Beware of Administrative Delegation

All licensed professionals should think twice when delegating the completion of various forms and applications to administrative personnel. As a licensed professional, administrative tasks such as completing and submitting applications for license renewals, credentialing, employment, etc. may seem like routine, mundane aspects of one’s career. However, these forms and applications, if not completed and submitted correctly, can lead to dire consequences that may have lasting effects on one’s ability to practice.


A common delegated task seen in many physician’s offices, healthcare institutions, and other professional settings is having an administrative assistant, employer, or hired service take over the responsibility of completing and submitting certain forms and documents on behalf of their employees, such as applications for licensure renewal, credentialing, or other types of official documents. While obtaining assistance from third-parties in completing applications and forms is not prohibited by law, and may be extremely helpful, the practitioner maintains the ultimate responsibility for confirming the accuracy of the information on those forms.


Following the completion of applications and forms, whether by the licensee themselves or by third-parties, the licensed professional for whom the document is prepared must conduct a full review prior to its submission. It’s extremely important to verify the accuracy of every response as failure to properly answer may result in negative consequences for the licensee. This is not limited to actions by the entity to whom the application is submitted. For example, the Medical Practice Act allows for the Illinois Department of Financial and Professional Regulation (IDFPR) to deny initial applications, refuse to renew existing licenses, or impose discipline against a physician for false responses or misrepresentations – which includes omissions – on applications or any other documents “connected with the practice of medicine”. The potential public discipline IDFPR may impose ranges from a reprimand of the license to the suspension of one’s ability to practice. Almost every other licensed profession has the same, or a very similar, basis of adverse action found within their specific practice Act or Rules.


While it’s possible for a third-party to complete official applications and documents, it is still the sole responsibility of the licensee to sign off – whether electronically or physically – on the form to be submitted once they complete their detailed review. By signing off on any application or form, the licensee is attesting to the fact that all provided information is true and correct. If a third party signs on behalf of the licensee and there is found to be an issue with the information provided, the licensee may face discipline against their license, rejected credentials, lost job opportunities, and even criminal penalties. Many official applications and documents note that attesting to false information or failure to adequately provide correct information may result in a Class A misdemeanor.


  • With the increase in remote work and electronic documents in recent years, the process of completing applications and forms has become a bit murky. That being said, the responsibility to provide correct information and proper attestations has not changed. Providing false information or allowing a third-party to sign off on official documents is almost always indefensible.
  • Support staff needs to be aware of these requirements as well. We have seen instances when support staff has taken it upon themselves to complete official applications on behalf of providers, only to provide inaccurate information to which they attest with a provider’s electronic signature without their knowledge. This leads to the same potential consequences as if the licensed professional completed the application themselves.
  • When it comes to applying for employment or privileges, job applications have been known to pull information from the online CAQH profile to populate responsive information within the application. It’s important to make sure all information within the CAQH is correct and kept up to date, as inaccurate responses will often disqualify applicants from employment opportunities.


If you would like us to assist with any application process – initial application, renewal, credentialing, etc. – or have any questions, please contact us. For additional information and updates, please refer to our website.

Disclaimer: This web site is addressed to those who hold professional licenses issued by the Illinois Department of Financial and Professional Regulation and by similar licensing agencies in other states. Suggestions herein are, in most circumstances, valid for any type investigation, whether administrative, criminal, or civil. However, it should be noted that in some other states, one who holds a professional license may be required to submit to an investigative interview as a condition of being licensed. Whatever the circumstances, a licensed professional who becomes the subject of an investigation would be wise to immediately retain legal counsel. No content, whole or in part, is to be considered as “legal advice,” and by reading this document, no attorney-client relationship is formed with the Crick Walanka Law Group, Ltd.