Summary. A professional license is frequently a person's entire livelihood, and a board complaint threatens it through a process that resembles litigation only partially. The board is investigator, prosecutor, and adjudicator; the rules of evidence are relaxed; the standard of proof may be lower than in civil court; and the collateral consequences of discipline — database reporting, reciprocal action elsewhere, exclusion from federal programs, loss of privileges and insurance — frequently exceed the sanction itself. This guide walks the process from complaint through judicial review, explains what to do in the investigative phase where most cases are decided, covers settlement terms that matter, and addresses collateral consequences.

The letter arrives from the board. It says a complaint has been received, describes the allegation in one or two sentences, and asks for a written response within twenty days.

What the licensee does in the next three weeks determines the outcome of the case, and the most common error is answering the letter personally, at length, before anyone has looked at the file.

Three things are true about that letter that are not obvious from reading it:

  1. The response becomes evidence. It will be quoted in the accusation, used to impeach at hearing, and — if the conduct is also criminal — potentially provided to prosecutors.
  2. The board is not neutral at this stage. It is investigating, and the staff evaluating the response is the same institution that will prosecute the case.
  3. Most cases are resolved in this phase. Complaints are closed without action far more often than they proceed to hearing, and a well-prepared response is what closes them.

Who these boards are and what they do

Every state licenses dozens of professions — medicine, nursing, pharmacy, dentistry, veterinary medicine, mental health, law, accounting, engineering, architecture, real estate, insurance, contracting, cosmetology, and many more — through boards that are typically composed of licensees plus public members, staffed by investigators and prosecutors, and empowered by an enabling statute and implementing regulations.

Their powers generally include: issuing and renewing licenses; investigating complaints; issuing subpoenas; conducting hearings; imposing discipline; and, in urgent cases, summarily suspending a license pending a hearing where the public health or safety requires it.

The grounds for discipline are defined by statute and are broader than most licensees realize:

  • Incompetence, negligence, or gross negligence in practice.
  • Unprofessional conduct, a deliberately open-ended category that in most statutes includes dishonesty, boundary violations, impairment, sexual misconduct, and conduct that would be recognized as unprofessional by the profession.
  • Violation of the practice act or the board's regulations.
  • Conviction of a crime, frequently "substantially related to the qualifications, functions, or duties" of the profession, and in some statutes any felony or any crime of moral turpitude.
  • Fraud or misrepresentation in obtaining or renewing a license.
  • Substance abuse or impairment, or a physical or mental condition affecting the ability to practice safely.
  • Failure to maintain records or to comply with documentation requirements.
  • Improper billing or fee practices.
  • Discipline by another jurisdiction or by another board — the reciprocal discipline provision.
  • Failure to cooperate with an investigation, which is independently sanctionable in most states.

Where complaints come from: patients and clients; family members; employers and supervisors; colleagues, sometimes under a mandatory reporting obligation; insurers and hospitals reporting adverse events, settlements, or privilege actions; other agencies; law enforcement; and the board's own monitoring of criminal history, prescription databases, and news reports. Most states grant immunity to good-faith complainants, which means the licensee generally cannot sue the reporter.

Self-reporting. Many statutes require a licensee to report their own criminal charges or convictions, discipline in another state, malpractice settlements above a threshold, or a change in practice status, frequently within a short period — thirty days is common. Failure to self-report is an independent violation and it is treated as a candor problem, which boards punish more severely than the underlying conduct.

The investigative phase

This is where cases are won, and where they are lost by well-meaning licensees acting alone.

On receiving notice of a complaint:

1. Retain counsel experienced with this board. Not a general litigator, and not the malpractice defense lawyer assigned by the carrier for the related civil case — their interests diverge. Board practice is idiosyncratic, and a lawyer who knows the staff, the board members, and the settlement norms is worth substantially more than one who does not.

2. Check insurance. Many professional liability policies include license defense coverage, often with a modest sublimit and sometimes with a panel counsel requirement. Notice promptly; late notice is a coverage problem. Some policies cover only the hearing and not the investigation, which is exactly backwards from where the money should be spent — negotiate for investigation coverage at renewal.

3. Do not contact the complainant. It will be characterized as intimidation or as an attempt to influence a witness, and it is independently sanctionable.

4. Preserve everything. Records, appointment systems, communications, billing, and any relevant device data. Do not alter a record, including to add a clarifying note, without a clear, dated, and disclosed amendment. Altering a record after notice of a complaint is the single most damaging fact available to a board, and it converts a defensible negligence case into a dishonesty case.

5. Gather the file before responding. The complete record, the policies in effect, any incident report, the credentials and training of everyone involved, and the standard-of-care literature.

6. Assess the parallel proceedings. A civil malpractice suit, a criminal investigation, an employment action, a payer audit, or a federal enforcement matter may all be running. The board response can be used in every one of them. Where criminal exposure exists, the sequencing decision — whether to assert the Fifth Amendment and accept an adverse licensing inference, or to respond and create a statement — is the most consequential judgment in the case and requires criminal counsel.

Responding to the inquiry

The written response is the most important document in the case. It should:

  • Be prepared by counsel, with the licensee's input, after the file is assembled.
  • Address the specific allegation, not the licensee's general excellence.
  • Explain the clinical or professional reasoning contemporaneously reflected in the record.
  • Cite the record and attach it.
  • Include supporting materials: relevant literature, policies, a chronology, and, where warranted, a supporting expert opinion on the standard of care.
  • Acknowledge what is true. A response that disputes the undisputable destroys credibility for everything else.
  • Describe remediation already undertaken — training completed, a process changed, a system implemented — which is the single most effective mitigation available.
  • Be respectful in tone. Boards are composed of the licensee's peers, and indignation reads badly.

Request an extension if needed. Boards routinely grant them, and a well-prepared response two weeks late is far better than a rushed one on time.

Ask for the complaint and any investigative materials the board will provide. Practice varies: some states provide the complaint and the investigative file, others provide a summary. Ask, and if refused, note it and consider whether a public records request reaches any of it.

The interview

Investigators frequently request an interview. Several points:

  • The licensee has the right to counsel present. Exercise it, always.
  • Prepare thoroughly. Review the record, anticipate the questions, and practice. An unprepared licensee will speculate, and speculation becomes an admission.
  • Answer the question asked. Do not volunteer, do not explain unrelated matters, and do not attempt to charm the investigator.
  • "I don't recall" is an acceptable answer when true. Guessing is not.
  • The Fifth Amendment applies to compelled testimony that could be used in a criminal case — but asserting it in a licensing proceeding generally permits an adverse inference and, in many states, is itself treated as failure to cooperate. This trade-off must be evaluated with criminal counsel before the interview, not during it.
  • Consider a written response instead, where the board's rules permit. A written answer is controlled; an interview is not.
  • Request a recording or a transcript, and if none is made, prepare a memorandum immediately afterward.

A note for licensees employed by government entities. Garrity v. New Jersey protections may apply to statements compelled under threat of job loss, rendering them inadmissible in a criminal prosecution. The analysis is specific and it must be raised at the time.

Resolution before a hearing

Most matters end here, and the outcomes range widely.

Dismissal or closure without action. The best result, and the most common where the response is strong. Ask whether the closure is recorded and whether it appears anywhere; in many states a closed complaint remains in the board's file and may be considered in a future matter, and in a few it is publicly disclosed.

A letter of concern, advisory letter, or letter of caution. Non-disciplinary in most states, not reportable to national databases in most cases, and not published — but confirm each of those points, because the classification varies and a licensee who accepts a "non-disciplinary" letter that turns out to be reportable has made an expensive mistake.

A citation and fine, in states with such a mechanism for minor violations. Frequently non-disciplinary but sometimes reportable.

A consent order, stipulation, or settlement agreement. The most common resolution of a substantive matter. The licensee admits or does not contest specified facts and accepts specified discipline.

Terms to negotiate in a consent order, in rough order of importance:

  • The characterization of the conduct. "Failure to maintain adequate records" and "gross negligence" carry the same practical burden and entirely different collateral consequences. Fight over the words.
  • Whether findings are admitted or the licensee neither admits nor denies. A no-contest resolution limits collateral use, though many boards insist on admissions.
  • The category of discipline. Reprimand, probation, suspension, and revocation are ordered categories with sharply different consequences.
  • Reportability. Whether the order is reported to the National Practitioner Data Bank or other databases, and how it will be characterized in the report.
  • Publication. Whether it appears on the board's public license lookup, in what terms, and for how long.
  • The duration of probation and the specific conditions: continuing education, a practice monitor, chart review, supervision, restrictions on scope or setting, testing, and reporting obligations.
  • The cost recovery many boards impose for investigation and prosecution costs.
  • Early termination provisions permitting a petition to end probation after satisfactory compliance.
  • Whether the order can later be expunged, sealed, or removed from public display.
  • Language about the effect in other jurisdictions, which will not bind another board but which frames how the conduct is described.

Diversion and impaired professional programs. For substance use and certain mental health matters, most states operate a program permitting a licensee to enter monitoring — testing, treatment, practice restrictions, meetings — in lieu of discipline, with the matter held in abeyance and, on successful completion, closed without a disciplinary record. These programs are demanding and long, typically three to five years, with immediate consequences for a positive test or a missed check-in. They are also frequently the best available outcome, and the decision to enter should be made early, because eligibility often closes once formal charges are filed.

The hearing

Where settlement fails, the board files a formal accusation or statement of charges, and the matter proceeds to an administrative hearing.

Who decides. Either an administrative law judge who issues a proposed decision the board may adopt, modify, or reject; a hearing panel of board members; or the full board. Where the board itself adjudicates a case its staff prosecuted, the structural fairness concern is real, and most states address it through separation-of-functions rules prohibiting the prosecuting staff from advising the decision-makers. Confirm those rules are being followed and object on the record if they are not.

Procedure, governed by the state's administrative procedure act and the board's rules:

  • Discovery is limited. Many states provide for exchange of witness lists, exhibits, and expert reports, and some permit depositions on a showing of need. It is far less than civil discovery, and the defense frequently proceeds without knowing exactly what the prosecution will present. Use every mechanism available, and consider a public records request for materials the board must disclose.
  • Subpoenas are available for witnesses and documents, issued by the ALJ or the board.
  • The rules of evidence are relaxed. Hearsay is generally admissible, though in many states it may not by itself support a finding unless it would be admissible over objection in a civil action — a rule worth knowing and citing.
  • The burden of proof varies by state and sometimes by profession. Some states use preponderance of the evidence; others require clear and convincing evidence, particularly where a license — a protected property interest — is at stake. Determine the standard early, because it shapes everything.
  • The burden is on the board, and the licensee should insist on it rather than defending a case the board has not made.

Trying the case:

  • Expert testimony on the standard of care is essential in negligence and competence cases, and the defense expert's credibility frequently decides the matter. Retain someone who practices in the same setting, not merely in the same specialty.
  • The licensee's own testimony is nearly always necessary and is the highest-risk moment. Prepare extensively. The board will assess insight, candor, and whether the licensee understands what went wrong — and a defensive, blaming witness produces a harsher sanction than the conduct warranted.
  • Character and practice evidence — colleagues, supervisors, patients or clients — humanizes the licensee and is generally admitted.
  • Mitigation is a separate case and should be prepared as such: remediation completed, systems changed, training obtained, treatment engaged, time elapsed without recurrence, cooperation with the investigation, and the absence of harm.
  • Preserve the record. Object to evidentiary rulings, make offers of proof, and raise procedural and constitutional objections at the hearing, because they are waived if not preserved.

The decision. Findings of fact, conclusions of law, and an order. Where an ALJ proposes a decision, the board may adopt, reduce, or in many states increase the sanction — and where the board rejects a proposed decision it must generally review the record and, in some states, permit argument.

Sanctions and collateral consequences

The sanctions themselves, in ascending order: a confidential letter of concern; a public reprimand or censure; a fine; probation with conditions; restriction of the scope of practice; suspension for a defined period or until conditions are met; voluntary surrender; and revocation, sometimes with a stated period before reapplication is permitted.

The collateral consequences are frequently worse, and they must be modeled before any resolution is accepted.

  • National databases. For healthcare practitioners, the National Practitioner Data Bank receives reports of licensure actions, malpractice payments, adverse privileging actions, and exclusions, and is queried by hospitals, health plans, and other boards. Reports are permanent and the dispute process is narrow. Ask, in every negotiation, whether the resolution is reportable and how it will be characterized.
  • Reciprocal discipline. Every state where the licensee holds a license will act on the discipline, frequently through a summary process treating the first state's findings as established. A licensee holding five licenses faces five proceedings. Notify the other boards as their statutes require — usually within thirty days — because failure to report is a separate violation in each.
  • Federal health program exclusion. 42 U.S.C. § 1320a-7 provides for mandatory and permissive exclusion from Medicare, Medicaid, and other federal programs, including permissive exclusion based on license revocation or suspension for reasons bearing on professional competence, performance, or financial integrity. Exclusion is effectively career-ending for a healthcare practitioner and it extends to employment by any entity that bills federal programs.
  • DEA registration. A state license action affecting prescribing authority puts the federal registration at risk, and the DEA's process is separate.
  • Hospital privileges and payer participation, each with its own process and its own reporting.
  • Employment. Most employment agreements make license discipline a for-cause termination event.
  • Malpractice insurance — nonrenewal, surcharge, or coverage conditions.
  • Immigration consequences for a licensee whose status depends on employment in the licensed profession.
  • Public reputation. Board actions appear on license lookup sites and are indexed by search engines indefinitely.

Judicial review

An adverse final decision is reviewable in court under the state's administrative procedure act.

Typical features:

  • A short deadline — thirty days is common — that is jurisdictional. Calendar it the day the decision issues.
  • Review on the administrative record, without new evidence except in narrow circumstances.
  • A deferential standard. Most states review factual findings for substantial evidence and legal conclusions de novo, with the sanction reviewed for abuse of discretion. A minority apply an independent judgment standard to cases affecting a fundamental vested right, which a professional license frequently is — and where that standard applies, the reviewing court weighs the evidence itself. Determine which standard governs, because it changes the case entirely.
  • A stay pending review is available in some states, sometimes automatically on filing and sometimes only on motion showing irreparable harm. Seek it immediately; a suspension that takes effect during a year of appellate review is the practical outcome regardless of who ultimately wins.

Grounds that succeed:

  • The findings are not supported by substantial evidence, most often where the case rested on hearsay that could not support a finding.
  • The board exceeded its statutory authority or applied a standard not found in the practice act.
  • Procedural error — inadequate notice of the charges, denial of the opportunity to present evidence, improper separation of functions, or a decision-maker who prejudged.
  • The sanction is disproportionate to the findings, particularly where the board departed from its own precedent without explanation.
  • Constitutional claims — due process, vagueness of an "unprofessional conduct" standard as applied, and in rare cases equal protection.

Realistically, reversals are uncommon and modifications of sanction are somewhat more common. The strategic value of preserving appellate issues is partly in the appeal itself and partly in the leverage it creates for a negotiated modification.

Rehabilitation and restoration

Petitions for early termination of probation, for modification of conditions, and for reinstatement after suspension or revocation are available in most states after a stated period.

What a successful petition contains:

  • Complete compliance with every condition, documented.
  • Evidence of rehabilitation: treatment records where relevant, sustained sobriety, education completed, supervised practice with favorable evaluations.
  • Insight. The petitioner must be able to describe what happened, why, and what has changed, without minimizing. Boards deny petitions from applicants who blame the complainant or the process.
  • Support letters from supervisors, colleagues, and treating professionals who know the facts.
  • A practice plan describing the intended setting, supervision, and safeguards.
  • Time. Boards want to see a sustained period without incident, and petitions filed at the earliest permissible moment are frequently denied for that reason alone.

Expungement or sealing is available in a small number of states and for a small number of categories. Where it exists, pursue it — a removed record materially changes employment and credentialing outcomes.

What licensees should do before any of this happens

  • Know the practice act and the board's regulations. Most disciplinary matters involve rules the licensee had never read.
  • Document contemporaneously and completely. The record is the defense, and a thin record converts a defensible judgment call into an indefensible one.
  • Never alter a record after the fact except by a dated, disclosed addendum.
  • Comply with self-reporting obligations on time, every time.
  • Maintain license defense coverage and confirm it covers the investigation stage.
  • Respond to renewal questions accurately, including questions about criminal history and other-state discipline. A false renewal answer is a fraud charge that is far worse than the underlying matter.
  • Address impairment early and voluntarily. Self-referral to a monitoring program before a complaint arrives produces dramatically better outcomes than referral afterward.
  • Take complaints seriously the first time. A prior letter of concern is an aggravating factor in every subsequent matter, and the licensee who treated it as a formality will regret it.

A closing perspective

Licensing boards exist because the public cannot evaluate professional competence directly and must rely on someone to do it. That mission is legitimate, and boards discipline people who should be disciplined.

They also operate with structural features that would be intolerable in a court: the same institution investigates, prosecutes, and decides; the rules of evidence are relaxed; discovery is thin; and the practical consequence of an adverse finding — professional destruction — is imposed under a standard of proof that in many states is merely a preponderance.

The response to that asymmetry is not outrage; it is preparation. The licensee who retains experienced counsel on day one, assembles the record before responding, answers the specific allegation with evidence, demonstrates remediation, and negotiates the characterization of any resolution as carefully as the sanction, gets a dramatically better outcome than one who does not. That is true across professions and across states, and it is the single most useful thing anyone can know about this process.

Summary suspension and emergency action

Where a board concludes that continued practice presents an immediate danger, most statutes permit summary suspension or an interim restriction before any hearing, with a post-deprivation hearing required within a short period — often ten to thirty days.

How it arrives: an order, sometimes accompanied by a supporting declaration, effective immediately. The licensee learns they cannot practice, frequently on the day it issues, and the practical consequences — patients or clients to be reassigned, employment suspended, income stopped — begin at once.

What to do in the first forty-eight hours:

  • Comply. Practicing after a suspension order is unlicensed practice, a separate violation, and in many states a crime. Whatever the merits, stop.
  • Demand the expedited hearing the statute provides, in writing, immediately. These deadlines are short and waivable.
  • Obtain the supporting materials. The board acted on something; get it.
  • Consider a negotiated interim restriction in place of a full suspension — supervised practice, a scope limitation, a chaperone requirement, or a prescribing restriction. Boards frequently accept a narrower measure that addresses the safety concern, and a licensee who proposes one credibly is in a materially better position than one who simply contests.
  • Address the immediate practice consequences ethically: patient or client notification, coverage arrangements, and, for a lawyer, compliance with the rules governing withdrawal and file transfer. A licensee who abandons clients while contesting a suspension has created a second charge.
  • Notify the carrier, the employer, and any other board, as the applicable obligations require.

Contesting it. The standard is typically whether the board had reasonable cause to believe the licensee presents an immediate threat, and courts and hearing officers are deferential. The realistic objectives are to narrow the restriction, to obtain a prompt merits hearing, and to begin building the remediation record that will matter at resolution.

A structural observation. Summary suspensions are appropriate in genuine cases and they are also used, occasionally, as leverage. The best protection is speed: a licensee who assembles the record, proposes a workable interim restriction, and demands the hearing within days is treated very differently from one who waits three weeks for a lawyer to review the file.

Profession-specific notes

The framework is general; the details differ, and a few recurring points are worth flagging.

Physicians and other healthcare practitioners. The National Practitioner Data Bank reporting consequence dominates every negotiation. Prescribing cases increasingly begin with prescription drug monitoring program data rather than a complaint, and the board may consult a prescribing expert before the licensee knows a matter exists. Boundary cases are prosecuted vigorously and the sanction is nearly always severe. Where a matter involves controlled substances, coordinate with counsel handling the DEA registration from the outset.

Nurses. Employer reporting drives a large share of matters, and the employer's investigation — often conducted without counsel for the nurse — produces the statements the board later uses. A nurse asked to attend an investigatory meeting has a right, under Weingarten, to union representation where represented, and should decline to provide a written statement without advice.

Lawyers. Disciplinary systems are typically run by the state's highest court rather than an executive-branch board, with their own rules, their own confidentiality regime, and diversion programs for minor matters. Trust account irregularities are treated as strict-liability matters regardless of intent, and the reconciliation records are the entire case.

Accountants. Board discipline runs alongside AICPA and, for auditors of public companies, PCAOB proceedings, each with independent consequences. Peer review findings frequently become board matters.

Real estate and insurance producers. Matters usually involve handling of client funds, disclosure, and unlicensed activity by unlicensed assistants. Producer license actions are reported through national databases used in every other state's renewal process.

Contractors. Boards typically have consumer-restitution authority and can order payment as a condition of continued licensure, and bond claims run in parallel. Unlicensed practice by a subcontractor can be attributed to the licensed general.

Engineers, architects, and surveyors. Cases frequently involve sealing documents not personally prepared or supervised, and the standard is unforgiving. Firm licensure obligations are separate from individual ones.

Mental health professionals. Confidentiality obligations complicate the defense: the licensee may be unable to disclose the records that would exonerate them without the client's authorization or an order, and the sequencing of that release requires care.

The employer's perspective

An employer whose licensed professional is under investigation faces its own set of decisions, and they are frequently made badly.

Reporting obligations. Many statutes require an employer to report specified conduct — termination for cause, a settlement above a threshold, a restriction of privileges, or a reasonable belief of impairment — within a stated period. Determine the obligation before deciding anything else, because a decision structured to avoid a report may itself violate the statute. Most reporting statutes provide immunity for good-faith reports, which removes the defamation concern that causes employers to hesitate.

Internal investigation. Conduct it, promptly and properly, but understand that its work product will be subpoenaed by the board and may not be privileged if it was not conducted for legal advice. Structure it through counsel where the exposure warrants.

Employment action. Termination, suspension, or a scope restriction pending resolution. Consider: the employment agreement's cause provisions; any collective bargaining obligation; whether the conduct is also a policy violation independent of the licensing question; whether a restriction rather than a suspension addresses the risk; and whether the employer's own liability — negligent retention — argues for action.

Do not condition employment on the outcome of the board matter if the conduct independently warrants action, and do not delay action the facts require while waiting for a board that may take two years.

Cooperation with the board. Employers are generally required to produce records on subpoena and frequently interviewed. Respond completely, and be careful about characterizing the licensee's conduct beyond what the records show.

Do not counsel the licensee. The employer's counsel does not represent the individual, the interests diverge immediately, and a licensee who believed otherwise will say so. Tell them, in writing, to obtain their own lawyer.

Consider the practical aftermath. A licensee who is cleared, or who resolves the matter with a minor sanction, may be a perfectly good employee whom the employer has by then alienated. Handle the process with the same care the employer would want if the positions were reversed, and communicate honestly about what the employer must do and why.

One final practical note on cost. License defense is expensive relative to what most individual licensees expect, and the expense is front-loaded into the investigative phase where it does the most good. A licensee weighing whether to engage counsel for a "minor" complaint should compare the fee against the value of the license over a remaining career, and against the cost of the reciprocal proceedings, database report, and credentialing consequences that follow even a modest public sanction. Measured that way, the answer is nearly always to spend the money early — and to buy license defense coverage before it is needed, which costs very little and is available on most professional liability policies as an endorsement.

Primary authority

License discipline is administrative law with a professional-practice overlay, and the constitutional floor matters more than practitioners expect.

  • Board of Regents v. Roth, 408 U.S. 564 (1972) and Barry v. Barchi, 443 U.S. 55 (1979) — a professional license is a property interest, and its summary suspension requires a prompt post-deprivation hearing.
  • Mathews v. Eldridge, 424 U.S. 319 (1976) — the three-factor test that decides how much process a particular board procedure owes.
  • Withrow v. Larkin, 421 U.S. 35 (1975) — combining investigative and adjudicative functions in one agency is not automatically a due process violation.
  • Gibson v. Berryhill, 411 U.S. 564 (1973) — but pecuniary interest of board members who are competitors can be.
  • North Carolina State Board of Dental Examiners v. FTC, 574 U.S. 494 (2015) — active supervision is required before a board of market participants gets state-action antitrust immunity, a live argument when discipline looks like competitive exclusion.
  • Model State Administrative Procedure Act (2010) §§ 401–423 — notice, discovery, the contested case hearing, the record, and the final order, in the form most state APAs follow.
  • 5 U.S.C. § 556 and § 557 — the federal analogue for formal adjudication, frequently borrowed by state courts construing their own statutes.
  • Steadman v. SEC, 450 U.S. 91 (1981) — the burden of proof in administrative proceedings, and the contrast with the clear-and-convincing standard most state licensing statutes impose.
  • 42 U.S.C. § 11131 et seq. and 45 C.F.R. Part 60 — the National Practitioner Data Bank, and the reporting obligations that outlast the discipline itself.
  • Goldberg v. Kelly, 397 U.S. 254 (1970) — the origin of the modern pre-deprivation hearing requirement.

Related articles

This guide is provided for general informational purposes and does not constitute legal advice. Licensing statutes, procedures, burdens of proof, standards of judicial review, and reporting obligations differ substantially by state and by profession. Consult counsel experienced with the specific board before responding to any inquiry.