Heather Fay

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:
Heather Fay
License No. [LICENSE NUMBER, IF KNOWN]
Kansas Functional Medicine
NPI (public registry): 1366803157

I. INTRODUCTION

Complainant respectfully submits this complaint to the Kansas State Board of Healing Arts requesting formal investigation and regulatory review concerning Heather Fay (the Respondent), practicing through Kansas Functional Medicine.

The public materials reviewed appear to present representations concerning the identification and management of health conditions, including Functional medicine can address autoimmune diseases, Functional medicine can address hormonal imbalances and hormone replacement, Functional medicine can address chronic fatigue and metabolic issues, Chronic Fatigue and Low Energy Levels, Autoimmune diseases, and Diagnosing and treating autoimmune diseases (systemic internal disease), that may extend beyond the DC scope in Kansas.

Public registry records associate the Respondent's licensure with Missouri, while the practice location described in the public materials is in Kansas. This complaint is directed to the board for the state where the practice is publicly advertised. The licensing authority in Missouri 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://kansasfunctionalmedicine.com/, https://us.fullscript.com/welcome/kfm-ae5668bc-9224-4060-9fe5-32e711bd6dbd, https://www.designsforhealth.com/u/heatherfay and the public registry and license verification sources listed in the exhibit index below.

II. STATEMENT OF FACTS

A. Scope of Practice Concerns

Publicly accessible content appears to address the application of functional medicine to address autoimmune diseases, hormonal imbalances, hormone replacement, chronic fatigue, and metabolic issues, which the applicable licensing rules suggest may fall outside the DC scope in Missouri. Public content further appears to address chronic fatigue and low energy levels, autoimmune diseases, and the diagnosis and treatment of systemic internal disease and systemic conditions, which the applicable licensing rules suggest may fall outside the DC scope in Missouri. Additional public content appears to address functional medicine for autoimmune diseases, hormone replacement and imbalance treatment, hormonal imbalances causing hot flashes and night sweats, and metabolic issues, which the applicable licensing rules suggest may fall outside the DC scope in Missouri. Public content also appears to address the use of detoxification protocols by functional medicine to treat disease, which the applicable licensing rules suggest may fall outside the DC scope in Missouri.

B. 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 Functional medicine can address autoimmune diseases, Functional medicine can address hormonal imbalances and hormone replacement, Functional medicine can address chronic fatigue and metabolic issues, Chronic Fatigue and Low Energy Levels, Autoimmune diseases, Diagnosing and treating autoimmune diseases (systemic internal disease), Diagnosing and treating chronic fatigue (systemic condition), Functional Medicine for Autoimmune Diseases, Hormone Replacement/Imbalance Treatment, Hormonal Imbalances Causing Hot Flashes and Night Sweats, Metabolic issues, and Functional medicine uses detoxification protocols to treat disease, 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 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.
6. Public registry records also associate the licensure with Missouri; consider sending a copy of this complaint to that state's board as well.

EXHIBIT INDEX