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This template is intended for residents or patients of Kansas. The complaint you submit is your own. It is not legal advice.

Jonah Yakel

Kansas State Board of Healing Arts

Hedged asks the board to investigate. Assertive states the concern as a would-be violation. The same facts and exhibits are used either way.

Download document (hedged)

Complaint template prepared from a public-record review by drtrustmebro.com. The complaint you submit is your own; review and edit every statement before signing. This template is intended for residents or patients of Kansas. It is not legal advice.

KANSAS STATE BOARD OF HEALING ARTS
FORMAL COMPLAINT REQUESTING INVESTIGATION AND REVIEW

In the Matter of:
Jonah Yakel
License No. [LICENSE NUMBER, IF KNOWN]
NPI (public registry): 1619145026

I. INTRODUCTION

Complainant respectfully submits this complaint to the Kansas State Board of Healing Arts requesting formal investigation and regulatory review concerning Jonah Yakel (the Respondent), identified in the attached public materials.

The public materials reviewed appear to present representations concerning the identification and management of health conditions, including Mold exposure root-cause style counseling, that may extend beyond the D.C. scope in Kansas. The materials also appear to describe paid consultations, care plans, or product sales offered in connection with those representations.

This complaint is based exclusively upon publicly available materials and does not rely upon confidential patient records, privileged communications, or non-public investigative information. The factual observations herein were assembled from an automated public-record review of the Respondent's public website and public registry records, and were reviewed and adopted by the Complainant. All observations are potential, unverified signals from public records; the Board is the sole finder of fact.

The principal public materials reviewed include https://www.facebook.com/photo.php?fbid=1216039470204576&set=a.533674328441097&type=3 and the public registry and license verification sources listed in the exhibit index below.

II. STATEMENT OF FACTS

A. Public Marketing Representations

Publicly posted content appears to make the following representations: "Mold in our living environments can do more than just damage our homes, it can harm our brains." It further states, "Prolonged exposure to mold releases mycotoxins, which are toxic substances that can lead to a range of neurological issues, including cognitive decline," and, "When you breathe in air contaminated with mold spores, these toxins can enter your bloodstream and make their way to your brain, causing inflammation and disrupting normal brain function." The same public content also advises, "Inspect your home regularly for signs of mold, especially in damp areas."

B. Scope of Practice Concerns

Public content appears to address Mold exposure root-cause style counseling, which the cited rule text suggests may fall outside the D.C. scope in Kansas.

C. Consultation and Monetization Structure

Public materials appear to describe the following consultation and monetization structure: Kickback/affiliate signals on 1 source(s).

D. Complainant's Own Experience

[DESCRIBE YOUR OWN EXPERIENCE, IF ANY]

III. AREAS OF CONCERN

COUNT I: PRACTICE BEYOND THE LICENSED SCOPE

Cited authority: Kansas Healing Arts Act, K.S.A. 65-2801 et seq. and K.S.A. 65-2836(g).

The public materials described in the Statement of Facts above appear to address Mold exposure root-cause style counseling, which the cited rule text suggests may fall outside the D.C. scope.

The conduct described above raises substantial concerns under Kansas Healing Arts Act, K.S.A. 65-2801 et seq. and K.S.A. 65-2836(g) and warrants Board investigation.

COUNT II: CHRONIC-CONDITION FUNCTIONAL MEDICINE ADVERTISING AND REPRESENTATIONS

Cited authority: K.S.A. 65-2837(b)(12), 65-2837(b)(13), and 65-2871.

The public marketing representations and testimonials described above appear to present the practice's services without consistently identifying the limits of the D.C. scope or the practitioner's credentials.

The conduct described above raises substantial concerns under K.S.A. 65-2837(b)(12), 65-2837(b)(13), and 65-2871 and warrants Board investigation.

COUNT III: FUNCTIONAL LABORATORY TESTING AND HEALTH-PLANNING REPRESENTATIONS

Cited authority: K.S.A. 65-2837(b)(1) and 65-2836(g).

The public materials described above appear to present condition-specific frameworks, laboratory-testing guidance, and treatment protocols directed at systemic conditions, rather than services grounded in the licensed scope.

The conduct described above raises substantial concerns under K.S.A. 65-2837(b)(1) and 65-2836(g) and warrants Board investigation.

COUNT IV: SUPPLEMENT-INTEGRATED FUNCTIONAL MEDICINE AND COMMERCIAL PRACTICE STRUCTURE

Cited authority: K.S.A. 65-2837 and 65-2871.

The consultation and product-sales structure described above appears to tie the health-related representations to paid consultations, care plans, and product sales offered to the same audience.

The conduct described above raises substantial concerns under K.S.A. 65-2837 and 65-2871 and warrants Board investigation.

COUNT V: UNPROFESSIONAL CONDUCT

Cited authority: K.S.A. 65-2836 and 65-2837.

The public representations described above appear capable of conveying to consumers a level of clinical authority beyond the licensed scope.

The conduct described above raises substantial concerns under K.S.A. 65-2836 and 65-2837 and warrants Board investigation.

IV. RELIEF REQUESTED

A. Formal investigation of the conduct described herein, including review of the Respondent's public advertising, website representations, consultation materials, and commercial structures.

B. A determination by the Board of whether the conduct described herein is consistent with the statutes and rules cited above.

C. Such disciplinary action as the Board deems appropriate based on its own investigation and findings, up to the maximum authorized for any violation the Board finds.

D. Corrective relief, where the Board deems appropriate, including requiring the Respondent to correct or remove the specific public representations described above and, if the conduct continues, seeking injunctive relief through a court of competent jurisdiction.

E. To the extent within the Board's authority, review of the revenues derived from the consultations, care plans, and product sales described above, and consideration of restitution for consumers who relied on the representations to their financial or physical detriment.

F. Such other and further relief as the Board deems just and proper to protect the public.

Respectfully submitted,

[YOUR NAME]

[YOUR MAILING ADDRESS]

[YOUR EMAIL AND PHONE]

[DATE]

EDIT BEFORE SENDING

  1. Confirm the license number using the license lookup in Exhibit A and fill it in on page 1.
  2. Replace every bracketed placeholder with your own information, or delete sections that do not apply.
  3. Print and attach dated captures of each exhibit page listed in the exhibit index.
  4. Review every factual statement yourself before signing; submit only what you can stand behind.
  5. Check the board's current submission rules (online portal, mail, or fax) before sending.

EXHIBIT INDEX

ExhibitDescriptionSourceArchived capture
Exhibit AState license verification printouthttps://ksbha.kansas.gov/verifications/[attach a printed, dated capture]
Exhibit BPractice homepagehttps://www.facebook.com/photo.php?fbid=1216039470204576&set=a.533674328441097&type=3[attach a printed, dated capture]

These templates are prepared from public records and are not legal advice. Every observation is a potential, unverified signal; the board is the sole finder of fact. Review and edit each statement before signing and submitting.