Lakeisha Janel Reveron, DAB, CR6901, (2026)

DECISION

Petitioner, Lakeisha Janel Reveron, was a registered nurse, licensed in the State of Virginia.  The Virginia Board of Nursing revoked her license because it determined that, when she applied for it, she had misrepresented her academic credentials.  Because her license was revoked, the Inspector General (IG) has excluded her from participating in Medicare, Medicaid, and all other federal health care programs pursuant to section 1128(b)(4) of the Social Security Act (Act).  The exclusion remains in effect until she is reinstated.  To be eligible for reinstatement, she must regain her Virginia nursing license, obtain another healthcare license, or has been excluded for a minimum period of three years. 

Petitioner now appeals the exclusion. 

For the reasons set forth below, I find that the Virginia Board of Nursing revoked Petitioner’s license to provide health care as a registered nurse for reasons bearing on her professional competence.  The IG therefore is authorized to exclude her from program participation, and I may not disturb the IG’s exercise of that authority. 

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I.  Background

In a letter dated December 31, 2025, the IG notified Petitioner that she was excluded from participation in Medicare, Medicaid, and all other federal health care programs because her license to provide health care as a registered nurse in the State of Virginia was revoked, suspended, or otherwise lost, or surrendered while a formal disciplinary proceeding was pending, for reasons bearing on her professional competence, professional performance, or financial integrity.  The letter explained that section 1128(b)(4) authorizes the exclusion.  The letter also explained that the exclusion would remain in effect until she is reinstated by the IG.  To be eligible for reinstatement, she has to regain her Virginia nursing license.  In the alternative, the letter explained, the IG would consider early reinstatement if she obtained a health care license in any state or after she had been excluded for a minimum of three years.  IG Exhibit (Ex.) 1. 

Petitioner requested review. 

Prehearing conference and parties’ briefs.  During a January 27, 2026 prehearing conference, Petitioner stated that, notwithstanding the loss of her Virginia license, she might qualify for early reinstatement.  Petitioner explained that she is also a registered nurse in Pennsylvania.  However, following the prehearing conference, Petitioner informed the IG that her license was pending a disciplinary action in Pennsylvania as well.  IG Ex. 6. 

Pursuant to the order following the prehearing conference, the parties filed their briefs.  On May 1, 2026, the IG filed its brief with six exhibits and no witnesses.  On May 4, 2026, Petitioner filed her brief with six exhibits and no witnesses.  On May 15, 2026, the IG filed its reply brief. 

Because neither party proposes any witnesses, an in-person hearing would serve no purpose.  I therefore close the record and issue this decision based on the parties’ written submissions.  See Anil Hanuman, D.O., DAB No. 3080 at 11-12 (2022); Emery Cnty. Care & Rehab. Ctr., DAB No. 3006 at 5-8 (2020); James Brian Joyner, M.D., DAB No. 2902 at 12 (2018); CRDP ¶ 16(b). 

In the absence of any objections, I admit the IG’s Exhibits 1-6 into evidence and Petitioner’s Exhibits 1-6 into evidence. 

II.  Discussion

1. Because Petitioner’s license to practice as a registered nurse in Virginia was revoked for reasons bearing on her professional competence, the IG may exclude her from participating in

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Medicare, Medicaid, and all other federally funded health care programs.1 

The Act authorizes the Secretary of Health and Human Services to exclude from program participation an individual whose license to provide health care has been revoked or suspended for reasons bearing on his “professional competence, professional performance, or financial integrity.”  Act § 1128(b)(4) (codified at 42 U.S.C. § 1320a-7(b)(4)); accord 42 C.F.R. § 1001.501(a)(1).  The exclusion “will not be for a period of time less than the period during which an individual’s . . . license is revoked . . . as a result of . . . a State licensing agency action.”  42 C.F.R. § 1001.501(b)(1) (authorized by Act § 1128(c)(3)(E)).  Under certain circumstances, the IG may lengthen the period of exclusion.  42 C.F.R. § 1001.501(b)(2). 

Here, in a consent order, the Virginia Board of Nursing and Petitioner agreed that: 

• On October 1, 2021, Petitioner was issued a license to practice professional nursing in Virginia;
• Petitioner did not meet the eligibility requirements for licensure by endorsement as a professional nurse in the Virginia prior to the issuance of her license on October 1, 2021;
• In her August 3, 2021 application for licensure, Petitioner identified Med-Life Institute as her nursing school and stated that she graduated on May 4, 2018.  Petitioner further stated in her application that the education program required 500 clinical hours.  However, the Virginia Board of Nursing later determined that Petitioner did not obtain the education or clinical training required for licensure as a professional nurse in Virginia from Med-Life Institute; and
• Petitioner’s license to practice professional nursing in Virginia is invalid because the license was issued without Petitioner completing the proper licensure eligibility requirements. 

IG Ex. 2. 

In the consent order, dated October 3, 2025, the Virigina Board of Nursing and Petitioner agreed to the findings of fact and conclusions of law in the consent order and that Petitioner’s license was to be recorded as permanently surrendered.  Id. at 4.  Based on those findings, the Nursing Board concluded that Petitioner violated Virginia Code § 54.1-3018 and 18 VAC 90-19-120(A) of the Virginia Regulations because her license was issued without Petitioner completing the proper licensure eligibility requirements. 

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Id. at 3.Based on these findings, the Board revoked Petitioner’s license to practice as a registered nurse.  Id. 

Contrary to the findings in the consent order between the Virginia Board of Nursing and Petitioner, Petitioner now claims that she tried to comply with the license requirements and that she made a “good-faith reliance on an institution that failed to meet regulatory expectations.”  Petitioner Brief (P. Br.) at 2.  Petitioner also argues that she should not be required to produce detailed clinic site records years later after Med-Life closed.  Id. 

The regulations preclude such a collateral attack on an underlying determination: 

When the exclusion is based on the existence of a . . . determination by another government agency, or any other prior determination where the facts were adjudicated and a final decision was made, the basis for the underlying . . . determination is not reviewable, and the individual or entity may not collaterally attack it[,] either on substantive or procedural grounds[,] in this appeal. 

42 C.F.R. § 1001.2007(d); Delores L. Knight, DAB No. 2945 at 9 (2019); Marvin L. Gibbs, Jr., M.D., DAB No. 2279 at 8-10 (2009); Roy Cosby Stark, DAB No. 1746 (2000). 

Petitioner’s license was revoked after she agreed in the consent order that she did not have the education or clinical hours required to qualify as a registered nurse at the time she applied for a license.  These factors bear directly on her professional competence. 

Having concluded that Petitioner’s license was revoked for reasons bearing on her professional competence and performance, I have no discretion; I must follow the federal exclusion statute and regulations and sustain the exclusion.  42 C.F.R. § 1005.4(c)(5); Richard R. Jimenez, DAB No. 2986 at 5-6 (2020); Chirsty Nichols Frugia, DAB No. 2736 at 4-5 (2016); see Marvin L. Gibbs, Jr., M.D., DAB No. 2279 at 8-10 (2009). 

The statute requires that Petitioner’s period of exclusion “shall not be less than the period during which [his] license . . . is . . . revoked . . . .”  Act § 1128(c)(3)(E); see also 42 C.F.R. § 1001.501(b)(1).  Although the regulations give the IG some discretion to reinstate under other conditions (if he obtains a health care license in another state or has been excluded for three years), I have no authority to review the IG’s exercise of that discretion. 

Petitioner additionally argues that she has obtained additional nursing degrees since the suspension of her nursing license and that she has maintained a clinical practice in multiple healthcare settings.  P. Br. at 3.  While this may be true and the achievement of additional nursing degrees is impressive, it does not negate that Petitioner’s license was

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surrendered in Virginia for not completing the proper licensure eligibility requirements.  Petitioner’s arguments are essentially equitable and are not a basis to overturn Petitioner’s exclusion.  Lastly, Petitioner asserts that the action being taken by the Pennsylvania Board of Nursing arises from the same facts related to the surrender of her Virginia nursing license.  Id.  And again, while this may be true, it does affect the grounds for exclusion.  Any license held in another state would only go to the timing of Petitioner’s reinstatement by the IG, which I do not have jurisdiction to address. 

III.  Conclusion

For the above reasons, I conclude that the IG properly excluded Petitioner from participating in Medicare, Medicaid, and all other federal health care programs for so long as her license to practice as a registered nurse is revoked.