An Expired Registration, a Fourth Site, and Teleconsultations Across Provinces
Dr. T registered five years ago. Her registration lapsed 14 months ago after she missed the renewal window during a family illness. Her practice licence for Klinik A in Bandung expired six months ago. She still holds apparently valid site licences for Klinik B in Cimahi and Klinik C in Jakarta, and she has continued seeing patients at all three, telling herself that renewal is "being processed" and the clinic manager assured her it was fine. Klinik D in Surabaya now wants her four days a month, which would make four sites. She also contracts with a health app that forwards photographs and symptom descriptions from users in five provinces; last week a user sent a photo of a fractured crown and asked her to send a prescription to a pharmacy in another city. Her continuing education record for the last five years shows two webinars, roughly 12 credits.
1. Can Dr. T continue treating patients at Klinik A, or at the sites whose licences are still valid, while her renewal is pending? Reason through the consequences.
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No, at none of the three.
Registration is the personal authority to practise; the site licence is the permission to practise at a particular place. They are cumulative, not alternative. A lapsed registration is not suspended, it is absent, and "being processed" describes an administrative queue, not a legal status. At Klinik A both layers are missing. At B and C the site licence is intact but the personal registration behind it is not, so the site licence authorises nothing.
Concrete consequences. Every clinical note she writes in this period is signed by someone without authority, which weakens the clinic's position and her own if any case goes wrong. A complication, an adverse drug reaction or a retained root becomes indefensible, and professional indemnity cover typically excludes unregistered practice. The clinic that schedules her is also exposed for employing an unregistered practitioner. Administrative sanctions and, depending on the statute, criminal liability for unauthorised practice attach to her, not to the manager who offered reassurance.
What she should do now. Stop clinical work immediately and say so in writing to all three clinics, so the instruction is on the record. Keep non-clinical work only: management, training, audit, patient recall calls. Handle incoming patients by directing them to a licensed colleague, and record that she did so. A manager's assurance is not a defence; the registrant owns the status of her own registration.
2. Analyse the fourth site and the app-based teleconsultation. Is either arrangement lawful as proposed, and what would make it lawful?
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Fourth site. The working assumption under the practice statute and its implementing rules is a maximum of three practice locations, each requiring its own site licence issued through the local health authority for that location. Four is over the ceiling, and the ceiling is not a formality: it exists so that a practitioner can actually supervise and be present. Even if the current health law has moved this number, the planning assumption should be three until the implementing regulation is checked, and the check is the dentist's job, not the recruiter's.
Geography matters too. A licence is site-specific and issued locally. Working in a fourth province on a Bandung licence is not a workaround.
Teleconsultation. It is practice, not publishing, so it requires a valid registration and a platform operating as a lawful health facility. Some functions are safe at a distance: triage, advice, review of an existing patient, referral. Prescribing from one photograph for a fractured crown, for a patient she has never examined, in a city where she cannot follow up, is not. She cannot test vitality, percussion, periodontal status or occlusion, and the prescription ends her involvement while the patient carries the risk. The correct response is to decline the prescription, advise an in-person examination, and, if there is pain or swelling, direct the patient to a local licensed dentist urgently.
3. Design a realistic recovery plan for Dr. T, including the record problems created by 14 months of unregistered practice.
Read the worked answer
Sequence it, because the steps depend on each other.
Close the exposure. Written notice to all three clinics that she has stopped clinical work; written notice to the app that she is suspending consultations. Date everything.
Restore registration first. Address the renewal requirements, including the continuing-education shortfall. Twelve credits in five years is far below what most renewal schemes expect, so she should expect to complete a structured programme rather than a weekend webinar, and should keep certificates indexed by date.
Then the site licences. Apply at no more than three sites, each through the authority for that location, and only after the personal registration is restored.
Audit the dark period. Pull every record she created while unregistered. Do not alter or backdate them; add a dated note identifying the treating practitioner and the registration status if the clinic's record system allows it. Identify patients with ongoing treatment, unfinished crowns, recent extractions, or antibiotics, and contact them so a licensed colleague can review. Continuity of care, not confession, is the framing.
Decide on Klinik D. She cannot take it. Declining in writing protects her if the recruiter later claims she withdrew without notice.
Expect a complaint. A pharmacist, a competitor or a patient may report the gap. Voluntary remediation before a complaint is investigated is treated very differently from remediation after.