HARRY HUGHES, Governor

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arguably contemplate a lifetime grant of a license, which
does not expire on the renewal date. This interpretation
reflects the philosophy and practice of the Board.

The present law requires the applicant to pay a renewal
fee and submit a renewal application to obtain a renewal
certificate. The present law does not indicate that the
license expires if not renewed. Present Art. 43, § 506
makes practicing without obtaining a renewal certificate
grounds for possible — not automatic or mandatory —
suspension or revocation. This fact reinforces the
interpretation that the license continues in effect. On the
other hand, the present law uses mandatory language when
establishing the renewal fee and also gives the Board the
power to establish mandatory continuing education
requirements "... as a condition to having their licenses
renewed ...". In practice, the Board treats the unrenewed
license as valid until further action is taken by the Board.
If the licensee fails to renew on or before September 1, the
Board notifies the licensee again and then begins a
disciplinary action.

Similarly, a licensee who fails to comply with the
continuing education requirements is not eligible to renew a
license, and does not receive a renewal certificate. If the
licensee continues to practice, the Board begins a
disciplinary action. See Art. 43, § 506(a), which now
appears as § 3-310 of this title. The practice of the Board
consistently reflects a view of the license as a continuing
entitlement.

The distinctive nature of this title is called to the
attention of the General Assembly.

Relationship of practice of chiropractic to the practice of
physical therapy.

Under the present law, a chiropractor may be licensed
by the State Board of Chiropractic Examiners to practice
chiropractic with the "right to practice physical therapy".
The relationship of the practice of chiropractic to the
practice of physical therapy is complex.

Chiropractic has been a regulated profession since
1920, and chiropractors, as part of the practice of
chiropractic, always have used certain of the techniques
that later came to be known as "physical therapy". See, for
example, the reference to diagnosis and to manual
manipulation of parts of the body in § 3-101(f) of this
title.

When a board to regulate the practice of physical
therapy was established by Ch. 906, Acts of 1947, the
relationship between the practice of "physical therapy" and
"chiropractic" was recognized in the new subtitle. Art. 43,
§ 514 (present § 614), stated that the subtitle was not to
"be construed to amend the laws relating to the practice of