CE Audit Three Months After Renewal: The Attestation That Was Not True
Devon has held an Ohio dental hygienist license for 11 years and works four days a week in a suburban practice. At his last renewal he attested on the online form that he had met the continuing education requirement and that his CPR certification was current, paid the fee, and received a renewed license. In fact he completed 14 hours during the two-year cycle: 8 hours at a national meeting (3 of them practice marketing) and 6 hours of self-study webinars from a company with no ADA CERP or state recognition. His BLS card expired two months before the renewal date. In month three of the new cycle the State Dental Board sends a CE audit letter asking for certificates within 21 days. Devon tells you, 'I already have the license in hand, so the audit is just paperwork. And my boss wants me to keep seeing patients while I dig up certificates.'
1. What is the legal status of Devon's license, and how do the 14 hours, the unrecognized webinars, and the expired BLS card factor in?
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The license is currently valid - it was renewed and no board order restricts it - but renewal does not erase the underlying requirement or the truth of the attestation he signed.
- Hours. Ohio sets a fixed biennial CE requirement for hygienists (commonly stated as 24 hours per renewal cycle). Fourteen hours is a clear shortfall before any course is scrutinized.
- Quality of hours. CE must come from recognized sponsors and fall within acceptable subject areas. Marketing/practice-management content is often limited or non-counting, and webinars from a provider with no recognized approval generally do not qualify. His countable total may be well below 14.
- CPR. Current CPR certification is a condition tied to renewal, not something that can expire mid-cycle and be fixed later. His card had already lapsed before he attested.
- The audit letter. It is not paperwork. Failing to respond within the stated window is itself a violation and converts a records problem into a separate disciplinary matter.
He should respond within the 21 days with an honest accounting, submit only certificates he can actually produce, immediately enroll in a recognized BLS course, and begin making up the deficit with approved CE.
2. What are the realistic consequences of the false attestation, and what should Devon do about it now?
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The Dental Practice Act allows discipline for violating the CE rules and for fraud or deceit in obtaining or renewing a license. Boards generally view a shortfall as a remediable administrative problem but view a knowingly false attestation as an honesty problem, which is treated more seriously. Realistic outcomes range from a citation, civil penalty, and a required corrective CE plan, up to suspension if the deficiency is large, the conduct is repeated, or the hygienist obstructs the audit.
What he should do:
- Reply timely and truthfully - acknowledge the shortfall rather than padding the file.
- Submit verifiable certificates, plus proof of a completed BLS course as soon as he has it.
- Complete the missing approved hours promptly and keep documentation of completion.
- Never backdate, alter, or purchase certificates. That turns a correctable CE issue into a fraud case and can end the license.
- Keep copies of everything sent and received, and retain counsel if the board opens an investigation rather than closing the audit administratively.
- Do not sign the next cycle's attestation until the requirements are actually satisfied.
3. Can Devon keep working while the audit is pending, and what should he tell his employer?
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Yes - while the license remains in force and no board order limits practice, an audit is not a suspension, and he may continue treating patients. The CPR point deserves separate attention: because current CPR certification is tied to the licensure renewal, the correct and conservative course is to complete a recognized BLS course before his next patient contact rather than waiting for the audit to resolve.
What to tell the employer: the facts, plainly - the license is active, a CE audit has been received, there is a response deadline, and he needs a half day for a BLS course. He should not let the schedule be built around rumor, and the employer should not ask him to attest to anything on the practice's behalf.
The line that matters: if the board later issues a suspension, restriction, or consent agreement, he must stop practicing the moment it takes effect. Working after that is unlicensed practice - a separate violation, and one that typically ends in revocation rather than a fine. He should also correct his CE record-keeping going forward so the next cycle can be documented on demand.