The Renewal Notice Went to the Old Apartment
A dental hygienist licensed in Connecticut moved from New Haven to Bridgeport in April and did not update her address with the Department of Public Health. Her license expired on June 30. The renewal notice went to the old apartment. She continued working four days a week through August 15 at a Norwalk practice. The office manager copied the old wallet license for the credentialing file and never checked the online verification. The hygienist completed 12 hours of continuing education in the two-year period, including a two-hour infection-control course, and assumed that was sufficient. The renewal form she downloaded states that a dental hygienist must attest to 20 hours per two-year period, including the infection-control hours. On August 16 a patient asks for her license number, and the front desk cannot find a current verification. The hygienist says she is “probably still in a grace period” and asks to finish the day’s schedule.
1. What is the legal status of the hygienist’s work after June 30, and what should she do on August 16?
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The work after June 30 is unlicensed practice. A Connecticut dental hygiene license expires on its stated date; renewal is not automatic, and a notice sent to an old address does not extend the license. The licensee has an affirmative duty to keep her address current with the Department of Public Health, so the missing notice is not a defense. On August 16 she must stop seeing patients immediately, inform the employer, and remove herself from the schedule until the license is active and verified. She should update her address, apply for renewal or reinstatement under the current procedure, pay the required fees including any late fee, and keep proof of the active license. Reasoning: the patient’s request for a license number exposed the gap, but the legal problem began on July 1. Continuing to treat patients would compound the violation, and the employer should not bill for hygiene services as though a licensed hygienist provided them. The Board may treat unlicensed practice as grounds for discipline in addition to any civil penalty.
2. Evaluate her continuing-education position and her ability to renew. Include the role of the employer’s credentialing file.
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Her CE is short on its face. The renewal form she has states a 20-hour requirement for the two-year period, and she has only 12 hours. The two-hour infection-control course may satisfy the infection-control component, but it does not cure the missing eight hours. She cannot truthfully attest to completion before she completes the hours; backdating certificates or claiming hours she did not earn would be a separate integrity violation. She should complete acceptable CE, obtain documentation, and then renew. Credentialing file: the office manager’s copy of an old wallet license is not verification. The practice should check the DPH online license lookup at hire and before each renewal cycle, and should maintain a copy of the current verification. Reasoning: the employer’s administrative error does not license the hygienist, but it is relevant to the practice’s compliance failure. The hygienist remains personally responsible for her own license status and CE attestation.
3. Could the practice face consequences for allowing her to work, and what should it do now?
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Yes. A dental practice that schedules a hygienist and bills for hygiene services when the hygienist’s license has expired risks billing and licensure exposure, and it may have reporting obligations depending on the facts. The practice should immediately remove her from patient care, confirm her license status in writing, audit appointments and claims from July 1 through August 16, and consult counsel about any required notices or corrections. It should also fix its credentialing process so that a wallet copy is never treated as verification. Reasoning: the practice is not a passive bystander; it controls scheduling and billing. The hygienist’s own duty to maintain a current license does not eliminate the employer’s duty to verify credentials. The strongest immediate step is to stop the unlicensed practice, document the corrective action, and avoid any record entry that suggests she was licensed when she was not.