Sarah Drake

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.

In the Matter of:
Sarah Drake
License No. [LICENSE NUMBER, IF KNOWN]
Drake Chiropractic
913-708-0867 LOCATION 2722 N 155th Street, Basehor, Kansas, 66007
NPI (public registry): 1871974675

I. INTRODUCTION

Complainant respectfully submits this complaint to the Kansas State Board of Healing Arts requesting formal investigation and regulatory review concerning Sarah Drake (the Respondent), practicing through Drake Chiropractic, 913-708-0867 LOCATION 2722 N 155th Street, Basehor, Kansas, 66007.

The public materials reviewed appear to present representations concerning the identification and management of health conditions, including Dealing with inflammation or autoimmune tendencies, Implying treatment for chronic fatigue and systemic inflammation, When this area is misaligned, it can trigger a cascade of nervous system dysfunction, functional lab testing, food sensitivity evaluations, and dry needling, that may extend beyond the DC scope in Kansas.

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 http://www.drakechiroandrehab.com/ and the public registry and license verification sources listed in the exhibit index below.

II. STATEMENT OF FACTS

A. Licensure and Business Operations

Public materials state the credentials DR, Chiropractor (DC), and the public registry record lists DC.

B. Scope of Practice Concerns

Public content appears to address dealing with inflammation or autoimmune tendencies, implying treatment for chronic fatigue and systemic inflammation, and stating that when this area is misaligned, it can trigger a cascade of nervous system dysfunction, all of which the cited rule text suggests may fall outside the DC scope in Kansas. Public content also appears to address functional lab testing, food sensitivity evaluations, dry needling, Graston Technique, kinesiotaping, and diagnosing internal symptoms with functional lab testing and food sensitivity evaluations, which the cited rule text suggests may fall outside the DC scope in Kansas. Public content further appears to address Upper Cervical Specific care for migraines, vertigo, neurological concerns, and fatigue, as well as pediatric chiropractic for colic, reflux, ear infections, and developmental delays, which the cited rule text suggests may fall outside the DC scope in Kansas, and the cited rule treats these as gray areas.

C. 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 Dealing with inflammation or autoimmune tendencies, Implying treatment for chronic fatigue and systemic inflammation, When this area is misaligned, it can trigger a cascade of nervous system dysfunction, functional lab testing, food sensitivity evaluations, dry needling, Graston Technique, kinesiotaping, Diagnosing internal symptoms with functional lab testing and food sensitivity evaluations, Upper Cervical Specific care for migraines, vertigo, neurological concerns, and fatigue, and Pediatric chiropractic for colic, reflux, ear infections, developmental delays, which the cited rule text suggests may fall outside the DC 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 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 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 stated credentials also appear to differ from the credential listed in the public registry record.

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