STATE OF ILLINOIS 2 DEPARTMENT OF FINANCIAL AND PROFESSIONAL REGULATION, & DIVISION OF PROFESSIONAL REGULATION 2 2 DEPARTMENT OF FINANCIAL AND PROFESSIONAL, ) OE REGULATION of the State of Ilinois, ) =f 2 DIVISION OF PROFESSIONAL REGULATION, ) a Complainant, ) se v. ) No. 2018-0243603 Jill Howe, DC., ) License No. 038,006954 ) Respondent.) COMP! NOW COMES the DEPARTMENT OF FINANCIAL AND PROFESSIONAL REGULATION of the State of Illinois, DIVISION OF PROFESSIONAL REGULATION (“Department”), by its Chief of Medical Prosecutions, Brandon R. Thom, and as its Complaint against Jill Howe, D.C., states as follows. COUNTI Patient P.K. 1, Respondent presently holds a Centificate of Registration as a Chiropractic Physi in the State of Illinois, License No, 038.006954, issued by the Department. Said license is currently in “Active” status. ‘The Department has jurisdiction to investigate complaints and to bring this action pursuant to 225 Illinois Compiled Statutes, Section 60/36. 3. Atall times relevant herein, Respondent practiced chiropractic in the State of Illinois. 4. Incarly 2015, Respondent submitted to the Department an application for a Registered Medical Cosporation credential for Wellness Institute of Illinois, Ltd. (“Wellness Institute”), a chiropractic clinic that was last located at 110 Hillcrest Road Suite 102 in Schaumburg, (L. Page 3 of 14mn 12, 13, Prior to early 2019, Wellness Institute also provided treatment to patients at another facility, which facility was located at 741 McHenry Avenue, Suite G, in Crystal Lake, IL. Respondent has held herself out as the “Executive Director” of Wellness Institute. Atall times relevant herein, Respondent was a spokesperson for Wellness Institute in marketing activitics regarding stem cell therapy and “regenerative medicine,” including at presentations and seminars advertised to the public. Atall times relevant herein, Respondent directed the operations of Wellness Institute On of about April 6, 2017, Patient P.K. presented to Wellness Institute at the Schaumburg location for treatment of severe osteoarthritis pain in the right knee. At Wellness Institute, she underwent ster cell injections in the right knee. Prior to this treatment, Patient P.K. had attended a seminar on stem cells, where Respondent stated that Wellness Institute had a “85 percent success rate.” This statement was false or misleading. Patient P.K. was charged $4,500 for her injections. Six months afterwards, Patient P.K.'s condition had remained the same or had worsened. She received no relief from the stem cell injections. Six months after the injections, Patient P.K. underwent X-rays at Wellness Institute's Crystal Lake location. However, she was never given any results from the X-rays. Around September 2018, Patient P.K. saw an orthopedist. The orthopedist ordered X-rays of the right knee, which X-rays showed that Patient P.K.’s arthritis remained bone-on-bone. Patient P.K. subsequently reached out to Wellness Insitute to advise thatthe stem cell injections were ineffective and to request a a refund. Wellness Institute did not respond or issue any. refund, Page 4 of 1416, The foregoing acts and/or omissions of Respondent provide grounds for the Department to revoke, suspend, or otherwise discipline Respondent's license as a Physician and Surgeon on the authority of 225 ILCS 60/22(A) paragraphs (5) and (10; 68 Ill. Admin, Code 1285.240; 20 ILCS 2105/2105-130. WHEREFORE, based on the foregoing allegations, the DEPARTMENT OF FINANCIAL AND PROFESSIONAL REGULATION of the State of Illinois, DIVISION OF PROFESSIONAL REGULATION, by Brandon R. Thom, its Chief of Medical Prosecutions, prays that Respondent's license be revoked, suspended, placed on probation, or otherwise disciplined. " 12, The Department hereby adopts and realleges paragraphs 1 through 8 of Count I of this Complaint as 1 through 8 of Count UL ‘On or about November 15, 2017, Patient J.Z. presented at Wellness Institute at the Schaumburg location for treatment of chronic pain in the neck and shoulder arising from sprains and strains. At Wellness Institute, he underwent stem cell injections to his neck and shoulder. Prior to this treatment, Patient J.Z. had attended s lunch seminar on stem cells, where Respondent stated that: (L} stem cells could regenerate damaged cartilage; and (2) stem cells had healed Respondent. These statements were false or misleading ‘After the “fee” lunch, Patient J.Z. further was: (1) told that stem cells could help rebuild his shoulder and neck; (2) told that X-rays or other imaging studies were unnecessary as stem cells ‘were “smart” and will circulate to damaged tissue; and (3) solicited to make an appointment for the next day at Wellness Institute, (On November 15, 2017, Respondent was present at the clinic but did not personally see or treat Patient JZ. Page 5 of 1413. 14. Patient J.Z, was charged $10,000 for the neck injections and $4,000 for the shoulder injections At around 3 months post-injection, Patient J.Z.’s condition remained unchanged or had worsened. As he was “still miserable,” he was compelled to seek out treatment from an orthopedist and extensive physical therapy. ‘The foregoing acts and/or omissions of Respondent provide grounds for the Department to revoke, suspend, or otherwise discipline Respondent's ticense as a Physician and Surgeon on the authority of 225 ILCS 60/22(A) paragraphs (5) and (10); 68 Ill. Admin, Code 1285.240; 20 ILCS 2105/2105-130. WHEREFORE, based on the foregoing allegations, the DEPARTMENT OF FINANCIAL AND PROFESSIONAL REGULATION of the State of Illinois, DIVISION OF PROFESSIONAL. REGULATION, by Brandon R. Thom, its Chief of Medical Prosecutions, prays that Respondent's license be revoked, suspended, placed on probation, or otherwise disciplined. 10. COUNT IIL Patient L.L. ‘The Department hereby adopts and realleges paragraphs | through 8 of Count I of this Complaint as 1 through 8 of Count IIL On or about October 15, 2018, Patient L.L. presented at Wellness Institute at the Crystal Lake location for treatment of arthritis pain in his left knee, At Wellness Institute, he underwent a stem cell injection to his knee. Prior to this treatment, Patient L.L, and his wife, Patient L.A.L. (see Count [V), had attended seminar where Respondent stated that: (1) amniotic stem cells would regrow cartilage in j Ss via injection into the damaged joint; (2} new cartilage would be produced within one year of treatment; and (3) Wellness Institute's success rate was greater than 80 percent. ‘These statements were false or misleading, Page 6 of 14mn 12 13, 16. Patient L.L. and his wife were further told by Respondent that if the cartilage had not grown back by the end of a year, Wellness Institute would offer a second injection for half price; however, Respondent added that “they had never had to do that.” Patient LL. was charged $6,000 for his knee injection. The evening before their previously scheduled 6-month follow-up appointment of April 16, 2019, Patient L.L. received a call from Wellness Institute. Wellness Institute requested that the couple's appointment be rescheduled and moved to the Schaumburg location, ws the Crystal Lake locati was closed due to a increase in rent. The patient did not return to Wellness Institute. At six months post-injection, Patient L.L.’s condition had not improved. He received no relief from the stem cell injection. ‘The foregoing acts and/or omissions of Respondent provide grounds for the Department to revoke, suspend, or otherwise discipline Respondent's license as a Physician and Surgeon on the authority of 225 ILCS 60/22(A) paragraphs (5) and (10), 68 Ill. Admin. Code 1285.240; 20 ILCS 2105/2105-130. WHEREFORE, based on the foregoing allegations, the DEPARTMENT OF FINANCIAL AND PROFESSIONAL REGULATION of the State of Illinois, DIVISION OF PROFESSIONAL REGULATION, by Brandon R. Thom, its Chief of Medical Prosecutions, prays that Respondent's license be revoked, suspended, placed on probation, or otherwise disciplined, COUNT IV Patient L.A. ‘The Department hereby adopts and realleges paragraphs | through 8 of Count I of this ‘Complaint ag 1 through 8 of Count IV. Page 7 of 1410. nN 12, 14, 15. 16, On or about October 16,2018, Patient L.A.L. presented at Wellness Institute at the Crystal Lake location for treatment of pain from bone-on-bone arthritis in her left knee and pain in her left shoulder. At Wellness Institute, she underwent stem cell injections to her knee and shoulder. Prior to this treatment, Patient L.A.L. and her husband, Patient L.L. (see Count II1), had attended ase 1 where Respondent stated that: (1) amniotic stem cells would regrow cartilage in joints via injection into the damaged joint; (2) new cartilage would be produced within one year of treatment; and (3) Wellness Institute's success rate was greater than 80 percent. These statements were false or misleading Patient L.A.L. and her husband were further told by Respondent that if the cartilage had not grown back by the end of year, Wellness Institute would offer a second injection for half price, but Respondent added that “they had never had to do that.” Patient L.A.L. was charged $6,000 for each injection. Patient L.A. also received physical therapy and other services by Wellness Institute in the following months. ‘The evening before their previously scheduled 6-month follow-up appointment of April 16, 2019, Patient L.L. received a call from Wellness Institute. Wellness Institute requested that the couple's appointment be rescheduled and moved to the Schaumburg location, as the Crystal location was closed due to an increase in rent. ‘At six months postinjection, Patient L.A.L.’s condition of bone-on-bone arthritis had ‘worsened, no cartilage and grown back, and she was in severe pain, She received no relief from. the stem cell injections. Patient L.A.L. eventually scheduled surgery with an orthopedic surgeon, Page 8 of 1417. ‘The foregoing acts and/or omissions of Respondent provide grounds for the Department to revoke, suspend, or otherwise discipline Respondent's license as a Physician and Surgeon on the authority of 225 ILCS 60/22(A) paragraphs (5) and (10); 68 Ill. Admin. Code 1285.240; 20 ILCS 2105/2105-130. WHEREFORE, hased on the foregoing allegations, the DEPARTMENT OF FINANCIAL AND PROFESSIONAL REGULATION of the State of Illinois, DIVISION OF PROFESSIONAL REGULATION, by Brandon R. Thom, its Chief of Medical Prosecutions, prays that Respondent's Jivense be revoked, suspended, placed on probation, or otherwise disciplined. 10. Me 12. COUNT V Patient FM. ‘The Department hereby adopts and realleges paragraphs 1 through 8 of Count I of this Complaint as 1 through 8 of Count V. On or about February 1, 2017, Patient F.M. presented at Wellness Institute at the Crystal Lake location for treatment of osteoarthritis knee pain. At Wellness Institute, he underwent stem cell injection in the left knee. Prior to this treatment, Patient F.M, heard 2 radio ad by Wellness Institute stating that ster cell, injections could stop pain in injured tissue. This statement was false or misleading. Patient F.M. was charged $4,50t0 for the injection. Patient F.M. also received physical therapy and other services from Wellness Institute in the following months. Patient F.M.’s condition remained unchanged or had worsened. He received no relief from the stem cell injections. Page 9 of 1414 Paticnt F.M. subsequently called Wellness Institute to advise that the injections were ineffective and to request a refund, ‘The Wellness Institute employee who answered the phone hung up on him. The foregoing acts and/or omissions of Respondent provide grounds for the Department to revoke, suspend, or otherwise disi ine Respondent's license as a Physician and Surgeon on the authority of 225 ILCS 60/22(A) paragraphs (5) and (10); 68 Il. Admin. Code 1285.240; 20 ILCS 2105/2105-130. WHEREFORE, based on the foregoing allegations, the DEPARTMENT OF FINANCIAL, AND PROFESSIONAL REGULATION of the State of Illinois, DIVISION OF PROFESSIONAL REGULATION, by Brandon R. Thom, its Chief of Medical Prosecutions, prays that Respondent's license be revoked, suspended, placed on probation, or otherwise disciplined. 10. COUNT VI Patient DS. ‘The Department hereby adopts and realleges paragraphs | through 8 of Count I of this Complaint as | through 8 of Count VI On or about April 23, 2018, Patient D.S. presented at Wellness Institute at the Schaumburg location for treatment of pain in her back and ankles that prevented her from walking. At Wellness Institute, Patient D.S. underwent stem cell injections to her lower back and ankles. At Wellness Institute, Patient D.S. was told that stem cell injections could repair the injuries in her back and ankles, ‘These statements are false or misleading, Patient D.S. was charged $12,000 for the injections. ‘A year afterwards, Patient D.S."s condition remained unchanged or had worsened. She received no relief from the injections Page 10 of 1413. ‘The foregoing acts and/or omissions of Respondent provide grounds for the Department to revoke, suspend, or otherwise discipline Respondent's license as a Physician and Surgeon on the authority of 225 ILCS 60/22(} paragraphs (5) and (10); 68 II. Admin, Code 1285.240; 20 ILES 2105/2105-130. WHEREFORE, based on the foregoing allegations, the DEPARTMENT OF FINANCIAL AND PROFESSIONAL REGULATION of the State of Illinois, DIVISION OF PROFESSIONAL REGULATION, by Brandon R. Thom, its Chief of Medical Prosecutions, prays that Respondents license be revoked, suspended, placed on probation, or otherwise disciplined. 10. 12, 1B. COUNT VII Patient A.K. ‘The Department hereby adopts and realleges paragraphs 1 through 8 of Count I of this Complaint as 1 through 8 of Count VIL On or about July 13, 2017, Patient A.K. presented at Wellness Institute at the Schaumburg location for treatment of osteoarthritis pain in the knees. At Wellness Institute, Patient AK. received stem cell injections in both knees. At Wellness Institute, Patient A.K. was told that: (1) stem cells could regenerate cartilage inside the knee joint; (2) her pain would be relieved within 6 months; and (3) stem cell therapy had a 90 percent success rate. These statements are false or misleading. Patient A.K. was further told that, after 6 months, she should return to Wellness Institute for an ‘X-ray to evaluate the regeneration of the cartilage. Six months post-injection, Patient A.K. called Wellness Institute to schedule an appointment for follow-up and for the X-ray, Wellness Institute claimed that the X-ray machine was broken, Patient A.K. attempted around five more times to schedule the follow-up and X-ray with Wellness Institute, to be done at either its Schaumburg or Crystal Lake location, but Wellness Page 11 of 1416, Institute was unresponsive and did not schedule an appointment for her. Eventually, Wellness Institute stopped returning the patient's calls. Patient A.K. was charged $8,500 for the injections. Afterwards, Patient A.K’s condition remained unchanged or had worsened. She received no relief from the stem cell injections. The foregoing acts and/or omissions of Respondent provide grounds for the Department to revoke, suspend, or otherwise discipline Respondent's license as a Physician and Surgeon on the authority of 225 ILCS 60/22(A) paragraphs (5) and (10); 68 Ill. Admin. Code 1285.240; 20 ILCS 2105/2105-130. WHEREFORE, based on the foregoing allegations, the DEPARTMENT OF FINANCIAL, AND PROFESSIONAL REGULATION of the State of Illinois, DIVISION OF PROFESSIONAL REGULATION, by Brandon R. Thom, its Chief of Medical Prosecutions, prays that Respondent's license be revoked, suspended, placed on probation, or otherwise disciplined. 10. COUNT VIII, Patient W.S. The Department hereby adopts and realleges paragraphs I through 8 of Count I of this ‘Complaint as I through 8 of Count VIII. ‘On ot about October |, 2018, Patient W.S. presented at Wellness Institute for treatment of knee pain, At Wellness Institute, Patient W.S. underwent stem cell injections in the right knee. Prior to treatment, Patient W.S. had seen Respondent on TV promoting stem cell therapy. Patient WS. called Wellness Institute, who recommended that he attend an upcoming seminar on stem cells to take place at a restaurant in Orland Park. Page 12 of 14ML 2 13. 4 ‘At the seminar, Respondent told Patient W.S. that if he underwent the stem cel injections, he “would not need anything further” for his knees and he would feel a difference “within days.” ‘These statements were false or misleading Patient W.S. was charged $9,500 for the injections. Patient W.S.s condition remained unchanged or had worsened. He received no relief from the stem cell injections. The foregoing acts and/or omissions of Respondent provide grounds for the Department to revoke, suspend, or otherwise discipline Respondent's license as a Physician and Surgeon on the authority of 225 ILCS 60/22(A) paragraphs (5) and (10); 68 Ill. Admin. Code 1285.240; 20 TLCS 2105/2105-130. WHEREFORE, based on the foregoing allegations, the DEPARTMENT OF FINANCIAL. AND PROFESSIONAL REGULATION of the State of Illinois, DIVISION OF PROFESSIONAL REGULATION, by Brandon R, Thom, its Chief of Medical Prosecutions, prays that Respondent’s license be revoked, suspended, placed on probation, or otherwise disciplined. 10, COUNTIX Patient S.N. ‘The Department hereby adopts and realleges paragraphs | through 8 of Count I of this ‘Complaint as 1 through 8 of Count IX. On or about June 28, 2017, Patient S.N. presented at Wellness Institute for treatment of lower back pain. At Wellness institute, Patient S.N. underwent two stem cell injections to each side of her lower back, a total of four injections, Prior to the treatment, Patient §.N. had attended a seminar on stem cells, held at a hotel, where Respondent promoted stem cell therapy. Page 13 of 14Patient S.N. was told that: (1) stem cells could provide relict for stenosis, hemiated disks, and extreme arthritis; and (2) she would have relief from pain in 2 to 3 months, These statements were false or misleading, Pati 1 S.N. was charged $10,000 for the injections. Afterwards, Paticnt $.N."s condition remained unchanged or had worsened. She received no relief from the stem cell injections. he foregoing acts and/or omissions of Respondent provide grounds for the Department to revoke, suspend, or otherwise discipline Respondent's license as a Physician and Surgeon on the authority of 225 ILCS 60/22(A) paragraphs (5) and (10); 68 III. Admin. Code 1285.240; 20 ILCS 2105/2105-130. WHEREFORE, based on the foregoing allegations, the DEPARTMENT OF FINANCIAL AND PROFESSIONAL REGULATION of the State of Illinois, DIVISION OF PROFESSIONAL. REGULATION, by Brandon R. Thom, its Chief of Medical Prosecutions. ‘ays that Respondent's license be revoked, suspended, placed on probation, or otherwise disciplined. DEPARTMENT OF FINANCIAL AND PROFESSIONAL REGULATION SECRETARY MARIO TRETO, JR. Chief of Medical Prosecutions Brandon R. Thom Angie A. Chen Stalf Atlomey | Medical Prosecutions Unit Department of Financial and Professional Regulation 555 West Monroe St., Suite 500 Chicago, Mlinois 6066 312-793-3927 | angie.a.chen@illinois gov