Expired License, CE Audit, and the Employer Who Says Keep Working
You are an OT in Elko. Your Nevada license expired on March 31. You believed you renewed it in February and paid $190 online, but on April 14 you receive a board letter stating no renewal was received and that your CE records are also under audit. You have worked nine shifts since April 1. In the last two years you completed 18 CE hours, including 1 hour of ethics. Your CPR card is current. Your employer says, 'Keep working; the board is slow, and patients need you.' The board's letter directs you to submit a written response within 21 days and warns that practicing on an expired license may lead to disciplinary action. You have not yet called the board.
1. Can you continue working after March 31? What should you do immediately?
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No. A Nevada OT license is required to practice, and an expired license means you are not authorized to provide occupational therapy, even if you believed you renewed and even if your employer tells you to keep working. Practicing on an expired license can subject you to board discipline and possibly criminal or civil consequences; the employer cannot waive the license requirement. Stop patient care immediately, notify your supervisor in writing, and ask that your assignments be covered by a currently licensed OT. Do not document or bill for services you provide while unlicensed. Preserve the board letter and any renewal or payment records. Call the Board promptly to confirm your status and ask what is needed to renew or reinstate. If patients are mid-treatment, arrange a safe handoff and document the transition according to facility policy. Do not treat the board's delay or your belief that you paid as a defense to continued practice.
2. What must you complete for CE and renewal, and how should you handle the audit?
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Nevada requires 24 hours of approved continuing education per biennial renewal period, including at least 2 hours in ethics. You have 18 hours, including only 1 ethics hour, so you need 6 more hours, including at least 1 more ethics hour, before you can certify completion. Take Board-approved courses and keep certificates, agendas, and proof of completion. Submit the renewal or reinstatement application with the required fee and any late fee, and respond to the CE audit within the Board's deadline. Do not backdate or invent CE. If a course you took was not Board-approved, it may not count; confirm before submitting. Keep a personal CE log. Because you practiced after expiration, the Board may review that separately; completing CE does not erase the lapse. Ask the Board whether you need a reinstatement application rather than a standard renewal, and follow its written instructions.
3. What disciplinary outcomes should you anticipate, and how should you respond to the Board?
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Anticipate a board inquiry into both the expired license and the nine shifts worked after expiration. Possible outcomes include a reprimand, fine, probation, additional CE, supervised practice, or other discipline; the Board could also refer unlicensed practice for further action. Do not minimize or blame the employer. Respond in writing within 21 days, state the facts, provide payment and renewal records, identify the dates you worked, and show corrective steps: stopped working, notified employer, completed CE, applied for renewal or reinstatement. Be honest about the CE shortfall. Ask for clarification if the notice is unclear. Do not contact the complainant or alter records. Consult a licensing attorney if the notice alleges unprofessional conduct or unlicensed practice. Continue to refrain from patient care until the Board confirms active status. Keep copies of all correspondence and document your compliance steps.