Reinstating A Not Renewed Or Inactive Chiropractic Physician License

Introduction

The Medical Practice Act and Rules list requirements for bringing a license back to active status when a physician has not renewed during one or more previous three-year license cycles.  This process is called “reinstatement,” which means changing a non-disciplined, not renewed or inactive license back to active status.  Reinstatement is not the same as “restoration,” a completely different process that means removing a license discipline, such as probation, suspension, or revocation.  This article will review requirements for non-disciplinary license reinstatement;restoration from discipline will be addressed in a separate article. (For a list of disciplinary statuses that require a different activation procedure, see information provided at the end of this article.)

Because the requirements are very different for reinstatement and restoration, applicants should carefully confirm they are using the correct forms and procedure for reinstatement.  It is common to hear other terms, such as “reactivation,” used colloquially.   However, because the legal requirements for reinstatement and restoration are not the same, this article will use these terms according to their formal, legal definitions.

Status Categories For Licenses Not Under Current Discipline

Non-disciplined licenses fall into one of the following status categories:

• Active license – An active license is one that has been properly renewed prior to the current renewal cycle and is unrestricted (not under current discipline.)
• Not Renewed license – A not renewed license is simply a license that the holder has not renewed by its expiration date. (The Medical Practice Act rules now use the term “not renewed” to replace the previous “non-renewed.”) If you take no action at renewal time, your license will automatically be “not renewed,” a non-disciplinary status.  Not renewed licenses may also be informally called “expired or lapsed,” and practice is prohibited. If you seek to renew, you will have to pay lapsed renewal fees and penalty fees.
• Inactive license – An inactive license is a license that has been voluntarily placed in inactive status (non-disciplinary) by request of the licensee, usually at renewal time.  As in not renewed status, practice is prohibited. If you seek to reinstate your inactive license, fees are less than those for reinstatement of a not renewed license.

As noted, non-disciplined licenses that are not in active status are either in not renewed status or inactive status. Both are eligible for reinstatement.  The same steps are required when applying to reinstate either a not renewed or inactive license; the only difference is the amount of fees, as outlined above.

Note:  Illinois does not have an official “retired” status.  Physicians who no longer practice and do not renew are shown on the IDFPR website License Lookup as under not renewed status.  However, if the IDFPR is notified of the death of a licensee, the agency will show “Deceased” for informational purposes in the status field.

Note also that even if a license was at one time in not renewed or inactive status, it is not immune from discipline if the IDFPR believes the license holder has violated the Medical Practice Act. Therefore, before taking action to reinstate a license, confirm the status of your license on the IDFPR website.

What Do Regulators Consider In A Reinstatement Application?

Current competency is the primary concern for regulators when deciding whether to grant reinstatement.  Generally, if the license has been not renewed or inactive for less than 3 years, i.e., for less than one full license cycle, the license will be reinstated upon payment of the current renewal fee, completion of the physician profile, and proof of continuing education requirements for the last renewal period (i.e., the licensee must send the IDFPR copies of all formal continuing education certificates and the log of information continuing education).  However, if the license has been not renewed or inactive for more than 3 years, i.e., more than one full license cycle, the licensee will also need to demonstrate he/she has taken additional steps to prove current professional competency, as detailed below.  Thus, licensees who did not renew their licenses or who placed their licenses on inactive status during the previous renewal should carefully assess their situations and consider the ramifications of not renewing before the expiration of the current cycle.

Reinstatement Of Licenses That Have Been In Not Renewed Status Or Inactive Status For Less Than Three Years

Chiropractic physicians must submit a request to the IDFPR to email an application and instructions to the licensee.  The request form can be found here.  Note that at this time the IDFPR uses the term “Physician” to mean only medical or osteopathic physicians on this form.  Therefore, chiropractic physicians should not use the link for “Physician” on this page and should instead fill out and submit the request for a reinstatement application.

The application requires the reinstating chiropractic physician to provide to the IDFPR:

• A signed and dated request that includes:
  • Full name;
  • Illinois license number;
  • Last four numbers of Social Security Number;
  • Current address of record (registered address with the IDFPR)
  • Telephone number;
  • Current email address.
• A completed, signed and dated personal history questionnaire that includes (without limitation) disclosure of chronic diseases or conditions impairing the ability to practice, denial of professional license by licensing authority, criminal charges, conviction of criminal battery or forcible felony, or registration under the Sex Offender Registration Act.  If the answer to any of those questions is “yes,” the IDFPR will open an investigation to determine whether or not to reinstate the license, and the applicant may be called for an interview with the board.)

• Verification that the licensee is not delinquent in payment of child support, Illinois state taxes, or workers’ compensation obligations. If the answer to any of those questions is “yes,” the IDFPR will open an investigation to determine whether or not to reinstate the license, and the applicant may be called for an interview with the board.
• Documentation of continuing medical education (CME) as required by rule.  You are required to provide copies of certificates showing 60 hours of formal CME and a log showing 90 hours of informal CME (unlike renewing during the regular renewal period, which requires only the checking of a box to certify completion of required CME).  Note that CME will be applied only if it was taken within 3 years prior to reinstatement.  Example:  your license was not renewed by July 31, 2020.  You file for reinstatement on March 1, 2021.  You may not count any CME taken prior to March 1, 2018.  Additionally, you may not re-use the same CME courses toward your next renewal. For CME content requirements, see Medical Practice Act Rule Section 1285.110.
• The required fee.
• Complete the physician profile — see Medical Practice Act Rule Section 1285.305.

Update the profile here.

• Mail all required documentation and fee payment to:

Department of Financial and Professional Regulation
Division of Professional Regulation
320 West Washington Street, 3^rd Floor
Springfield, IL  62786

Note:  The only difference between reinstating from not renewed versus inactive status is that fees are less for licenses reinstated from inactive status. 

Reinstatement Of Licenses That Have Been Not Renwed Or Inactive For Three Years Or More

Physicians who wish to reinstate a license after it has been expired, not renewed, or been placed on inactive status for more than 3 years, are required to:

• Submit a request for a reinstatement application here.  Note that the IDFPR uses the term “Physician” to mean only medical or osteopathic physicians on this form.  Therefore, chiropractic physicians should not use the link for “Physician” on this page and should instead fill out and submit the request for a reinstatement application.  You will need to provide all information as outlined in the section above.  Complete the physician profile — see Medical Practice Act Rule Section 1285.305;
• Provide copies of certificates showing 150 hours of continuing medical education (unlike renewing during the regular renewal period, which requires only the checking of a box to certify completion of required CME).  For CME requirements, see Medical Practice Act Rule Section 1285.110;
• Pay required fees.
• A chiropractic physician is also required to submit one or more of the following to prove current professional capacity to practice safely. (Requirements are parallel but different for allopathic (medical and osteopathic) physicians.  This list is taken from Medical Practice Act Rule Section 1285.130 and includes those applicable to chiropractic physicians):
  1. Sworn evidence of active practice in another jurisdiction.  That evidence must include verification of employment and an official statement from the other jurisdiction within 3 years from the date of the application that the licensee was authorized to practice during the term of active practice.
  2. An affidavit attesting to military service as provided in Section 21 of the Act.
  3. Proof of successful completion of an approved postgraduate clinical training program of at least 12 months in length within 3 years from the date of application.
  4. For individuals applying for reinstatement of a chiropractic license, proof of completion of 30 credit hours (academic hours) in an accredited chiropractic program within 3 years from the date of application or the Special Examination for Chiropractic (SPEC) or its equivalent as approved by the Board. [Note:  The Medical Board may not consider SPEC sufficient on its own to prove current capacity.  See explanation below.]

Note that this rule is different than the one for new graduates who wait more than 2 years from graduation to apply for a license (Rules Section 1285.95).  The new graduate rule allows these applicants to submit research, many forms of training, publication of papers and clinical activities to prove current competency.  However, the rule for licensees who have been out of practice for 3 years or more is to instead count practice in another jurisdiction, military service, and/or 30 credit  hours in an accredited training program toward current competency. 

Although the rule lists passage of the Special Purpose Examination for Chiropractic (SPEC) as one type of proof of current competency, the Medical Board does not always accept those exams as adequate by themselves.  Depending on the duration of lack of practice, some chiropractic physicians who have not been in current practice in another jurisdiction or in military service have been required to complete an 30-credit-hour educational program  that meets the standards in Section 130 above, or pass the National Board of Chiropractic Examiners Examination Part IV (clinical skills), or both.  Also, because the 30-hour remedial programs are not routinely offered by most chiropractic colleges, applicants should communicate with the IDFPR prior to starting a program to gain as much assurance as possible that it meets with requirements.

The IDFPR may require a reinstatement applicant to appear for a Medical Licensing Board interview when the IDFPR has any questions about the information provided.  It is common practice for the Board to interview applicants who have been out of practice for 3 or more years to determine their current competency.  This an informal proceeding that takes place during the closed portion of the Board meeting.  The Board will review the licensee’s reinstatement application and documentation and ask questions to clarify the nature of the licensee’s activities or additional classroom hours.  The licensee is permitted to offer any relevant additional information to the Board.  At the conclusion, the Medical Licensing Board will make a recommendation as to whether an applicant meets the requirements to have his or her license reinstated, or, if not, the conditions the applicant will need to meet.

Fees For Reinstatement

Reinstatement fees are established in Section 21 of the Medical Practice Act. The IDFPR provides a fee calculator here.  (Important note:  this web page is to be used for fee calculation only under the category “Physician.”  Do not use this application form for reinstatement as it applies to medical and osteopathic physicians with license prefix 036.  Chiropractic physicians with license prefix 038 should use the procedure and forms as described above in this article.)

Reinstatement fees depend on whether a license was inactive or non-renewed and how many renewal cycles were missed.  The fees are now the same for both resident and non-resident licensees.

Fees for reinstatement are currently assessed as follows:

Date License Expired	Amount Due if Paid Prior to Next Renewal Period	Next Renewal Period Starts	If Paid by Renewal Start Date License Is Active Until	Amount Due after Renewal Start Date
7/31/2023	$773	5/1/2026	7/31/2026	$1,316
7/31/2020	$1,316	5/1/2026	7/31/2026	$1,400
7/31/2017	$1,400	5/1/2026	7/31/2026	$1,400
7/31/2014	$1,400	5/1/2026	7/31/2026	$1,400
7/31/2011	$1,400	5/1/2026	7/31/2026	$1,400

To complicate matters, when the medical professions are in the renewal period, any licensee who did not renew during the previous three-year cycle would be considered two cycles behind and would accrue an additional renewal fee, limited by the $1,400 cap.  

Bottom line: Inactive status is cheaper to reinstate. Non-renewed licenses often reach the $1,400 maximum, especially after a renewal period starts.

Conclusion

Circumstances may arise that make license renewal impossible during a particular period of any physician’s life.  However, if the doctor believes the situation is temporary and intends to continue to practice, it is clearly simpler to maintain an active license, if at all possible.  Licensees may complete online all continuing education required for renewal by taking courses from approved providers such as the ICS.  If a licensee cannot meet the requirements for routine renewal, he or she should remain informed of the professional capacity requirements in the Medical Practice Act and Rules, as they apply to any plans for reinstatement.   The ICS remains the premier resource for this type of profession-specific information for chiropractic physicians in Illinois. 

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Disciplinary Statuses

All of the statuses listed below are considered formal disciplines that are public, reflected on the IDFPR website, reportable to the National Practitioner Data Bank, and generally must be disclosed by a licensee on applications that ask whether the licensee has ever been disciplined.  A license that is in a disciplinary status may be activated only by filing a Petition for Restoration and following the restoration process.  The reinstatement process is not available for licenses under these status categories:

• Reprimand – An official record that the license has been disciplined, but allows the license status to remain active and allows the licensee continued unrestricted ability to practice.
• Probation – A sanction that permits the licensee to continue to practice, subject to certain terms and conditions for a period of time.
• Suspension – A sanction that means the licensee may not practice during the period specified in the IDFPR order.  
• Temporary Suspension – Several Illinois practice acts including medical, dental and pharmacy) give the Director of DPR authority to temporarily suspend a professional’s license prior to and pending a hearing before the appropriate board or committee, where the Director finds that a professional licensee must stop practicing immediately due to an immediate danger to the public.
• Revocation – A sanction that means the licensee may not practice indefinitely. 
• Permanent Revocation – A form of revocation that is permanent and for which the licensee has no right to file a petition to have the permanent revocation lifted.