A Confidential Rehabilitation Order (CRO) is a private agreement that allows eligible physicians or physician assistants to keep their license while addressing substance use or mental health concerns under strict conditions. 

In Texas, the official legal term is Non-Public Rehabilitation Order, as defined under §180.1 of the Texas Administrative Code. However, many licensees and legal practitioners still refer to it informally as a “Confidential Rehabilitation Order.”

This option is only available through the Texas Medical Board (TMB) and applies under specific circumstances. It is not available to nurses, pharmacists, or other licensed healthcare professionals in Texas.

If you are uncertain whether this provision applies to your circumstances, a Texas medical license defense lawyer can assess your eligibility and advise you on board-specific alternatives.

Understanding Confidential Rehabilitation Orders

A CRO is a formal, non-disciplinary agreement between a physician or physician assistant and the Texas Medical Board. It is designed to protect the public while supporting licensees through structured monitoring and compliance. 

CROs are available only to licensees who satisfy narrow statutory criteria and offer a confidential mechanism to retain licensure while undergoing board-approved monitoring.

Unlike public disciplinary actions, a CRO remains confidential as long as the participant meets all terms. This protection helps preserve professional standing while addressing personal health needs.

Who Can Benefit from a CRO?

CROs are available only to physicians and physician assistants licensed by the Texas Medical Board under Texas Administrative Code § 180.1(c). These orders provide a confidential, non-disciplinary path forward for licensees who meet strict eligibility criteria and self-report mental health or substance use concerns.

Other licensed professionals in Texas, such as nurses, pharmacists, or dentists, are not eligible for CROs. 

That said, other licensing boards may offer alternative confidential monitoring agreements, such as Corrective Action Orders or participation in diversion programs like TPAPN (Texas Peer Assistance Program for Nurses). 

These programs have their own eligibility requirements and procedural rules, which differ from those governing CROs under the Texas Medical Board.

If you’re unsure what your licensing board allows, it helps to talk with a Texas license defense attorney. They can explain your board’s specific options and help you take the right next step.

Eligibility for a Confidential Rehabilitation Order

To be considered for a CRO, the physician or physician assistant must meet specific eligibility criteria outlined by the Texas Medical Board. 

This may require self-disclosure of a qualifying mental or physical condition under Texas Administrative Code §180.1(c), no prior disciplinary action involving substance use, and evidence that no harm resulted to patients.

The Texas Medical Board evaluates each application on a case-by-case basis, considering both statutory criteria and any aggravating or mitigating circumstances in accordance with board disciplinary policies.

If the situation does not meet TMB requirements, a different form of confidential resolution may be available, depending on the applicable licensing board.

How Does a Confidential Rehabilitation Order Work?

If the Texas Medical Board determines that a licensee qualifies for a CRO, the physician or physician assistant must enter into a formal, legally binding agreement outlining the conditions of participation.

This agreement delineates specific terms that must be followed to maintain the confidentiality of the order and continue practicing.

These conditions typically include the type of treatment or counseling required, the frequency of drug or alcohol testing, the duration of the rehabilitation period, and expectations for communication with the board. The agreement’s structure aims to provide support while keeping public discipline off your record.

Strict adherence to the agreement is critical. Noncompliance may trigger adverse licensing action, including public disciplinary measures or suspension.

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The Benefits of a Confidential Rehabilitation Order

A Confidential Rehabilitation Order offers practical benefits that protect both your career and your well-being.

Protection of Privacy

A significant benefit of participating in a CRO is that it keeps your matter private. When you follow all conditions, the order does not become a public record, which helps protect your personal and professional reputation.

Professional Continuity

A CRO lets you continue practicing rather than stepping away from your role. This arrangement allows licensees to continue practicing without career interruption, thereby preserving income and addressing underlying health concerns through a structured recovery plan.

Structured Support

The order also introduces structure and accountability. Required treatments, regular reporting, and professional oversight create a reliable framework to support your ongoing recovery and success.

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Risks and Responsibilities

While a CRO offers meaningful protections, the obligations are serious. Full compliance is not optional. Any deviation from the terms, missed appointments, failed tests, or incomplete reporting can result in disciplinary measures.

Due to the legal and professional implications, many licensees retain a Texas medical license defense attorney to ensure complete comprehension of CRO requirements and to facilitate continued compliance.

Common Misconceptions About CROs

Addressing these common misconceptions can help demystify the process and assist licensees in making informed decisions.

It’s Not an Admission of Guilt

Agreeing to a CRO through the Texas Medical Board does not constitute an admission of wrongdoing. It’s an opportunity for physicians and PAs to address private health matters without public discipline, provided they meet all conditions. Successful completion keeps the agreement confidential and off public records.

It’s Not a Permanent Record

Another common concern is whether the CRO will follow you throughout your career. When you complete the order successfully and no violations occur, the agreement remains confidential and does not appear in public records.

What to Expect from the CRO Process in Texas

Only the Texas Medical Board offers a Confidential Rehabilitation Order, and only for physicians and physician assistants. The process often looks like this:

• The physician or PA self-reports to the board or is identified through another channel.
• The TMB evaluates whether the individual meets eligibility criteria under §180.1(c).
• If accepted, a confidential agreement is drafted, including treatment, drug testing, and ongoing compliance.
• As long as the terms are followed, the agreement remains private and does not appear in public records.

For nurses and other licensees, boards like the Texas Board of Nursing use different tools. For example, TPAPN is a voluntary, confidential assistance program for nurses facing similar issues, but it is not a CRO and operates under a separate set of rules.

We’re Here to Support You

When substance use or health-related concerns put your license at risk, a Confidential Rehabilitation Order may give you a private and structured path forward. You have options, and you don’t have to face the board alone.

A Texas medical license defense lawyer can help you understand the terms, protect your rights, and keep your career moving in the right direction. At Bertolino LLP, we represent licensees across Texas who need clear answers and steady guidance.

Your license reflects years of work. Let’s talk about how we can help you protect it.

Call or text (512) 476-5757 or complete a Case Evaluation form