A Waterville doctor facing the loss of his medical license said he did not take standard steps to gather information about medical history and previous ailments before issuing letters recommending that about 100 health care and front-line workers be exempt from the state’s vaccination mandate.

Dr. Paul Gosselin, who ran a practice called Patriots Health, was suspended from practice in November by the state’s Board of Osteopathic Licensure after it found evidence that he was spreading misinformation about COVID-19 and had issued questionable exemption letters before a Nov. 1 vaccination deadline went into effect for certain Maine workers.

By late December, the case the board was considering had been narrowed to focus on a dozen exemption letters Gosselin issued in late October, shifting away from mention of COVID-19 science or Gosselin’s potential beliefs about how to best treat the disease.

Last Thursday, more than 150 people listened in to the public hearing held over Zoom.

If the board decides against him, Gosselin could face a range of sanctions, from a reprimand to a revocation of his license and fines.

Dr. Paul Gosselin Joe Phelan/Kennebec Journal

Gosselin, who has an extensive history of medical misconduct, testified Thursday that he did not keep records on the people who sought the vaccine exemption letters, never solicited a medical history, and did not require or seek medical records corroborating their assertions of past ailments that made vaccination risky or inadvisable. His attorney, F. Ron Jenkins, argued that he was not required to take those steps because the people seeking letters were not actually patients.


Osteopathic doctors are trained similarly to medical doctors and hold the same powers to prescribe medicine, perform surgery and care for patients. Osteopathic training focuses more on a holistic approach to patient care, incorporating an examination of related external factors in a patient’s life that go beyond a strict diagnosis and treatment of symptoms with pharmaceuticals.

At the time of his suspension, Gosselin’s website advertised COVID-19 evaluations and alternative COVID-19 prevention and treatment options not approved by the Food and Drug Administration, including use of the antiviral malaria drug hydroxychloroquine and the animal deworming drug ivermectin, neither of which has proved effective or safe. Gosselin’s clinic website also offered a one-time flat rate of $200 for an unproven coronavirus regimen of vitamins, with continued treatment through a membership program. It did not specify what treatments or medications are included in the service.

Gosselin’s attorneys have argued that the board unfairly targeted him because he has resisted accepting the broader medical community’s conclusions about the safety and efficacy of COVID-19 vaccinations. The suspension of his license, his lawyers say, amounted to a violation of his First Amendment right to free speech and his due process rights. Jenkins argues in pleadings filed with the board that the case against Gosselin was brought in bad faith.

The board, in rejecting Gosselin’s motion to dismiss the case, said his arguments were misplaced, and that the focus of the case is on the exemption letters and his failure to generate and maintain medical records, not on his beliefs about how to treat COVID-19.

A secretary for Gosselin estimated he signed about 100 exemptions often for a $100 fee, but said he did not charge for all of them and eventually stopped signing the letters because the number of requests distracted from his focus treating patients with chronic pain and substance use disorder.

“(The people who requested letters) did not have any ambivalence or questions about the COVID-19 vaccine,” Jenkins said during questioning. “They had already decided they weren’t going to have it, and no one could possibly convince them to get it. They were not looking for Dr. Gosselin to diagnose or treat them.”


Jenkins, who declined a request for an interview, suggested that because there was no doctor-patient relationship, Gosselin did not have to keep the records that are standard in almost every modern medical setting.

An expert for the state disagreed.

Taking medical histories, obtaining prior medical records and following a standardized and accepted process to determine the right medical course in a patient’s care – including whether to exempt someone from a vaccination – is a bedrock element of good medical practice while preventing harm, said Dr. Kathryn Brandt, the chair of the primary care department at the University of New England’s College of Osteopathic Medicine.

Keeping detailed notes about how and why a doctor decided to take a particular step in someone’s treatment protects the patient, allows other doctors to understand earlier thinking and can provide a refresher for a physician months or years after a visit.

“(The letters) did not meet the standard of care,” Brandt said. “They did not take into account any observation of the patient. There is no delineation of thought process or defense of clinical decision-making. Doctor Gosselin failed to evaluate these patients.”

Gosselin testified that he signed the letters without having people complete intake paperwork or schedule in-person visits or telehealth appointments. Some of the exemptions were issued after phone conversations, and sometimes the caller was on the phone with his secretary and he was a few feet away.


Jenkins said that the health care workers who sought Gosselin’s signature were sophisticated about their health care decisions and were informed about the purported risks of vaccination and had already decided they would not get vaccinated. They sought Gosselin’s help to keep their jobs and were not looking for a medical diagnosis or treatment. One woman, referred to by her initials, J.S., said her email to Gosselin seeking an exemption letter was a “last-ditch effort” to save her livelihood.

“I do not believe in the vaccine and the mandate,” wrote the 28-year-old, who worked in an operating room at MaineGeneral Medical Center in Augusta. “I’ve applied for a religious exemption but was denied. I’ve already had and recovered from COVID-19. I love my job and I do not want to lose it.”

A former health care worker, Katie York, said her employer asked for more specific information from Gosselin in order to accept the exemption letter he had written for her, including citation of CDC guidelines, with which he did not appear familiar.

“What exactly does the CDC say about exemptions?” Gosselin wrote back to her when she asked for him to revise the language. York never responded and ultimately was fired from her position at MaineGeneral.

York was the first witness to testify in Gosselin’s defense. She said she spoke to him directly on the phone and he asked her questions about her history, including about a past adverse reaction to the seasonal flu vaccine. She said nothing in the letter he signed on her behalf was false, and she did not think he harmed her in signing it.

“I had expressed my experience, my concerns, what I was looking for, my intentions. He asked me some clarifying questions, and that was it,” York said of her conversation with Gosselin. “It was pretty direct.”


Gosselin’s legal team also demanded the recusal of one board member, Peter Michaud, a retired attorney for the Maine Medical Association, arguing that Michaud’s pro-vaccination posts on social media and commentary online that they characterized as showing contempt and derision for people who were skeptical of the vaccine or refused to get one showed an impermissible bias. But that motion and a second, last-minute request for reconsideration were rejected by hearing officer Rebekah Smith.

The hearing process operates under state administrative law and resembles a traditional court proceeding, but there is no judge. Instead, a hearing officer presides over the process, makes rulings on motions made by both sides and also functions as legal counsel for the board. Two prosecutors from the Attorney General’s Office brought the case against Gosselin and questioned him and other witnesses.

Gosselin’s attorneys began to present their defense Thursday but will have to resume it next month. It’s unclear when the board will issue a ruling, but it could occur as soon as the next monthly meeting. After the board renders a verbal decision, the hearing officer will craft a written decision.

Gosselin has been disciplined for professional misconduct before. In 1999, he was found to have responded to emergency calls after consuming alcohol and when he was not the on-call physician. In 2001, he impersonated his physician assistant and called two pharmacies in an attempt to obtain prescriptions for himself.

His next disciplinary case was decided in 2011, when the board determined that Gosselin had committed professional violations related to a romantic relationship with a woman who was also a patient.

In 2013, Gosselin was charged with operating under the influence after his erratic driving in Fairfield caused two cars to crash before Gosselin drove into a ditch and then left the scene. Although he had no alcohol in his system, Gosselin was displaying signs of impairment, and a urine sample ordered by Fairfield police found multiple narcotics in his system, including morphine, according to the osteopathy board.

His latest violation was in 2017, when he was found to have violated a probationary agreement. It’s not clear when he resumed practicing medicine.

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