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The June 30 Renewal and the Unapproved CE Provider

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The June 30 Renewal and the Unapproved CE Provider

Dr. A has held a Louisiana psychology license since 2011. In August she moved from Baton Rouge to Monroe and began seeing clients at a new office, but she did not notify the Board of the address change. Her annual renewal is due June 30. She submits the renewal fee and attests to 30 continuing education hours: 12 hours of recorded webinars from a for-profit online company that is not on the Board's approved-provider list; 8 hours labeled ethics (4 from a Board-approved workshop and 4 from a podcast with no learning objectives or post-test); and 10 hours from an APA-approved convention. In September the Board sends an audit letter requesting certificates, an explanation of the address discrepancy, and a corrected renewal form. Dr. A has kept receipts but no certificates for the podcast. She asks whether she can simply wait until next year to make up any shortfall.

1. Identify the licensure and renewal deficiencies in Dr. A's file and explain which CE hours are most vulnerable to disallowance.

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Start with the administrative defect: Dr. A moved and opened a new practice location without promptly notifying the Board. Louisiana licensing rules require current address information, and an outdated address can cause missed Board notices, including renewal and audit correspondence. That is a separate issue from the CE audit and should be corrected immediately.

On CE, the total is 30 hours, but totals alone do not satisfy the rule. The 12 webinar hours are vulnerable because the provider is not on the Board's approved-provider list; approval status matters, not just the topic. The 4 podcast ethics hours are vulnerable because the format lacks learning objectives and a post-test, and Dr. A has no certificate. The 4 Board-approved ethics workshop hours and the 10 APA-approved convention hours are the strongest. If the Board disallows the 12 webinars and the 4 podcast hours, only 14 acceptable hours remain, leaving a 16-hour shortfall.

The analysis should separate what is documented from what is merely attested. Dr. A should not assume the Board will allow her to defer the shortfall to next year; renewal is annual and the Board may require completion within a cure period or treat the renewal as incomplete.

2. What should Dr. A do now, and what are the possible consequences if she does nothing?

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Dr. A should respond to the audit in writing before the deadline, update her address, and provide every certificate she has. For the podcast, she should explain the deficiency rather than manufacture documentation. She should ask the Board whether it will accept a corrective plan and, if so, complete approved ethics and general CE hours to replace the disallowed hours. She should keep a CE log that identifies provider, date, hours, format, and approval status.

Doing nothing is the worst option. If the Board treats the renewal as incomplete, her license may not be renewed; practicing after expiration can be treated as unlicensed practice and may expose her to cease-and-desist action, disciplinary charges, and difficulty with insurers or PSYPACT. Even if the Board allows a cure, late fees and an audit flag are likely. The safer course is prompt disclosure, correction, and documentation of remediation. This is also a good reason to calendar the address-change and CE-certificate requirements separately from the renewal payment.