A San Diego doctor who has written an estimated 1,000 vaccine exemptions since 2015 is facing charges of repeated negligence from the Medical Board of California.

Dr. Tara Zandvliet is San Diego’s biggest doctor for the anti-vaxxer movement, especially in the city’s schools, where she’s written nearly a third of all vaccine exemptions for children. Now, the state’s health authorities are questioning her methods with a four-part complaint, first reported by the Voice of San Diego, accusing her of gross and repeated negligence, failure to maintain records, and unprofessional conduct.

In 2016, the father of a four-year-old girl sought Zandvliet’s help exempting his daughter from vaccines, according to the state complaint filed this month. The girl, referred to as Patient A, had already received some vaccinations, with none of the adverse effects that the anti-vaccination movement claims can come with immunization.

Nevertheless, Patient A’s father sought to exempt her from the shots required for kindergarten enrollment. Zandvliet allegedly sent him a link to her website, which contained a long list of illnesses, allergies, and skin conditions. If A’s father could “find 4 or more” family members affected by those conditions, “I could make a case that she likely has inherited a tendency to over reactive immune system,” Zandvliet wrote, according to the complaint.

A’s father replied that that his grandmother had experienced asthma and psoriasis, his mother had asthma and adverse reactions to some pain medications, his half-brother “had asthma when he was younger,” and his uncle had “asthma, psoriasis, eczema, and allergies to cat dander and dust.” “Do you think that would qualify?” he asked in an email.

Zandvliet said it would. A’s father then sent her letters from three of those relatives testifying to their illnesses, and a one-page medical record from his uncle.

“All of it looks fantastic!” Zandvliet wrote of the documentation. “Good job! I am putting you on the list of qualified and documented.” Later that month, without having met or examined A, Zandvliet wrote an email approving her for a vaccine exemption.

“I certify under penalty of perjury that I have personally examined the pertinent medical records of [Patient A’s] family, and find her qualified per California law SB277 for a medical exemption to vaccines,” she wrote.

If the decision was dubious in 2016, it would come under even greater scrutiny today. Following media reports, Zandvliet removed a number of familial medical conditions (including psoriasis and asthma) that she used as a basis for A’s vaccine exemption.

The new Medical Board filing is not a criminal complaint, but she could stand to lose her license. Zandvliet did not return a request for comment on Wednesday. She previously told the Voice that she recommended parents vaccinate their children.

“I can’t force them to do anything. But I can recommend it,” she said of vaccination, adding that skipping vaccinations “is a public health risk. It absolutely is. Each school needs to be above 95 percent vaccinated.”

Doctors cite the 95 percent figure as the baseline for establishing “herd immunity” in a community. When 95 percent or more of a population is vaccinated, an illness is unlikely to spread among the remaining 5 percent of people who are not immunized (often infants, the elderly, and people with specific medical conditions that prohibit vaccinations).

Despite medical recommendations, vaccination rates plummeted in California after a 2015 law allowed parents to exempt their children based on their personal beliefs. More than a dozen San Diego kindergarten classes have measles or whooping cough vaccination rates under 95 percent, including one school with a 50 percent measles vaccination rate.

A new state law, effective in 2021, would allow the state to step in when a school’s vaccination rate drops below 95 percent, or when one doctor writes more than five vaccine exemptions in a year.

Despite Zanvliet’s claim to promote vaccines, her conversations with patients include misinformation about immunization, including a myth about aluminum in shots, according to the medical board complaint.

She also allegedly told parents to “follow [their] gut” when deciding whether to vaccinate each child, and claimed to have used the same rationale for her own daughter, who was sure she was “going to get the flu this year and die” because she’d “felt it in [her] bones … that’s a pretty strong gut feeling. So I gave her the shot.”

In A’s case, vaccines appear to have been a point of contention in the family. A’s parents are divorced, and when the girl’s mother found out about the exemption, she asked Zandvliet whether she’d fabricated her daughter’s medical records. “[I]n terms of falsifying medical documents, it didn’t happen,” Zandvliet wrote, according to the medical board complaint. “I have the records direct from the doctor.”

That wasn’t true, the medical board says. The only family medical records she’d received came from the girl’s great-uncle. Those records showed he had psoriasis and dermatitis, which Zandvliet no longer allows as a basis for exemptions.

Eventually, after granting the exemption, Zandvliet conducted a brief examination of A, which consisted of watching her play with toys. "Respondent did not find any evidence in Patient A of an autoimmune condition," the complaint alleged.