Todd Vincent Farney

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 Tennessee. It is not legal advice.

In the Matter of:
Todd Vincent Farney
License No. [LICENSE NUMBER, IF KNOWN]
101 Bass Drive, Columbia, Tennessee, 38401-2433
NPI (public registry): 1336249143

I. INTRODUCTION

Complainant respectfully submits this complaint to the TENNESSEE BOARD OF CHIROPRACTIC EXAMINERS requesting formal investigation and regulatory review concerning Todd Vincent Farney (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 Chronic Fatigue, Most chronic fatigue protocols do not work, Pycnogenol acts as an anti-diabetic agent, Digestive concerns like bloating, IBS, or reflux, Thyroid and adrenal dysfunction, and Autoimmune and inflammatory conditions, that may extend beyond the D.C. scope in Tennessee.

Public registry records associate the Respondent's licensure with Kansas, while the practice location described in the public materials is in Tennessee. This complaint is directed to the board for the state where the practice is publicly advertised. The licensing authority in Kansas may also accept a complaint concerning the same conduct.

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.youtube.com/watch?v=XjiqtBztLQM, https://functionalhealthtn.com/ 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 represent that \"A high HRV means you're adapting well to stress and you have resilience. A low HRV means you're having a poor recovery and you're not adapting well to stress.\" The same content appears to state, \"The average HRV that you should have um in order to have good resilience is above 30.\" Other public representations appear as \"Functional Health Solutions\" and \"Cardio & HIIT strategies that boost HRV.\"","B. Scope of Practice Concerns":"Public content appears to address interpreting HRV as a marker of resilience and poor recovery in a quasi-diagnostic manner, setting a target HRV threshold as a wellness benchmark, and frameworks described as Functional health, underlying imbalance, Functional Medicine, and Complex Chronic Illness. Public content also appears to address Digestive Health, Immune System Support, root-cause treatment for previously treatment-resistant cases, gut, immune, and chronic health concerns, Functional Medicine for Complex Chronic Illness, Root-Cause Treatment for Gut and Immune Issues, and Functional Lab Testing. The applicable licensing rules are cited as suggesting that these subjects or approaches may fall outside the D.C. scope in Tennessee.","C. Complainant's Own Experience":"[DESCRIBE YOUR OWN EXPERIENCE, IF ANY]"}

III. AREAS OF CONCERN

COUNT I: PRACTICING BEYOND THE LAWFUL SCOPE OF CHIROPRACTIC

Cited authority: T.C.A. Section 63-4-101 and Rule 0260-02-.02.

The public materials described in the Statement of Facts above appear to address Chronic Fatigue, Most chronic fatigue protocols do not work, Pycnogenol acts as an anti-diabetic agent, Digestive concerns like bloating, IBS, or reflux, Thyroid and adrenal dysfunction, Autoimmune and inflammatory conditions, Mold Illness: The Hidden Factor Behind Persistent Symptoms, Interpreting HRV as a marker of resilience and poor recovery in a quasi-diagnostic way, Setting a target HRV threshold as a wellness benchmark, Functional health / underlying imbalance framework, Functional Medicine, and Complex Chronic Illness, which the cited rule text suggests may fall outside the D.C. scope.

The conduct described above raises substantial concerns under T.C.A. Section 63-4-101 and Rule 0260-02-.02 and warrants Board investigation.

COUNT II: DECEPTIVE AND MISLEADING CONDUCT

Cited authority: Rule 0260-02-.13(1) and T.C.A. Section 63-1-123.

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 Rule 0260-02-.13(1) and T.C.A. Section 63-1-123 and warrants Board investigation.

COUNT III: MISREPRESENTATION OF PROFESSIONAL STATUS AND TITLE

Cited authority: Rule 0260-02-.03.

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 Rule 0260-02-.03 and warrants Board investigation.

COUNT IV: EXCESSIVE EXAMINATIONS AND TREATMENT

Cited authority: Rule 0260-02-.13(5) and 0260-02-.13(6).

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 Rule 0260-02-.13(5) and 0260-02-.13(6) and warrants Board investigation.

COUNT V: USE OF UNLICENSED ASSISTANTS

Cited authority: Rule 0260-02-.13(9).

The conduct described above raises substantial concerns under Rule 0260-02-.13(9) 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.
6. Public registry records also associate the licensure with Kansas; consider sending a copy of this complaint to that state's board as well.

EXHIBIT INDEX