Expired license, incomplete CE, and an online attestation
An OT in Santa Fe missed the December 31 renewal deadline. She continued treating patients for 18 days in January because her employer's credentialing office said the license was 'in grace.' Her CE file contains 20 hours: 8 from an AOTA conference, 4 from an employer in-service on lifting mechanics, 4 from a live ethics webinar approved by the Board, and 4 from a Facebook Live presentation with no provider approval. The renewal form asks her to attest that she completed all required CE and that her license was active during the practice period. She has not been disciplined before and wants to renew online immediately.
1. What are the consequences of practicing after the license expired, and what should she do now?
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Stop practicing immediately. A license expiration is not the same as a grace period for clinical practice unless the Board has issued a specific extension or temporary authorization. Treating patients after expiration can be unlicensed practice and can expose her to Board discipline, employer sanctions, and billing problems. The credentialing office's statement is not a legal opinion from the Board.
Contact the Board and use the correct reinstatement path. She should ask whether her license is expired, inactive, or suspended, and whether late renewal or reinstatement is available. She should pay required fees, submit a truthful explanation of the lapse, and provide CE documentation. She should notify her employer in writing that she is not practicing until the Board confirms active status.
Do not backdate or misrepresent. The renewal attestation must be truthful. She should not claim the license was active during January or sign off on CE she cannot substantiate. Self-reporting the lapse is generally better than waiting for a complaint.
2. Which CE hours can she count toward renewal, and what should she do about the shortfall?
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Apply the Board's approval and category rules, not just the hour count. AOTA conference hours and a Board-approved live ethics webinar are strong candidates if she has certificates and the content is relevant. The employer in-service may count only if it meets the Board's requirements for approved providers, documentation, and relevance; an internal training is not automatically approved. The Facebook Live presentation is the weakest: unless the provider and activity were Board-approved and she can document attendance and content, it likely cannot be counted.
Assume she may be short and fix it before attesting. She should review the current New Mexico OT CE rule for the required number of hours, ethics hours, and allowable self-study or online formats. If any hours are disallowed, she should complete additional Board-approved CE and retain certificates. She should not submit an attestation that she knows is inaccurate, because false CE reporting is a disciplinary risk separate from the lapse.
Keep a CE log. A simple table with date, provider, title, hours, approval number if any, and certificate location will support renewal and any audit.
3. How should she handle the renewal form's statement that her license was active during the practice period?
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Answer truthfully and explain. If the form asks her to attest to active licensure during a period when she was expired, she cannot sign as if nothing happened. She should complete the form accurately, attach a brief timeline, and explain that she stopped practicing when she learned of the lapse. If the online system will not allow a truthful submission, she should contact the Board for the correct procedure rather than force a false attestation.
Distinguish the lapse from the CE issue. The Board may treat unlicensed practice and false attestation as separate concerns. A candid correction, cooperation, and a plan to prevent recurrence are mitigating facts. She should also review her employer's credentialing process and set calendar reminders before the next renewal.