The Lapsed CE and the Renewal Deadline
Dr. Okafor's Arkansas license renewal is due June 30. On June 15 she reviews her records and finds she has completed 12 of the required continuing education hours. Six of those hours were a self-study webinar on practice management that was not Board-approved and did not carry a provider number. She also has 4 hours of approved glaucoma CE from a national meeting and 2 hours of approved ethics CE. She is scheduled to take a 6-hour approved course on July 10, after the deadline. Her employer tells her to 'just submit what you have and fix it later.' She asks whether she can simply pay a late fee and renew in August.
1. Assess Dr. Okafor's CE compliance as of the June 30 deadline and whether the employer's advice is sound.
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Counting only Board-approved hours:
- 4 hours glaucoma (approved) + 2 hours ethics (approved) = 6 qualifying hours.
- The 6-hour practice-management webinar does not count: it was not Board-approved and lacked a provider number.
Shortfall: She is 6 hours short of the typical annual requirement (assuming a 12-hour annual cycle; the exact number is set by Board rule and must be verified against the current rule in effect).
Employer's advice is not sound. Submitting a renewal attesting to completed CE that has not been completed is a false attestation and grounds for discipline. 'Fix it later' does not cure a false statement.
Correct path:
- Take an approved course before June 30 if possible, or
- Apply for an extension or hardship waiver if the Board's rules permit one, and
- Renew truthfully, disclosing the shortfall and the plan to cure it.
Paying a late fee in August does not retroactively create CE hours completed after the deadline unless the Board grants an extension.
2. Dr. Okafor renews on time but reports only the 6 approved hours, and the Board audits her. What is her likely exposure, and how does the July 10 course affect it?
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Exposure:
- Deficiency citation / conditional renewal: the Board may renew with a condition requiring completion of the missing hours within a set period.
- Discipline: if the shortfall reflects a pattern or a false statement, the Board may impose a reprimand, fine, or suspension. A single good-faith shortfall disclosed truthfully is usually treated as a deficiency, not fraud.
- The July 10 course can cure the deficiency going forward, but it does not count toward the cycle that ended June 30 unless the Board's rules allow a grace period or the Board accepts it as a cure condition.
Practical steps: keep certificates, provider numbers, and course approvals; respond to the audit promptly; and request that the July course be credited to the cure plan if the Board permits.