The FCLB Refuses to Confront NBCE’s Centralization Scheme: When Silence Becomes Complicity:
Originally published: 2025-08-20
Letter? What Letter?
On June 27, 2025, the Chiropractic Freedom Coalition sent a formal letter to the Federation of Chiropractic Licensing Boards (FCLB). The letter asked a series of clear, reasonable questions: Had any state chiropractic licensing boards reviewed the NBCE’s decision to centralize Part IV in Greeley, Colorado? Had any sought legal counsel or public input? Had anyone considered the serious statutory and regulatory implications?
The FCLB did not respond.
So we followed up.
Still no answer.
This isn’t bureaucratic oversight. It’s institutional cowardice.
“Without corresponding state-level review or formal adoption, continued enforcement of Part IV as a condition of licensure under this new centralized model will raise legal and administrative concerns.”
—Chiropractic Freedom Coalition Letter to FCLB, June 27, 2025
CLICK HERE for a copy of the letter
The Danger to State Boards
This silence should terrify every state board attorney in the country. Because here’s the reality:
Most state laws and rules explicitly name the NBCE exams, Parts I through IV, as the pathway to licensure. But those references were made when Part IV was regionally administered, accessible from nearly every chiropractic college campus or nearby test center.
Now, NBCE is imposing a unilateral structural shift: centralizing the exam in Greeley, Colorado, beginning in 2026. No rulemaking. No public hearing. No state-level legal review. No AG opinions.
If state boards continue to enforce the use of NBCE Part IV under these radically altered conditions, they risk:
Acting ultra vires (beyond their lawful authority);
Violating due process by enforcing a new burden without notice or comment;
Running afoul of state administrative procedure acts;
And ultimately, becoming liable for litigation by affected students and graduates.
“The shift to a single-location, travel-required examination format represents a significant structural change that was neither envisioned nor authorized when these laws were originally enacted.”
FCLB: Funded by NBCE, Silent on Oversight
Why won’t the FCLB address this?
Because the FCLB’s operating budget is largely funded by the NBCE.
It has become an organization beholden to the very entity whose actions threaten to destabilize the licensure framework across all 50 states. And it shows. The FCLB has offered no guidance to boards. No position statement. No invitation to convene. No legal analysis.
Its silence is not neutral, it is protective. Of NBCE. And by extension, of the CCE, which enforces Policy 56 and its reliance on NBCE exam scores for accreditation.
What This Means for the Chiropractic Cartel
We are witnessing the collapse of regulatory accountability within the chiropractic profession.
NBCE changes national testing policy without oversight.
CCE refuses to intervene, while still using NBCE scores as its primary accreditation metric.
FCLB, funded by NBCE, won’t ask its member boards to review their laws.
And state boards, advised by attorneys who haven’t been briefed on the implications, continue to enforce statutes written for a completely different testing structure.
This is a textbook example of regulatory capture, and it places every board that enforces Part IV in its new form at serious legal risk.
“We respectfully request that the Federation provide information regarding whether any member boards have addressed these issues.”
—CFC Letter to FCLB
What Happens Next Is On the States
Let this be a warning to every chiropractic licensing board:
If you continue to require Part IV under its new centralized format without formal rulemaking, legal review, or public input, you are assuming the liability for NBCE’s actions.
The NBCE won’t defend your statute in court. The FCLB certainly won’t. And the CCE will hide behind Policy 56.
You’re on your own.
