The Lapsed License and Short CE File
A Missouri OT license expired on January 31. The OT believed her employer's credentialing office had filed the renewal and continued treating 14 clients per week for three weeks. On February 21 she learns the renewal was never submitted. She files an online renewal and uploads certificates showing 18 contact hours from the two-year cycle. The Board's renewal instructions state that 24 contact hours are required, and two certificates are from a course she attended but for which the provider has not issued credit because she has not paid the fee. Her supervisor says the clinic's credentialing file shows 'active' and tells her to keep working while the Board processes the renewal. A parent asks whether the OT is still licensed. The OT has no prior discipline and asks whether the late filing fixes the problem.
1. Was the OT authorized to treat clients between February 1 and February 21? What are the consequences?
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No. A Missouri license authorizes practice only while it is active. The employer's credentialing file, the clinic's internal 'active' label, and the supervisor's instruction do not create authority to practice. The OT should stop treating clients immediately when she learns of the lapse. Continuing to treat during the lapse can be treated as unlicensed practice and can expose her to discipline even though the lapse was administrative. Each of the approximate 42 client encounters during those three weeks is a separate concern for documentation, billing, and supervision. The late renewal application may eventually restore the license, but it does not retroactively authorize the sessions already delivered. The OT should notify the employer in writing, ask for reassignment of her caseload, and contact the Board about how to proceed. She should not wait for the Board to discover the lapse.
2. How should she handle the continuing education shortfall and the unpaid course?
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She should not claim credit for the unpaid course unless and until the provider issues valid credit, and she should not submit a renewal attesting to 24 hours when she has 18. She should immediately enroll in and complete at least six additional approved contact hours, keep certificates, and confirm the current cycle rules on the Board's website or by contacting Board staff. If the Board permits late completion or imposes a deadline, she should meet it. Backdating certificates or asking the provider to predate credit would turn an administrative problem into a falsification problem. She should also determine whether the renewal can be completed with a deficiency pending or whether reinstatement is required. A transparent explanation to the Board is stronger than a renewal form that overstates the hours.
3. What should she tell the parent and her employer?
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She should tell the parent the truth at an appropriate level: she is not currently authorized to provide OT services while her license status is resolved, and the agency is arranging coverage. She should not disclose unnecessary personal details or blame the credentialing office. To the employer, she should give written notice that she is ceasing patient care immediately, identify the clients affected, and request reassignment and a compliance review of the credentialing process. The employer should not bill for services delivered during the lapse without advice from compliance or counsel. The OT should keep copies of her notices and create a timeline of dates: expiration, last patient encounter, discovery, renewal filing, and CE completion. If the Board opens an investigation, she should cooperate and consult an attorney before providing a statement.