California Board of Occupational Therapy Attorney Fee Petition Mechanics: Tyler Odyssey Civil Complaint Date as Primary Welch Anchor, CBOT License Verification Database as Secondary Institutional Anchor (the Only California Board of Occupational Therapy License Database Anchor in this Series), CLRA § 1780 Mandatory Attorney Fees for Clients Harmed by Unlicensed Occupational Therapy Practice

Statutory Framework: Bus. & Prof. Code §§ 2570–2573.5 — CBOT License Requirements, Prohibited Conduct, and CLRA § 1780 Mandatory Attorney Fees for Unlicensed Occupational Therapy Practice

California Business and Professions Code § 2570.14 establishes the foundational licensing requirement for occupational therapy practice in California: no person may practice occupational therapy — or use the title "Occupational Therapist," "OT," "Occupational Therapy Assistant," or "OTA" — without first obtaining a current license issued by the California Board of Occupational Therapy. The CBOT OT license is issued only after the applicant completes a Master's degree or entry-level doctoral degree (MOT, OTD, or equivalent) in occupational therapy from an ACOTE-accredited OT program, six months of supervised fieldwork (Level II fieldwork), passage of the NBCOT OTR certification examination, compliance with California law and ethics examination requirements, and CBOT criminal background check and continuing education requirements for biennial license renewal. The CBOT OTA license requires an Associate's degree in occupational therapy from an ACOTE-accredited OTA program, two months of supervised Level II fieldwork, and passage of the NBCOT COTA examination. Both CBOT license types require that OT services be provided under the supervision of a CBOT-licensed OT — an OTA cannot independently practice occupational therapy without OT supervision, creating a supervising-OT liability dimension in cases involving unlicensed OTA practice.

Section 2570.14 makes unlicensed occupational therapy practice a criminal misdemeanor. Unlicensed OT practice manifests most frequently in three settings: (1) home health agencies that deploy medical assistants, home health aides, or individuals with foreign OT credentials (without CBOT licensure) to provide ADL retraining services to post-surgical or post-stroke patients in their homes — services that require CBOT licensure and physician order to qualify as OT for Medicare and Medi-Cal billing; (2) pediatric therapy clinics that employ individuals without CBOT licensure (or with lapsed CBOT licenses) to provide sensory integration therapy, play therapy, and school readiness skill-building to children with ASD and developmental disabilities — services marketed to parents as evidence-based "occupational therapy" that require CBOT licensure; and (3) skilled nursing facilities and assisted living communities that employ unlicensed aides to perform OT-scope ADL assessment and retraining services that are billed to Medicare and Medi-Cal as OT services rendered by a licensed OT or OTA — a billing fraud pattern that simultaneously creates CLRA § 1780 consumer fraud liability for the resident patient and False Claims Act exposure for the facility.

The CLRA civil remedy arises because occupational therapy services — whether provided in an acute care hospital, SNF, home health setting, outpatient clinic, or pediatric therapy center — are consumer services purchased for personal health care and daily living function needs, satisfying the definition of "consumer services" under Civil Code § 1761(b). Every OT service provider that presents itself to the public as a licensed occupational therapy service implicitly represents that its practitioners hold current CBOT licenses — a representation that constitutes a misrepresentation of service provider qualifications under Civ. Code § 1770(a)(14) when the practitioner lacks CBOT licensure. Section 1780(e) mandates: "the court shall award court costs and attorney's fees to a prevailing plaintiff in litigation filed pursuant to this section" — eliminating judicial discretion and establishing CLRA § 1780 as a pure mandatory fee statute for unlicensed OT practice claims.

Three Unique Distinctions in the Fee-Petition-Mechanics Series

• THE ONLY CBOT LICENSE VERIFICATION DATABASE anchor in the series — categorically distinct from the Physical Therapy Board License Database (which covers physical therapists and physical therapy assistants who provide movement-based rehabilitation) and all other healing arts board databases; the CBOT covers OTs and OTAs under a separate statutory licensing program with distinct ACOTE-accredited educational requirements, NBCOT national certification, and a distinct scope of practice focused on functional independence in daily activities rather than movement impairment remediation: the California Board of Occupational Therapy License Verification Database covers exclusively California-licensed occupational therapists (OTs) and occupational therapy assistants (OTAs) under Bus. & Prof. Code §§ 2570–2573.5, recording for each licensee: the CBOT license number; the licensee's full legal name; the license type (OT or OTA); the NBCOT credential (OTR or COTA); the license issue date; the license expiration date; the current license status (Active, Inactive, Suspended, Revoked, or Surrendered); and any public disciplinary actions; the CBOT database is separate from the Physical Therapy Board's license database under Bus. & Prof. Code §§ 2600–2697 — reflecting the distinct OT scope of practice (ADL retraining, upper extremity rehabilitation, cognitive rehabilitation, pediatric sensory processing) versus the PT scope of practice (gait training, therapeutic exercise, manual therapy, pain management); while OT and PT services are frequently ordered together in rehabilitation settings, they are separately licensed professions with separate CBOT and PTB licensing programs, separate ACOTE/CAPTE accreditation systems, and separate NBCOT/FSBPT national certification examinations; the CBOT database is THE ONLY CBOT license database anchor in the fee-petition-mechanics series
• THE ONLY page where unlicensed practice specifically harms POST-SURGICAL AND POST-STROKE REHABILITATION patients whose functional independence outcomes — measured by validated instruments including the Functional Independence Measure (FIM), Barthel Index, Canadian Occupational Performance Measure (COPM), and the Modified Rankin Scale — depend on evidence-based OT interventions by licensed practitioners trained in functional assessment and task-specific retraining methodology: the harm from unlicensed occupational therapy practice is not primarily physical injury but functional outcome harm — the patient who receives unlicensed "OT" services instead of genuine CBOT-licensed OT interventions does not obtain the evidence-based functional gains that BRL-licensed OT services would have produced; this functional outcome harm is documented through validated outcome measurement instruments: the Functional Independence Measure (FIM) — a 18-item scale measuring self-care, sphincter control, transfers, locomotion, communication, and social cognition, with each item scored 1–7 — that documents the difference between the functional level the patient would have reached with licensed OT and the functional level the patient actually reached with unlicensed "OT" services; the Canadian Occupational Performance Measure (COPM) — a client-centered outcome measure documenting the client's self-perception of performance and satisfaction in their identified occupation goals — that documents the gap between the occupational goals the client set for licensed OT and the goals actually achieved through unlicensed services; in post-stroke rehabilitation, the Barthel Index documents the specific ADL tasks (bathing, dressing, feeding, transfers, continence, stairs) in which the patient failed to achieve independence that a BML-licensed OT would have enabled; and the WeeFIM for pediatric patients documents the specific developmental ADL milestones that children with ASD or developmental disabilities failed to achieve through unlicensed pediatric OT services — outcome harms that are measurable, documentable, and directly attributable to the absence of evidence-based OT interventions by a CBOT-licensed practitioner
• THE ONLY page where billing fraud involves MEDICARE/MEDI-CAL-COVERED SERVICES requiring a physician order — creating a government records trail through CMS and Medi-Cal billing records that independently documents the unlicensed OT practice and creates parallel federal False Claims Act exposure for any unlicensed OT provider or institutional facility that billed Medicare or Medi-Cal for OT services rendered without a valid CBOT license: Medicare Part A and Part B cover occupational therapy services as a medically necessary rehabilitation service, subject to the requirement that services be provided by a licensed OT or OTA and that services be ordered by a physician or other qualified health professional; Medi-Cal covers OT services under the California Children's Services (CCS) program and in SNF, home health, and outpatient rehabilitation settings, with the same licensure requirement; when an unlicensed provider performs OT-scope services and the service is billed to Medicare or Medi-Cal as OT rendered by a CBOT-licensed practitioner, the billing constitutes a false claim under the federal False Claims Act (31 U.S.C. § 3729) — a false certification that the services were rendered by a qualified, licensed provider — creating parallel FCA exposure for the individual unlicensed provider and any institutional facility (SNF, home health agency, outpatient clinic) that submitted or caused the submission of the false claim; the Medicare/Medi-Cal billing records for the unlicensed OT services create an independent government records trail documenting the unlicensed practice: the Provider Transaction Access Number (PTAN) assigned to the billing provider, the date of service, the CPT code billed (97003 for OT evaluation, 97004 for OT re-evaluation, 97110, 97112, 97165, 97166, 97167, 97168 for OT treatment), and the rendering provider's NPI number — records that the plaintiff attorney can obtain through a Medicare or Medi-Cal records request and that independently establish the dates, scope, and billing of the unlicensed OT services for the CLRA § 1780 fee petition lodestar

PURE KETCHUM — Bus. & Prof. Code § 2570.14 unlicensed occupational therapy practice claims with no concurrent federal statute providing mandatory civil attorney fee-shifting; no Ketchum/Dague split for the CLRA § 1780 lodestar: no federal statute creates a private right of action with mandatory attorney fees specifically for clients harmed by unlicensed occupational therapy practice; IDEA provides attorney fees only in IDEA administrative proceedings for FAPE disputes — not for consumer fraud claims against unlicensed OT providers in civil court; Medicare's and Medi-Cal's coverage conditions for OT services create government billing records but no private right of action for patients against unlicensed OT providers; the False Claims Act's qui tam provisions require a separate government investigation and do not create a direct private right of action for individual OT patients against unlicensed providers for CLRA § 1780 fee-shifting purposes; for the CLRA § 1780 unlicensed OT practice claim, the entire lodestar from the CBOT License Verification Database search date through the Tyler Odyssey complaint through judgment is pure Ketchum, eligible for the full Ketchum multiplier without any Dague constraint.

Primary Welch Anchor: Tyler Odyssey Civil Complaint Filing Date

The Tyler Odyssey civil complaint filing date is the primary Welch temporal anchor for the CLRA § 1780 attorney fee petition lodestar in Bus. & Prof. Code § 2570.14 unlicensed occupational therapy practice cases. In unlicensed OT matters, the Tyler Odyssey complaint is typically filed after the plaintiff attorney has: confirmed through the CBOT License Verification Database that the defendant practitioner operated without a current CBOT license; reviewed the client's OT treatment records and functional outcome measurements; coordinated with a CBOT-licensed OTR expert to document the functional outcome harm from the unlicensed "OT" services; and assessed the Medicare/Medi-Cal billing records as an independent government records trail corroborating the scope and billing of the unlicensed services.

The pre-complaint advisory period in post-surgical or post-stroke rehabilitation unlicensed OT cases typically begins when the patient or family member discovers that the "OT" who provided home health or outpatient OT services lacked CBOT licensure — often after the patient's treating physician or physiatrist reviews the functional outcome data and notes that the patient's functional gains are substantially below what the rehabilitation literature predicts for properly delivered OT services. The attorney then searches the CBOT database to confirm the unlicensed status (establishing the secondary anchor), reviews the Medicare/Medi-Cal billing records to document the scope and dates of unlicensed services, and coordinates with a CBOT-licensed OTR expert to quantify the functional outcome harm through validated instruments.

Secondary Institutional Anchor: CBOT License Verification Database

The California Board of Occupational Therapy License Verification Database is the secondary institutional anchor in CLRA § 1780 unlicensed occupational therapy practice fee petition cases — THE ONLY secondary institutional anchor in the entire fee-petition-mechanics series tied specifically to the CBOT licensing program under Bus. & Prof. Code §§ 2570–2573.5. The CBOT maintains a public License Verification Database recording for each licensed OT and OTA: the CBOT license number; the licensee's full legal name; the license type (OT or OTA); the NBCOT credential (OTR or COTA); the license issue date; the license expiration date; the current license status; and any public disciplinary actions, consent agreements, or probationary conditions. When the attorney searches the CBOT database and confirms the defendant's absence from the CBOT active licensee roster, the search date establishes the secondary Welch anchor for the CLRA § 1780 fee petition.

The CBOT database search simultaneously establishes: (a) the secondary anchor; (b) per se violation of § 2570.14 (unlicensed OT practice); and (c) the predicate credential misrepresentation triggering CLRA § 1780 mandatory attorney fees. Cross-referencing the PTB database confirms whether the defendant holds a PT license that does not authorize OT-scope services — establishing the scope-of-practice violation. The Medicare/Medi-Cal billing records (obtained through a CMS or Medi-Cal records request) corroborate the CBOT database search by documenting the specific OT CPT codes billed under the unlicensed provider's NPI — establishing both the scope of unlicensed services and the institutional billing fraud that creates parallel FCA exposure.

Billing Gap 1 — CBOT License Database Search, OT Treatment Records Review, and Medicare/Medi-Cal Billing Records Analysis (4.50 hrs/yr = $1,350–$2,250)

The first billing gap arises in the pre-complaint advisory phase — from initial client contact through Tyler Odyssey complaint filing — during which the attorney searches the CBOT License Verification Database, reviews the client's OT treatment records and functional outcome measurements, and obtains Medicare/Medi-Cal billing records as an independent corroborating government records trail.

• Searching the CBOT License Verification Database and cross-referencing the PTB database to confirm the defendant's unlicensed OT status and distinguish CBOT unlicensed practice from authorized PT scope-of-practice services that overlap with OT: the attorney searches the California Board of Occupational Therapy License Verification Database for the defendant practitioner to confirm: (a) the absence of a current active CBOT OT or OTA license; (b) whether the defendant holds any lapsed, expired, suspended, or revoked CBOT license; (c) whether the defendant holds a PTB physical therapist license that does not authorize the OT-scope services performed (ADL assessment and retraining, cognitive rehabilitation, pediatric sensory processing intervention, upper extremity orthosis fabrication); and (d) whether the CBOT database reflects any prior CBOT investigation or citation; the attorney also cross-references the CBOT database for the supervising OT if the unlicensed provider was an OTA — to confirm whether the supervising OT held a valid CBOT license and maintained the required supervision ratio and contact requirements for the OTA's patient caseload; all CBOT database search results are documented with screenshots memorializing the search date.
• Reviewing the client's occupational therapy evaluation reports, OT treatment notes, functional outcome measurement scores, and home exercise program documentation to establish the scope of services provided by the unlicensed practitioner and the baseline functional outcome expected from evidence-based CBOT-licensed OT: the attorney reviews: the OT initial evaluation report documenting the functional assessment conducted by the unlicensed practitioner (including whatever assessment instrument was used — or, notably, absent in cases where the unlicensed practitioner failed to conduct a standardized functional evaluation); any FIM, Barthel Index, or COPM scores recorded by the unlicensed practitioner; all OT treatment notes documenting interventions and progress; any home exercise program or home modification recommendations made by the unlicensed practitioner; the physician's order for OT services and any OT goals established by the treating physiatrist or attending physician; and any OT re-evaluation or discharge summary; the attorney also obtains the patient's pre-injury or pre-hospitalization functional status records — to establish the functional baseline from which recovery was measured — and any prior OT evaluation by a CBOT-licensed practitioner (from the inpatient rehabilitation stay, for example) to document the functional gains trajectory that was expected from outpatient OT.
• Obtaining and analyzing Medicare/Medi-Cal billing records for the unlicensed OT services — documenting the OT CPT codes billed under the unlicensed provider's NPI and establishing the government records corroboration of the CBOT database search: the attorney submits a Medicare beneficiary records request through the CMS MyMedicare.gov portal (or the Medicare Administrative Contractor for the patient's geographic region) and/or a Medi-Cal records request to the DHCS to obtain: the complete Medicare/Medi-Cal claims data for the OT services provided by the unlicensed practitioner — including the date of service, the CPT codes billed (OT evaluation, OT re-evaluation, and therapeutic procedure codes), the rendering provider's NPI number, the billing provider's NPI number, and the amount billed and paid; a CMS NPI registry lookup confirming the rendering provider's NPI registration details — which may confirm the defendant's claimed OT credential in the NPI registration versus their actual CBOT database status; and any Medicare or Medi-Cal audit records for the billing provider indicating prior CMS or DHCS investigation of the unlicensed OT billing practice; these billing records create a government-validated corroborating record of the unlicensed OT services that is independent of the CBOT database and is admissible as a government record in the CLRA § 1780 proceeding.

Billing Gap 2 — CBOT-Licensed OTR Expert, Functional Independence Outcome Analysis, and CBOT Treatment Standard-of-Care Deviation Documentation (5.00 hrs/yr = $1,500–$2,500)

The second billing gap arises from the active litigation phase — from Tyler Odyssey complaint through trial or settlement — during which the attorney coordinates CBOT-licensed OTR expert testimony on the functional outcome harm from the unlicensed OT services, documents the evidence-based OT interventions the client was denied by the unlicensed practice, and establishes the economic value of the functional independence the client failed to achieve.

• Coordinating CBOT-licensed OTR expert testimony to establish the functional outcome harm from the unlicensed OT services — using validated instruments to document the gap between the functional outcomes achieved through unlicensed services and the outcomes a CBOT-licensed OTR would have produced: the attorney retains a CBOT-licensed, NBCOT-certified OTR (with specialty certification in the relevant area — SCLV for low vision, CSRS for spinal cord rehabilitation, CHT for hand therapy, or CAPS for aging-in-place assessment) to provide expert opinions on: the evidence-based OT interventions that a CBOT-licensed OTR would have provided for the client's specific diagnosis and functional goals — the specific ACOTE-accredited education and supervised fieldwork training competencies that the unlicensed practitioner lacked; the functional outcome measurement scores the client would have achieved through licensed OT services, based on the published rehabilitation outcomes literature for the client's specific diagnosis (post-stroke functional recovery trajectories, post-TKA/THA ADL recovery benchmarks, pediatric sensory processing intervention effectiveness data for ASD); the specific OT interventions the unlicensed practitioner failed to provide or failed to provide competently — the task-specific training not conducted, the adaptive equipment recommendations not made, the home modification assessment not performed, the cognitive strategy training not implemented; and the resultant functional independence deficit — quantified in FIM scale points, Barthel Index points, or COPM performance and satisfaction scores — that represents the measurable gap between the functional level the client reached with unlicensed "OT" and the functional level they would have reached with licensed OT.
• Economic valuation of the functional independence deficit — converting the FIM/Barthel/COPM functional outcome gap into economic terms using cost-of-care data for personal care assistance, home health aide, and adult day health program services: a functional independence deficit has a direct economic equivalent in the cost of personal care assistance, home health aide services, or adult day health programs required to compensate for the ADL functions the client failed to achieve independence in through the unlicensed OT services; the CBOT-licensed OTR expert and a life care planner calculate: the specific ADL tasks in which the client failed to achieve independence attributable to unlicensed OT (bathing, dressing, meal preparation, home management) — tasks in which CBOT-licensed OT would have produced independence; the hourly cost of personal care assistance or home health aide services for the non-independent ADL tasks, based on current California home care market rates (California minimum wage for home care workers, IHSS program rates, and private pay home health aide agency rates in the client's geographic region); the annual cost of the personal care assistance attributable to the functional independence deficit; and the present value of the lifetime cost of the personal care assistance if the functional deficit is permanent — yielding a substantial economic damages calculation that anchors the Ketchum multiplier analysis to the magnitude of the client's loss from unlicensed OT practice.
• Parallel False Claims Act qui tam referral assessment — evaluating whether the unlicensed OT billing to Medicare or Medi-Cal meets the threshold for a qui tam referral or government reporting that supplements the CLRA § 1780 consumer fraud case: the attorney assesses whether the institutional billing of unlicensed OT services to Medicare or Medi-Cal meets the threshold for a qui tam False Claims Act referral under 31 U.S.C. § 3730(b) — evaluating: the total amount of Medicare/Medi-Cal claims submitted for unlicensed OT services by the defendant provider or institution; whether the institutional billing involved a false certification of OT provider licensure (a false certification that the rendering provider held a valid CBOT license when in fact they did not); the potential FCA recovery available to the relator (30% of any FCA recovery in a case where the government elects not to intervene); and whether the government's parallel FCA investigation interest would support or inhibit the CLRA § 1780 consumer fraud case; if a qui tam referral is made, the attorney preserves the CLRA § 1780 mandatory fee claim as the primary client recovery mechanism, unaffected by the FCA proceeding, since the FCA is an enforcement mechanism with no Dague constraint applicable to the California CLRA § 1780 mandatory fee lodestar.

Billing Gap 3 — CLRA § 1780 Fee Petition, Ketchum Multiplier on Rehabilitation Patient Protection, and Fees-on-Fees (4.00 hrs/yr = $1,200–$2,000)

The third billing gap arises from the CLRA § 1780 mandatory attorney fee petition — establishing the complete lodestar from the CBOT License Verification Database search date (secondary anchor) through the Tyler Odyssey complaint (primary Welch anchor) and judgment, briefing the Ketchum multiplier with particular emphasis on the rehabilitation outcome protection value of CBOT licensing enforcement, and recovering fees-on-fees under Missouri v. Jenkins.

• Documenting the complete CLRA § 1780 lodestar from the CBOT License Verification Database search date through the Tyler Odyssey complaint and judgment — establishing the secondary anchor narrative and the Medicare/Medi-Cal billing records corroboration: the CLRA § 1780 fee petition documents the complete lodestar from the CBOT License Verification Database search date (secondary anchor) through: the OT treatment records and functional outcome measurement review; the Medicare/Medi-Cal billing records analysis; the PTB cross-reference; the CBOT-licensed OTR expert retention and functional outcome gap analysis; the life care plan for functional independence deficit; the Tyler Odyssey complaint (primary Welch anchor); all active litigation against the unlicensed OT practitioner and any institutional facility that billed for unlicensed OT services; and the judgment or settlement; the secondary anchor narrative explains that the CBOT License Verification Database — distinct from the PTB database (physical therapists) and all other healing arts board databases — is the government record that confirmed the defendant's unlicensed OT practice, triggering the CLRA § 1780 mandatory fee obligation; the Medicare/Medi-Cal billing records corroboration is documented as an independent government records trail that validates the CBOT database search finding.
• Ketchum multiplier factors specific to CLRA § 1780 unlicensed occupational therapy practice cases — emphasizing the functional independence protection imperative for post-surgical, post-stroke, and pediatric rehabilitation patients, the specialized expert coordination required, and the private enforcement function of mandatory fee awards against unlicensed OT providers: the Ketchum multiplier analysis has a distinctive rehabilitation outcome deterrence dimension: (a) the contingency risk of litigating complex functional outcome harm cases where the defendant's likely argument is that any functional deficit is attributable to the client's underlying injury or disease rather than the unlicensed OT practice — a causal attribution dispute that requires expensive OTR expert work to defeat; (b) the specialized expert coordination required — CBOT-licensed OTR, life care planner, Medicare billing expert — that commands significant fees; (c) the critical functional independence protection value of CBOT licensing enforcement: post-surgical, post-stroke, and pediatric rehabilitation patients receive OT at a developmental and rehabilitative inflection point where the window for achieving maximum functional recovery is limited (the neuroplasticity window for post-stroke rehabilitation is most responsive in the first 3–6 months post-stroke; the sensory processing development window for pediatric intervention is most responsive before age 7); an unlicensed "OT" provider who occupies this therapeutic window with ineffective, non-evidence-based interventions permanently forecloses the maximum functional recovery the patient would have achieved with licensed OT; and (d) the Medicare/Medi-Cal billing fraud dimension: unlicensed OT providers who bill government payers for unlicensed services harm the integrity of the Medicare and Medi-Cal programs and divert limited program resources from patients receiving licensed care — a systemic public harm that supports the Ketchum multiplier on deterrence grounds.
• Missouri v. Jenkins fees-on-fees for CLRA § 1780 petition preparation including CBOT database search narrative, functional independence outcome analysis summary, Medicare/Medi-Cal billing records corroboration, and Ketchum multiplier briefing on rehabilitation patient protection: all attorney time preparing the CLRA § 1780 fee petition is recoverable under Missouri v. Jenkins (491 U.S. 274 (1989)) — including the CBOT License Verification Database search narrative; the functional outcome measurement gap analysis; the Medicare/Medi-Cal billing records corroboration documentation; the PLCM Group Inc. v. Drexler (22 Cal.4th 1084 (2000)) market rate analysis; the Ketchum multiplier briefing; and all time preparing the fee petition and responding to the defendant's opposition.

Total Annual Billing Gap — Three-Gap Summary

• Gap 1 (CBOT database search, OT treatment records & Medicare/Medi-Cal billing records analysis): 4.50 hrs = $1,350–$2,250/yr
• Gap 2 (CBOT-licensed OTR expert, functional independence outcome analysis & CBOT treatment standard-of-care deviation documentation): 5.00 hrs = $1,500–$2,500/yr
• Gap 3 (CLRA § 1780 fee petition, Ketchum multiplier on rehabilitation patient protection & fees-on-fees): 4.00 hrs = $1,200–$2,000/yr
• Total: 13.50 hrs = $4,050–$6,750/yr untracked at $300–$500/hr median California solo practitioner rate

Related California Attorney Fee Petition Pages

• California Physical Therapy Board — Bus. & Prof. Code § 2660
• California Board of Registered Nursing — Bus. & Prof. Code § 2878
• California Respiratory Care Board — Bus. & Prof. Code § 3738
• California Board of Podiatric Medicine — Bus. & Prof. Code § 2472