Telehealth Across State Lines and the Expired License
Priya is an OTR licensed in Alaska, working for a telehealth company. She is based in Anchorage and treats Alaska clients via video. In March she accepts a new client who recently moved to Fairbanks - but the client's home address in the intake system is listed as Washington state because the family has a winter home there. Priya's Alaska license renewal lapsed 20 days ago; she submitted the renewal but the board has not yet processed it. Her employer says, "Just keep treating, the renewal is in the pipeline." She has 14 active clients and is scheduled for 9 visits this week. She also has not completed her continuing competence documentation for the prior cycle, which she believes she can "catch up on" next month.
1. Analyze Priya's licensure status and whether she may continue treating this week.
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Practicing on a lapsed license is unlicensed practice, even if a renewal is pending. "In the pipeline" is not a license. Priya should stop providing services that require licensure until the license is active or she has written confirmation of a valid temporary/grace status from the board. She should verify whether Alaska offers a grace period or temporary authorization - she cannot assume one exists. She should notify her employer in writing, document the dates, and contact the board immediately to expedite. Continuing to treat 14 clients on a lapsed license exposes her to disciplinary action and the employer to liability, and it is not excused by employer instruction.
2. What is the jurisdictional issue with the client who has a Washington address, and how should Priya resolve it?
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Telehealth licensure generally follows the location of the client at the time of service. If the client is physically in Washington during sessions, Priya may need Washington authorization (or to qualify under an applicable interstate compact/privilege, if one applies to OT and to that state). If the client is physically in Alaska, Alaska licensure governs. Priya must confirm the client's actual physical location at each session and document it. She should not rely on a stale intake address. If Washington licensure is required and she lacks it, she must arrange coverage or refer until authorized.
3. How should Priya handle the missing continuing competence documentation?
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She should not fabricate or backdate records. She should review the actual requirements, gather genuine evidence of completed activities, and report honestly what she did and did not complete, using any permitted remediation or late-completion process the board allows. If she is short, she should complete the deficiency going forward and disclose it accurately on her renewal. Misrepresenting continuing competence is a separate disciplinary ground from the lapsed license and compounds the problem.