Continuing Education Audit and Three Weeks of Expired Practice
An OT has held a Michigan license for 6 years and works in outpatient hand therapy. Her license expired on October 31. She continued treating patients for 3 weeks because the clinic scheduler did not flag it; she thought renewal was automatic. She now submits a renewal application with 24 continuing education hours: 10 hours from a weekend webinar by a national vendor not approved by the Michigan Board, 6 hours from a local conference approved by the Board, 4 hours of ethics from an approved provider, and 4 hours of 'practice management' from her employer. She also asks whether she can backdate her renewal to the expiration date and whether she can keep treating while the application is pending. The clinic owner tells her to 'just keep working; nobody checks.'
1. Does her 24 hours of continuing education satisfy Michigan renewal requirements? Analyze each category.
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Not necessarily. Michigan OT renewal requires a biennial set of continuing education contact hours, and the Board's rules require the hours to be from Board-approved providers or programs and to include specified content such as ethics. Her 6 hours from the Board-approved local conference and 4 approved ethics hours are the strongest. The 10 hours from a national vendor not approved by the Michigan Board may be rejected unless the vendor or program has the required approval. The 4 employer 'practice management' hours may count only if the employer program is approved and the content is relevant to OT practice; generic management may not. She should not assume 24 hours is enough by number alone. She should audit the certificates, replace unapproved hours with approved OT-relevant courses, and keep documentation for renewal audit.
2. Can she backdate the renewal or keep treating while the application is pending? What are the consequences of the 3 weeks of practice?
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No. A license expires on its expiration date; renewal after the fact does not backdate authority to practice. Practicing on an expired license is unlicensed practice, even if the lapse was an administrative mistake and even if the clinic scheduler missed it. The application being pending does not authorize practice; she must stop treating until LARA issues an active license or other authorization. The 3 weeks may be investigated and can be grounds for discipline, and the employer may have billing and compliance exposure. She should notify the employer immediately, stop clinical work, keep a written timeline, and respond truthfully to the Board. She should not alter records to hide the lapse.
3. What steps should she and the clinic take now?
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She should immediately stop patient care, tell the clinic owner and compliance officer, and submit the renewal or reinstatement application with accurate dates. She should obtain qualifying CE, document it, and pay any late or reinstatement fees. The clinic should remove her from the schedule and billing until licensure is confirmed, audit the 3 weeks of claims, and correct any claims submitted under an expired license. She should not follow the owner's advice to 'keep working.' If the Board sends a request, she should cooperate and provide the timeline. The clinic should also build a license-expiration tracking system so this does not recur.