The Continuing Education Audit
After 15 years licensed in Idaho, you obtained Montana licensure by comity 18 months ago. Your first Montana biennial renewal is due June 30. You submit a renewal attestation claiming 30 PDH. Your file shows: 8 hours attending a national survey conference (sessions on boundary law and drones); 6 hours teaching a "Boundary Evidence" course at a community college (first time teaching it); 7 hours of self-study reading NCEES manuals and watching recorded webinars; 4 hours of your firm's annual safety training (hazard communication, ladder safety); 3 hours of a Montana Board law and rules webinar; and 2 hours of a vendor's sales demo for new total station software. You also carried over 6 hours from the previous cycle. You have certificates for the conference and the law webinar, but only a personal log for the self-study and teaching.
1. Evaluate each category against Montana CE requirements and identify the strongest and weakest credits.
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Strongest: the 8 hours of conference technical sessions and the 3 hours of Montana law and rules webinar are directly relevant and documented. Teaching may qualify if the Board allows teaching credit and it is first-time preparation, but the personal log is weak; a college letter and syllabus are needed. Self-study may be capped or not accepted without structured verification; reading manuals and watching recorded webinars often needs documentation. The 4 hours of safety training are not surveying CE-hazard communication and ladder safety do not maintain surveying competence. The 2-hour vendor sales demo is marketing, not education. Carryover may be subject to a cap and must have been eligible in the prior cycle. The licensee cannot simply add the numbers to 30.
2. What should you do before submitting if you cannot document the teaching and self-study hours?
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Do not attest to undocumented hours. Obtain documentation for the teaching and any structured self-study; replace nonqualifying safety and sales-demo hours with documented surveying, ethics/law, or technical courses; if short, complete additional qualifying PDH before June 30; and keep records for the audit period. If the requirement cannot be met, contact the Board about inactive status or an extension before the deadline, not after. A first renewal after comity licensure is a common audit target, so the file should be complete.
3. If audited and found short, what are the consequences and the proper response?
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The Board may deny renewal, require additional CE, impose a fine, or discipline the license. The proper response is truthful cooperation, production of records, and a remediation plan. Backdating or fabricating records is a separate and more serious violation. The surveyor should identify which hours were nonqualifying and cure the deficiency promptly rather than argue that the total number was close enough.