The Lapsed License and the Late Fee
Dr. B holds a Michigan chiropractic license. Her two-year license cycle expired on October 31 of the last odd-numbered year. She completed 24 hours of continuing education, including 2 hours in ethics and 2 hours in pain management, but not the full 30 hours required for her cycle. She moved her office in August and did not notify the licensing agency. On November 14, she treated 17 patients and submitted insurance claims. On December 1, she renewed online, answered “no” to a question asking whether she had practiced while unlicensed, and paid a late fee. Her employer says the late fee makes everything retroactive. Dr. B also advertises “board-certified” although she holds no specialty board certification beyond her Michigan license. She asks whether she can keep treating patients while the agency processes the renewal.
1. Was Dr. B authorized to treat patients on November 14? Explain the effect of the December 1 renewal and late fee.
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No. A Michigan chiropractic license must be active to practice. If the license expired on October 31, Dr. B was unlicensed on November 14, even if she later renewed and paid a late fee. Renewal is not retroactive; the late fee is a processing consequence, not a grant of authority for past practice. Treating 17 patients and submitting insurance claims during the lapse can be unlicensed practice and may also create billing/insurance problems. Her 'no' answer on the renewal application is a separate integrity issue because she had practiced while unlicensed. She should stop treating patients until the license is shown active, confirm the status in writing, and consult counsel about self-reporting. The employer's statement does not change the legal status; only the licensing agency can determine licensure.
2. Identify the separate compliance problems beyond the lapsed license.
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Beyond the lapse, Dr. B has a continuing-education shortfall: 24 hours is below the required 30 for the cycle, and the missing mandated hours must be completed. She failed to notify the agency of her office move, which can interfere with official notices and is a separate administrative violation. The renewal answer 'no' is inaccurate and could be treated as a false statement on a licensing application. Advertising 'board-certified' without holding the relevant specialty board certification is potentially misleading advertising, even if she holds a Michigan license. Each issue should be corrected separately. Dr. B should not assume the late fee resolves anything. She should gather CE certificates, correct the address, review the ad, and prepare a truthful explanation.
3. What should Dr. B do now to reduce exposure?
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Dr. B should immediately suspend patient care until she verifies active licensure. She should complete the missing CE, including any required subject areas, and keep certificates. She should correct her address with the licensing agency and review all public advertising, removing 'board-certified' unless it is accurate and can be documented. She should consult a health-care attorney about correcting the renewal application and whether self-reporting the lapse is appropriate. She should notify her malpractice carrier and review insurance claims submitted during the lapse with her billing compliance officer. She should document the steps taken. She should not backdate anything or ask staff to change records. If the agency opens an investigation, she should respond truthfully and on time. The board may impose sanctions, but prompt correction and candor can reduce risk.