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Licensing Board Complaints: Tips for Those Considering Whether to Report
At some point, many victims of therapy abuse will consider filing a licensing board complaint against
their offending therapist. This option presents as a "no-brainer" for some and a subject of considerable
uncertainty and even anxiety for others.
The decision to report is personal. There are many variables to assess: our emotional needs and
stamina, our willingness to engage in a process with unknowns, the potential for personal harm or
backlash, how we believe it might affect us emotionally, and more. Some choose not to report. Many
who do report find that the process of preparing and submitting a formal complaint is crucial to their
healing.
Licensing boards use reports from citizens as a means of protecting the public from substandard
practices by licensed professionals. In the case of therapy abuse, the system can disappoint: boards
may be slow to act, and their judgments may seem inadequate. People who report abuses may be
passionate about preventing others from being harmed, but they may have other motives too, such as
the desire for justice, to see their abusers held accountable, to be heard, to honor their own pain, and to
achieve closure. All of these are valid.
Following is a list of things to consider when deciding whether to file a board complaint. For those who
have already filed, these prompts may help you check in with your emotions and expectations of the
process.
Note that licensing boards operate differently in different venues and for different specialities. Any
suggestions here should be reviewed with the agency at which the complaint will be filed.
Initial Reminders
- Licensing bodies exist to police licensed professionals and protect the public. They are not
designed to serve individual victims or address their injuries.
- The person being accused has legal rights. Even if you believe the offending therapist has done
grievous harm and must be punished (e.g. have their license revoked), a licensing board is
required to give the accused due process.
- Your written complaint will be shared with the person you are reporting.
- A licensing board complaint is only one option for holding your abuser accountable. You may
choose to work with a lawyer to pursue a civil suit or other actions. If your abuser is a member
of a professional association, is a member of the clergy, and/or is affiliated with an agency or
institution, you may be able to file complaints with those groups. In the case of a criminal
offense, you may opt to contact law enforcement.
Potential Benefits of Reporting
Exposing your abuser. By filing a formal complaint, you will be forcing your abuser to face agents of
authority. This will be a harsh experience for someone who is accustomed to working in the shadows,
controlling others, and operating by their own rules.
Demonstrating that you have changed. Filing a complaint will announce to your abuser that "the jig is
up," and you are no longer under their control. Further, it will make clear that your positive qualities,
such as compassion, loyalty, or conscientiousness, are no longer available for their exploitation.
Validating your story for yourself. Composing a complaint requires you to establish a timeline, trace any
grooming that took place, identify boundary violations, and gather evidence. The process clears the
clutter and brings the abuse into focus. This can be highly validating, especially for victims who have
been conditioned to doubt themselves or blame themselves for their abusers' inappropriate behaviors.
Performing a public service. You are doing something quietly heroic by informing the authorities that
one of their licensees has exploited a patient and by documenting that claim. Although the system may
not function as well as we hope, you will have done your part to prevent at least one practitioner from
preying upon others. You will also be adding to the body of evidence on abuse in therapy-related
professions.
Considering your future self. It is normal to feel conflicted about reporting early in your recovery. If
possible, consider how you will feel years, even decades, later if you do report versus if you choose not
to. In cases where the risks are minimal or tolerable, it is very likely that you will look back and be glad
you had the courage to report.
Fears about Reporting
Fear of retaliation. Fear of backlash or personal harm is a very common impediment to reporting. This
may be a realistic risk and should be considered carefully. At the same time, a knee-jerk fear response
may be a remnant of the power imbalance at the root of therapy abuse. Typically, violators respond to
accusations by denying any wrongdoing and trying to cast doubt on their victims.
Fear of being judged by future therapists. A qualified, ethical therapist has no reason to be suspicious of
a new client or patient who presents with an abuse story. Anyone searching for a new therapist after
abuse should raise this issue during the initial contact to make sure there is no hesitation or conflict.
There is no sense in beginning work with a therapist with whom you feel you cannot be honest and
authentic.
Concerns about privacy. Licensing boards should protect your privacy including your identity as well as
the nature and content of your complaint. Most licensing boards will identify you only as, e.g., "Patient
A." There will be no formal public record of your complaint unless and until there is a guilty judgment.
This record would include the name of the abuser, the violation(s), and the disciplinary measures, but
nothing that identifies you. Remember, though, that your abuser will receive a copy of your complaint,
which will include your name, and there is no guarantee that this will not lead to a breach.
Fear of damaging the abuser's career (or reputation, or marriage, or family or social life, or...). Many
victims are conditioned to believe they are responsible for what took place or indebted to their abuser in
some way. A victim who is concerned about ruining the abuser's career, marriage, etc. may be feeling
the residual effects of this manipulation. It is exceedingly unlikely that an abuser was leading an
impeccable life until crossing boundaries with you. Because it is always the responsibility of the
professional to set and maintain safe and therapeutic boundaries, the negative consequences of
abusers' behaviors are entirely self-inflicted.
Fear of prolonged grief. Preparing a complaint can be arduous and stir up difficult feelings and
memories. After submitting, you may be asked for an interview. Following that, however, you may hear
very little unless and until there is a hearing, which may take a year or more to come about. During this
time, it will be important for you to focus on your own healing and leave the board to do its job.
Remember that, over time, most victims find that reporting their abusers helps their healing regardless
of the outcome.
Emotional Readiness
Knowing when you are ready. If you try to act too soon, your emotions may be too raw and the process
too painful. Many victims struggle with misplaced affection or compassion for their abusers and the
cognitive dissonance that comes with discovering they have been exploited. Taking some time will allow
you to settle into your healing, gain some objectivity, rebuild your confidence, and discern what you
need from this process. (Most licensing bodies do not impose time limits within which a victim must file.
The same is not true for civil cases for which statutes of limitations may apply.)
Trust that you will evolve. It is not necessary to feel completely healed to begin the process. As long as
you have the objectivity to report honestly and fully, and can manage the task without being overcome
by difficult emotions, you may be ready. Telling your story is one of the keys to healing, and preparing a
complaint for the licensing board is a potent opportunity. With time, you will be better able to distance
yourself from the abuse. Feelings that confuse you now, such as residual compassion for your abuser,
self-doubt, and self-blame, will fade. By the time your case is resolved, you may no longer feel like the
person you were when you fell prey to your abuser.
Begin with Some Research
Learn about the licensing body's processes. As you consider whether to report, or if you are ready, visit
the appropriate licensing board's website and explore every relevant section. Specifically:
- Read the terms that apply to your abuser's license (e.g. Mental Health Counselor, Psychologist,
Social Worker). Note the specific standards that must be violated to meet the criteria for
disciplinary action.
- Locate the online complaint form; consider what you will be asked to provide and what
procedures you must follow.
- Read about the enforcement process and how complaints are handled.
- Look for the section listing disciplinary actions. Search for your abuser's name to see if there
have been previous judgments. Also read sample entries in the relevant licensing category (e.g.
Mental Health Counselor, Psychologist, etc.) to see what information is typically offered to the
public.
Call the licensing board directly. Identify yourself as a potential complainant and ask to speak to
someone who can answer specific questions. Consider asking:
- Is the complainant's privacy protected?
- Is any deadline in effect? How long can you wait to file?
- What process is followed when a complaint is submitted? What are the stages? What is the
typical timeline?
- Can you expect to be interviewed at the start?
- Will you be informed of progress along the way or only at the conclusion?
- Do they classify cases based on severity?
- What determines whether there will be a hearing? What procedure will be followed if you are
asked to testify?
- At the conclusion of the process, will you be given any personal feedback, or will you see only
what is posted publicly?
- Who will be involved in the process (e.g. investigator and prosecutor)? Will you be permitted to
have contact with them?
Learn about other options. Remember that you may be able to report your abuser to other groups, such
as professional associations, churches, and agencies where they are employed. As you weigh the pros
and cons of a licensing board complaint, consider researching these options, as well.
Consider involving a lawyer. It is not necessary to use a lawyer to file a licensing board complaint.
However, you may wish to consult a lawyer for help composing the complaint, for advice on strategy, or
if you have concerns about privacy, protecting yourself, etc. If you are working with a lawyer on a civil
suit or other legal action, you should discuss how the board report will fit into the overall strategy. (Be
clear with your attorney if you want to retain the right to file a licensing board or other complaint or are
willing to forgo that right as a condition of a civil settlement.)
Practical Suggestions for the Written Complaint
- Remember that the complaint will be shown to the person you are accusing.
- Consider writing an introduction in which you offer to cooperate as necessary, such as speaking
to investigators, testifying in a hearing, providing evidence, providing contact information for
witnesses, etc.
- Present your story chronologically.
- For ease of reading, consider a bulleted format or headings with subheadings. If your story is
long, and/or falls into phases (e.g. a grooming phase, violations in therapy, continued abuse
after therapy), consider dividing the text into sections for each phase.
- Match your experience to the specific violations that are subject to discipline for your abuser's
license. Consult the licensing board's website for this information, and use their language to
present the abuses you experienced.
- Keep your narrative direct and as brief as possible. Provide just enough detail to establish that
standards were violated.
- Avoid emotional language. Strive for an objective tone.
- Do not include copies of texts, phone messages, etc., unless directed to do so. Instead, note in
parentheses that you can provide evidence.
- If the complaint involves other people, e.g., other victims, witnesses, family members,
colleagues, etc., do not give their names. Instead, note that you can provide names and contact
information upon request.
- Print your complaint, make a copy for your records (paper or digital), and submit the paper copy
through a traceable delivery service, such as Certified Mail, as well as online if requested.
Online submission alone may not provide a secure record for future reference.
While Waiting
Adopt reasonable expectations. It is natural to wish for a swift response and full justice. In reality, the
process may be very slow, and the outcome may be disappointing. If so, remind yourself that this is
absolutely not a reflection of you, your worth, or the validity of your case. You have taken the socially
and personally responsible and correct action.
Practice self care. After filing, it may help to put the subject to the side of your thoughts and focus on
things you can control that will advance your healing. Eat well, exercise, and get enough sleep.
Meditate or engage in a spiritual practice. Continue reaching out to TELL and other support systems.
Read and learn, write or create, and invest in important relationships. In short, do anything and
everything you can to give yourself the loving care that you deserve.
Nancy Daley
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