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Reporting Impaired Practitioners

When is it appropriate for a state licensing board to file an Adverse Action Report with the NPDB on an impaired practitioner who is seeking treatment? The impairment can arise as a result of a physical or mental illness, injury, incapacitation, or alcohol or drug abuse.

The board should file an Adverse Action Report under the following circumstances:

  • Rather than discipline the practitioner, the board issues an order that includes an agreement that the practitioner will not practice. An enforceable agreement not to practice, signed by the board, is reportable.
  • The board takes an adverse licensing or certification action, and the practitioner enters a treatment or rehabilitation program for drug or alcohol abuse as a result. The adverse action must be reported, but the board should not report the fact that the practitioner entered a drug or alcohol treatment program.
  • The board allows a practitioner to put his or her license into "inactive status," or to voluntarily agree not to practice while under investigation or in exchange for not conducting an investigation. This is, in effect, a voluntary surrender or resignation of a license that must be reported.

The board should not file an Adverse Action Report under these circumstances:

  • The practitioner enters a substance abuse treatment program, and the board knows about it. However, the board does not enter into an agreement with the practitioner that the practitioner not practice while in the program, nor does it take any other action regarding the practitioner.
  • The practitioner voluntarily surrenders a license or certification due to personal reasons such as illness, and the practitioner is not under investigation the license or certification is surrendered.
  • The practitioner enters a treatment or rehabilitation program and agrees with the treatment or rehabilitation program not to practice while in the program. There is not a separate written agreement between the practitioner and the board that restricts the practitioner's ability to practice.
  • The practitioner voluntarily enters a treatment or rehabilitation program at the direction of or suggestion of the licensing board - initiated either by the board or the practitioner - and the board does not take a formal adverse action.

Additional information is available in the NPDB Guidebook's section on reporting state licensure and certification actions.


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