Jill C Carnahan

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 Colorado. It is not legal advice.

In the Matter of:
Jill C Carnahan
License No. [LICENSE NUMBER, IF KNOWN]
400 S. McCaslin Blvd, Suite 210, Louisville, Colorado, 80027
NPI (public registry): 1649284811

I. INTRODUCTION

Complainant respectfully submits this complaint to the Colorado Medical Board requesting formal investigation and regulatory review concerning Jill C Carnahan (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 DAN Defeat Autism Now, Functional Medicine, root causes of their symptoms, Integrative Holistic Medicine, Read more, and Functional Medicine for 'root cause' diagnosis, that may extend beyond the M.D. scope in Colorado. 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.jillcarnahan.com/, https://www.aquatru.com/carafe and the public registry and license verification sources listed in the exhibit index below.

II. STATEMENT OF FACTS

A. Licensure

Public content appears to address DAN Defeat Autism Now, which the cited rule text suggests may fall outside the M.D. scope in Colorado. Public content appears to address Functional Medicine, which the cited rule text suggests may fall outside the M.D. scope in Colorado. Public content appears to address root causes of their symptoms, which the cited rule text suggests may fall outside the M.D. scope in Colorado. Public content appears to address Integrative Holistic Medicine, which the cited rule text suggests may fall outside the M.D. scope in Colorado. Public content appears to address Read more, which the cited rule text suggests may fall outside the M.D. scope in Colorado. Public content appears to address Functional Medicine for 'root cause' diagnosis, which the cited rule text suggests may fall outside the M.D. scope in Colorado.

B. Marketing

Publicly posted content appears to make the following representation. QUOTE: "Functional Medicine". Publicly posted content appears to make the following representation. QUOTE: "uncover the root causes of their symptoms and find true...". Publicly posted content appears to make the following representation. QUOTE: "Trained in Integrative Holistic Medicine Board Certified - 2005". Publicly posted content appears to make the following representation. QUOTE: "She uses functional medicine help you find answers to the cause of your illness and the nutritional and biochemical imbalances that...".

C. Clinical Frameworks

Public content appears to address DAN Defeat Autism Now, which the cited rule text suggests may fall outside the M.D. scope in Colorado. Public content appears to address Functional Medicine, which the cited rule text suggests may fall outside the M.D. scope in Colorado. Public content appears to address root causes of their symptoms, which the cited rule text suggests may fall outside the M.D. scope in Colorado. Public content appears to address Integrative Holistic Medicine, which the cited rule text suggests may fall outside the M.D. scope in Colorado. Public content appears to address Read more, which the cited rule text suggests may fall outside the M.D. scope in Colorado. Public content appears to address Functional Medicine for 'root cause' diagnosis, which the cited rule text suggests may fall outside the M.D. scope in Colorado.

D. Funnel

Public materials appear to link to AquaTru (other); the vendor's public materials describe provider compensation for such links. Public materials appear to describe the following consultation and monetization structure: Promotes 1 commerce partner(s); compensation model not yet established. Kickback/affiliate signals on 1 source(s).

E. Storefront

Public materials appear to link to AquaTru (other); the vendor's public materials describe provider compensation for such links.

F. Testimonials

Public materials appear to link to AquaTru (other); the vendor's public materials describe provider compensation for such links.

G. Complainant's Own Experience

[DESCRIBE YOUR OWN EXPERIENCE, IF ANY]

III. AREAS OF CONCERN

COUNT I: PRACTICE BEYOND THE LICENSED SCOPE

Cited authority: the state's medical practice act and board advertising rules.

The public materials described in the Statement of Facts above appear to address DAN Defeat Autism Now, Functional Medicine, root causes of their symptoms, Integrative Holistic Medicine, Read more, and Functional Medicine for 'root cause' diagnosis, which the cited rule text suggests may fall outside the M.D. scope.

The conduct described above raises substantial concerns under the state's medical practice act and board advertising rules and warrants Board investigation.

COUNT II: ADVERTISING AND PUBLIC REPRESENTATION CONCERNS

Cited authority: the state's medical practice act and board advertising rules.

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

The conduct described above raises substantial concerns under the state's medical practice act and board advertising rules 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