The Lapsed License
On February 10, Ms. P, a PT in a small DC clinic, realizes her license expired on January 31. She has continued to treat 22 patients over six weeks and has signed Medicare and private insurance claims using her expired license number. Her CE file contains: 12 hours of online courses from a provider not approved by the DC Board; 2 hours of ethics from an approved provider; 4 hours of CPR; and 10 hours of teaching a continuing education course for PTs, for which she has a letter from the course sponsor but no certificate. She completed renewal but did not report the lapse. The clinic owner says, 'The Board never audits; just backdate the CE certificates.' A front-desk employee who is not licensed has been performing ultrasound under the owner's direction.
1. What are the consequences of practicing on an expired license, and what must Ms. P do now?
Read the worked answer
Practicing on an expired license is prohibited. Each of the 22 patient encounters and each claim submitted may be a separate violation and may also create insurance-fraud exposure. Ms. P must stop treating immediately, complete the renewal, pay any late fee, and notify the Board in writing of the lapse. She should not backdate anything. She should notify her employer and billing staff to hold or correct claims. The Board may impose discipline, but self-reporting and remediation are mitigating factors.
2. Evaluate her CE documentation against the renewal requirement and identify what she needs.
Read the worked answer
DC requires approved CE for renewal, and the biennial requirement is 30 hours. Even if all 12 online hours counted, she has only 24 hours (12 + 2 + 10), and CPR is generally not CE for PT licensure unless the Board specifically approves it. The 12 online hours from a non-approved provider are questionable unless the Board accepts the provider or the courses. The 2 ethics hours from an approved provider likely count. Teaching may count if the Board approves and she has documentation, but a sponsor letter is not a certificate. She needs to obtain certificates, replace non-qualifying hours with approved courses, and retain records. She should not claim hours she cannot document.
3. What should Ms. P do about the unlicensed employee and the owner's instruction to backdate certificates?
Read the worked answer
The unlicensed front-desk employee must not perform ultrasound. That is unlicensed practice, and the PT must not aid it. Ms. P should stop the practice, document it, and report it to the Board and the clinic's compliance officer. The owner's instruction to backdate certificates is false documentation and must be refused. Ms. P should not alter CE records. She should keep a written record of the owner's instruction and her refusal, because she may need it in a Board inquiry.