Twelve Hours Short and Still Treating Patients
A 51-year-old chiropractor moved across Indiana eight months ago and did not notify the Board or update her address. Her license expired three months ago. She completed 12 of the 20 continuing education hours required for the biennium, including no ethics hours, and assumed the remainder could be made up later. She continues to treat about 15 patients per week and bills Medicare and a commercial insurer under her old license number. The office manager schedules new patients and tells them the doctor is 'fully licensed.' A patient complaint about a billing dispute prompts the Indiana Professional Licensing Agency to open a file. The chiropractor says she is 'basically licensed' because she paid the renewal fee late and has been in practice for 25 years.
1. What is her licensure status, and may she continue treating and billing patients? Explain.
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Her license is expired, not 'basically licensed.' Paying a late fee does not revive a lapsed license, and 25 years of practice does not create authority to treat patients without a current license. She must stop seeing patients and stop billing immediately. Treating patients after expiration is unlicensed practice, and billing Medicare or a commercial insurer under an expired license number is a separate serious problem that can be treated as fraud. The fact that the office manager tells patients she is 'fully licensed' adds a misrepresentation risk. The 12 of 20 CE hours and the missing ethics hours are also unresolved; continuing education is a condition of renewal, not something that can be made up after the fact while she keeps practicing. She should notify the clinic staff, cancel or transfer appointments, secure patient records, and respond to the IPLA inquiry through counsel. She should not submit claims for services rendered during the lapse.
2. What steps must she take to restore her license, and what disciplinary exposure does she face?
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To restore the license, she should complete the full 20 hours of continuing education for the biennium, including the required ethics component, update her address with the Board and IPLA, pay the renewal and any late fees, and file a reinstatement or renewal application as directed. She may need to explain the lapse and the continued practice in writing. The Board can impose discipline for unlicensed practice, failure to meet CE requirements, failure to notify the Board of an address change, and false billing. Possible sanctions include a reprimand, civil penalty, probation with conditions, suspension, or revocation; the Board may also require extra CE or a practice monitor. Because insurers were billed, she may face recoupment, network termination, or referral for fraud. She should cooperate, correct the records, and avoid any further patient contact until the Board confirms reinstatement. A written compliance plan and legal representation are prudent.