Manipulation vs. Mobilization

By Adrienne Hersh, JD, ICS Legal Counsel · June 1, 20052 min read

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(Arkansas Supreme Court, April 2005) – The ICS has been watchful of attempts by other licensed professions to push the limits of their scope of practice into areas that are exclusive to the practice of chiropractic medicine. This case is a clear declaration by a state supreme court that spinal manipulation is exclusive to chiropractic medicine and is not within the scope of physical therapy. Teston is a licensed physical therapist who performed spinal manipulation on two patients.

The Arkansas State Board of Chiropractic Examiners filed a notice of hearing against Teston, alleging that he was practicing chiropractic medicine without a license. Subsequently, the Chiropractic Board conducted a hearing and found that, based on the hand positions and pressure used, Teston’s treatment constituted spinal manipulation that could only be performed by licensed chiropractic physicians.

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About the Author

Adrienne Hersh, JD, ICS Legal Counsel

Adrienne serves as Illinois Chiropractic Society general counsel and provides legal advice and support on a wide range of legal issues affecting chiropractic physicians, including licensing and other health care regulations, scope of practice, insurance and reimbursement, business structuring, labor and employment, contracts, and litigation. Adrienne previously served for 8 years as general counsel to the Illinois Department of Professional Regulation (now the Division of Professional Regulation, Department of Financial and Professional Regulation), where she was chief legal counsel responsible for overseeing all legal issues and advising the 50+ licensing and disciplinary boards, including the Medical Disciplinary Board and the Medical Licensing Board. She is a member of the Illinois State Bar Association Health Care Section, the Illinois Association of Healthcare Attorneys, and the National Association of Chiropractic Attorneys.