in a report submitted by June 30, 2017. Oklahoma Executive Order 2016-39 (December 2016) Creation of Occupational Licensing Task Force

Political Climate: FTC FTC Economic Liberty Task Force FTC Enforcement FTC v. Texas Medical Board FTC closed investigation in June 2017 after legislation passed addressing definition of telehealth/telemedicine (see Teladoc litigation against Texas Medical Board) Legislature passed and governor signed SB 1107 in May 2017, redefining practitioner/patient relationship to include telemedicine services that comply with Boards standard of care regulations.

FTC v. Louisiana Real Estate Appraiser Board FTC sued Louisiana Real Estate Apppraiser Board alleging that the board unreasonably restrained price competition for appraiser services. (May 30, 2017) Governor then signed an Executive Order to provide active supervision of the Boards actions and the administrative law judge granted a 90-day stay of the proceedings. (August 9, 2017) Perception is Reality Are the professions self-regulated? What role does the private sector play in regulation?

What role should it play? In the News Cornyn plans bill aimed at reining in licensing rules http://www.mystatesman.com/news/state--regional-govt--politics/cornyn-pla ns-bill-aimed-reining-licensing-rules/YDQCXkZNWBAsPvfHhhgt4O/ (April 2017) Restoring Board Immunity Act... https://www.lexology.com/library/detail.aspx?g=3d945eec-f626-48b7-a39d-c 080102eb003

(July 2017) In the News State Board will oppose counseling bill in Tennessee Senate http:// www.wbir.com/news/local/state-board-will-oppose-counseling-bill-in-tennesse e-senate/389322287 (January 2017) WV high court: Licensed counselor not needed for behavorial health center

https:// www.wvgazettemail.com/placement/wv-high-court-licensed-counselor-not-nee ded-for-behavioral-health/article_867bcb35-1313-5723-b1f2-be97a8492c47.ht ml (March 2017) In the News Two licensing boards, for psychologists and counselors, at impasse with governor over sexual orientation language http:// journalstar.com/news/local/govt-and-politics/two-licensing-boards-for-psycholo

gists-and-counselors-at-impasse-with/article_2ae2a247-a4ad-5b3f-9f3c-23afae 9981da.html (March 2017) State mental health board staffs to merge, grow http:// www.eastoregonian.com/eo/capital-bureau/20170327/state-mental-health-bo ard-staffs-to-merge-grow (March 2017) In the News

The Anti-Anxiety App Mobile therapy platforms have some issues to iron out before they unseat traditional treatment. But as an anxiety-management tool, text-and-video therapy might be just what the doctor ordered https://www.wsj.com/articles/the-anti-anxiety-app-1495542095 (May 2017) To Treat Depression, Try a Digital Therapist Studies suggest online tools do just as well if not betterthan traditional therapy for some patients

https://www.wsj.com/articles/to-treat-depression-try-a-digital-therapist-1498227092 (June 2017) The App Will See You Now: Could Your Phone Soon Replace Your Therapist? Scientists are working on an adaptable robotic app called Woebot that might someday help people deal with anxiety and depression. http:// www.healthline.com/health-news/app-will-see-you-now-could-phone-soon-replace-thera pist

(September 2017) In the News Drug addiction up; need for counselors climbs http ://theranger.org/2017/10/16/drug-addiction-up-need-for-counselors-climbs/ (October 2017) Looking to add substance abuse counselors, state eases licensing https:// docs.google.com/spreadsheets/d/17g3PHpW8sYkT1T8ew-T_k9Cg-cAMYAmBdx

PJHy4i7Jo/edit#gid=165649456 (October 2017) Solutions TRAIN Trained board members and staff Reflect on essential issues Accept the facts Integrate communications among and between boards and professions Needs.Understand and articulate your needs

State Board Opportunities Trained board members Communication With board members With other boards With legislature Public protection AASCB AASCB

Opportunities.TRUST Membership Collective wisdom Collective voice Common ground Uniformity Opportunities

Data gathering and management Applications and renewals Exams CE Adverse action databanks Model documents

Education programs And so much more.. Are we there yet? Relevance to you Challenges Political Deregulation Consolidation Other

Status quo Media, perception Additional legal challenges Key Take Home Points Seize the opportunities The status quo may will need to change States rights

Thank You

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