The Renewal Gap
Marcus is a dental hygienist who moved from Ohio to Lexington. He held an active Ohio license for six years with no discipline. In January he applied for Kentucky licensure by credentials, submitted his Ohio verification, passed the Kentucky jurisprudence exam, and received a Kentucky license in March. He then changed jobs and missed the renewal deadline. His license lapsed on April 1. He continued seeing 14 patients between April 2 and April 22 because the office manager told him the Board "always gives a grace period." During that period he completed 24 hours of continuing education, but 10 hours came from unapproved in-office staff meetings. He now wants to renew, backdate his CE, and have the office bill third-party payers for the lapsed period. He asks whether his Ohio license is enough and what to do.
1. Did Marcus qualify for licensure by credentials, and what should he have verified before treating patients?
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Likely yes for eligibility, but eligibility is not the same as authorization to practice. Under KRS Chapter 313 and 201 KAR Chapter 8, the Board may issue a license by credentials to an applicant who holds an active, unrestricted license in another state with substantially equivalent requirements, has no disciplinary history, and passes the required jurisprudence examination. Marcus should have verified that his Kentucky license was active and noted the renewal date before seeing patients. The Ohio license does not authorize Kentucky practice, and the Board does not create a grace period by practice habit. Once the Kentucky license lapsed, he was unlicensed regardless of his Ohio status.
2. How should Marcus handle the CE deficiency and the lapsed-practice period?
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He must stop practicing immediately. The 10 hours from unapproved in-office staff meetings are unlikely to count as Board-approved continuing education, so he should replace them with approved courses and complete the full required hours. He must not backdate CE or ask the office to misrepresent the dates. He should contact the Board, disclose the lapse and the CE deficiency, and ask for the proper reinstatement process; the Board may impose a late fee, additional CE, or discipline. Practicing on a lapsed license is unprofessional conduct and can also create criminal exposure. He should keep proof of completion and a written timeline.
3. What are the billing and notification obligations for the lapsed period?
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Do not bill any payer for services delivered between April 2 and April 22. The office should identify those claims, correct or refund them, and document the correction. Marcus should notify his employer in writing that his license was lapsed and that he has stopped practicing. He should disclose the lapse to the Board in his reinstatement request. If patients were treated by an unlicensed provider, the office should consult its compliance officer or attorney about notification; at minimum, the records must accurately identify the provider. Falsifying a claim or backdating CE would compound the problem and is itself unprofessional conduct.