Delegation at a Savannah Clinic: Ultrasound, Adjustments, and a Front-Desk Aide

The core problem is that Marcus is unlicensed and untrained, yet he performed acts that fall within chiropractic practice. Under Georgia law, chiropractic includes diagnosis and treatment of human ailments by adjustment or manipulation of the spine and extremities, plus recognized ancillary modalities. Spinal adjustment is a licensed chiropractic act and cannot be delegated to an unlicensed aide. Even if a properly trained chiropractic assistant may apply ultrasound under supervision, the assistant must have documented training and the chiropractor must provide the level of supervision required by Board rule. 'Direct supervision' generally means the supervising chiropractor is on the premises and immediately available, not merely reachable by phone 15 minutes away. The patient's osteoporosis and vertebral artery history make cervical manipulation especially risky; Dr. Marsh also failed to screen and document contraindications. Phone availability does not cure the delegation problem. The Board can characterize this as aiding unlicensed practice, gross negligence, and unprofessional conduct, and Dr. Marsh remains responsible for the aide's acts within her clinic.

A Georgia chiropractor holds a Doctor of Chiropractic degree, not a medical degree, and the title 'physician' can be misleading unless it is clearly qualified and accurate under Board advertising rules. The phrase 'chiropractic physician' may imply medical licensure or a broader scope than the licensee actually has. 'Physical therapy services' is likewise a protected professional description associated with licensed physical therapists. A chiropractic office may provide chiropractic ancillary procedures, but it may not hold itself out as providing physical therapy unless the services are lawfully supervised or provided by an appropriately licensed physical therapist. The Board examines the overall impression created by the advertisement, not just isolated words. Combined with the unlicensed aide's activities, the website statements support a false or misleading advertising allegation. The clinic should correct the website, describe services accurately, and ensure any modality is within chiropractic scope and properly supervised.

Georgia administrative discipline is governed by the Administrative Procedure Act and the Board's enabling statute. Dr. Marsh is entitled to notice of the specific charges, a hearing before an impartial Board or hearing officer, the right to counsel, the right to present evidence and witnesses, the right to cross-examine the Board's witnesses, and a written decision supported by the record. An emergency or summary suspension is extraordinary and should require a showing of immediate danger to the public. Even then, Dr. Marsh is entitled to a prompt post-deprivation hearing; the emergency power cannot replace the full hearing. If the Board imposes sanctions, it must consider the evidence and explain the basis. Dr. Marsh may appeal the final agency decision to the superior court under Georgia law. Because the facts involve patient harm and unlicensed activity, the Board may also seek an injunction or refer the matter for criminal prosecution.