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The Texas License and the Missing Disclosure

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The Texas License and the Missing Disclosure

A dental hygienist licensed in Texas for six years applies for Louisiana licensure by credentials. She has an active Texas license, a current BLS card, and passed the NBDHE years ago. Three years ago, the Texas board issued a reprimand after an audit found her short 4 CE hours; she completed the hours and the reprimand is on her Texas record. On the Louisiana application, the question asks, 'Have you ever been disciplined by any licensing board?' She answers 'No' because the matter was 'just a CE audit.' While her application is pending, the Louisiana office where she has been hired schedules her to see patients next Monday and lists her as a 'hygiene coordinator' so she can 'get oriented.' The office manager says the Board 'probably won't check' and that the dentist will 'supervise' her.

1. Can she begin seeing patients Monday? Explain the licensure pathway.

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No. A Texas license authorizes practice in Texas; Louisiana requires a Louisiana license before she performs clinical hygiene services. Licensure by credentials is not automatic: the Board must verify her education, licensure history, examination scores, CPR, and any disciplinary history, and she must satisfy Louisiana's jurisprudence requirement. Calling her a 'hygiene coordinator' does not change the analysis if she is doing prophylaxis, scaling, radiographs, or patient assessment. A title cannot launder unlicensed practice. The dentist who allows her to see patients before licensure also risks discipline. She should tell the employer she cannot begin until the Board issues the license, and the office should reschedule or assign a licensed hygienist. If she is only completing non-clinical orientation, she should confirm in writing that no clinical duties will be performed.

2. Analyze the disclosure question and the consequences of the 'No' answer.

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The question asks about any licensing board discipline, not just serious discipline. A reprimand is discipline, even if it arose from a CE audit and was resolved. Answering 'No' is a false statement on a licensure application. The Board can obtain the Texas record through verification, so the omission is likely to be discovered. Consequences can include denial of the application, a disciplinary action in Louisiana, and a finding of unprofessional conduct for misrepresentation. The fact that the underlying matter was minor does not excuse the omission; candor is the issue. She should amend the application immediately in writing, explain the Texas reprimand, and provide the Texas board order and proof that she completed the CE. Voluntary correction before the Board discovers it is far better than waiting.

3. What steps should she take now?

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She should (1) stop any clinical activity in Louisiana until licensed; (2) notify the employer in writing; (3) contact the Board to amend the application and disclose the Texas reprimand; (4) gather the Texas license verification, the reprimand order, CE completion proof, NBDHE scores, diploma or transcripts, BLS card, and any jurisprudence exam documentation; (5) ask the Board whether a temporary or provisional status is available-do not assume; and (6) keep a copy of every submission. She should also review the Louisiana CE and renewal rules so she understands what will be required after licensure. If the Board asks why she answered 'No,' she should be direct: she misunderstood the scope of the question, but she is correcting it now. Minimizing or blaming the office will not help; ownership and correction will.