The CE Audit and the Lapsed Renewal
Karla, an LCPC in Montgomery County, missed her license renewal deadline by 45 days. The Board's online portal showed 'expired,' but Karla continued seeing 12 clients because her employer's credentialing office said the renewal was 'in process.' She submitted 30 continuing-education hours: 12 from a podcast series not approved by the Board, 6 from an approved ethics workshop, and 12 from a conference brochure that lists a provider number she cannot verify. The Board sends an audit letter requesting certificates and an explanation of practice after expiration. Karla's employer asks her to sign a statement saying she was 'continuously licensed.' Karla has no prior discipline and is panicked.
1. What are the consequences of Karla's expired license, and what should she do immediately?
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Practicing after the license expired is unlicensed practice, even if renewal is 'in process.' Karla should immediately stop seeing clients until the Board confirms reinstatement or issues a valid license. She should notify her employer in writing, remove herself from billing and clinical scheduling, and cooperate fully with the Board. She should complete the reinstatement process, pay any late fees, provide the required CE documentation, and explain truthfully the dates she practiced after expiration.
The Board may impose discipline, including a reprimand, probation, suspension, or other conditions, depending on the facts and her candor. Her lack of prior discipline may mitigate but does not erase the violation. She should not continue practicing while the audit is pending. She should also arrange coverage for current clients and document the transition so clients are not abandoned.
2. Evaluate Karla's CE submission and explain how she should respond to the audit.
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Karla must submit only hours she can document and that meet the Board's approval rules. The 6-hour ethics workshop from an approved provider is likely acceptable if the certificate shows the provider, date, hours, and topic. The 12 podcast hours are questionable unless the series is Board-approved or otherwise qualifies under the regulations; unapproved podcasts may not count. The 12 conference hours are also questionable because she cannot verify the provider number, so she should not represent them as approved without proof.
She should respond honestly: identify which hours she can verify, acknowledge any shortfall, and propose a remediation plan to complete acceptable CE before or as a condition of reinstatement. She should not alter certificates, create provider numbers, or submit hours she knows are unverifiable. If she is unsure whether a program qualifies, she should ask the Board before claiming it. Candor and correction are more protective than a false or exaggerated submission.
3. How should Karla handle the employer's request to sign a statement that she was 'continuously licensed'?
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Karla should refuse to sign a false statement. She was not continuously licensed during the 45-day period after expiration, and signing a contrary statement could constitute falsification, jeopardize her license further, and expose her employer. She should provide a factual statement with the expiration date, the date she stopped practicing, the reinstatement date, and the steps taken. She should ask the employer to correct any credentialing records that inaccurately show continuous licensure.
If the employer pressures her or retaliates, she should document the request and seek legal or Board guidance. Her ethical duty is honesty to the Board and to clients. She should also ensure that any client communications about the lapse are accurate and limited to what clients need to know. The priority is to correct the record, comply with reinstatement requirements, and avoid compounding the original violation.