The License That Expired Over the Holiday
Priya passed the National Physical Therapy Examination in 2022 and has held an Oregon physical therapist license since then. She moved to Washington in 2023 and allowed her Oregon license to expire on December 31, 2024, because she assumed she would not return. In February 2025, her former employer asks her to cover six home-health visits in Portland for three weeks. Priya agrees. Between February 3 and February 21, she sees 11 patients, signs notes as “PT,” and submits claims to Medicare. On February 24, the employer’s compliance officer asks for her license number. Priya sends an image of her 2024 license card. She has completed 18 hours of continuing education since her last renewal, including a two-hour ethics course. She asks whether she can “just pay the late fee and backdate the renewal” to February 1.
1. Was Priya authorized to provide and bill for physical therapy services in February 2025? Analyze the consequences.
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No. A license that expired on December 31, 2024, does not authorize practice in February 2025. An image of the old card proves only that she once held a license; it does not renew it. Practicing on an expired license is unlicensed practice and exposes her to Board discipline, civil penalties, and possible criminal liability. Submitting Medicare claims for services furnished by an unlicensed provider also raises false-claims and overpayment issues; the employer may have separate obligations. Her clinical competence and continuing education hours do not cure the licensure defect. She must stop treating immediately, notify the employer, and not submit further claims until the Board restores her license. Backdating would compound the problem by creating a false record.
2. What must Priya do to return to active practice, and how should she handle the 18 continuing education hours?
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She must apply to the Board for reinstatement or renewal under the applicable rules, pay the required fees, and satisfy any continuing education or competency requirements the Board imposes for a lapsed license. She should not assume that 18 hours automatically suffices; the Board will apply the continuing education requirement for the renewal period and determine whether her courses qualify. If the lapse is short, the Board may require a reinstatement application and fee rather than a new license; if the lapse is longer or the rules require it, additional education or examination may be required. She should provide accurate dates and explanations, not backdate. She should keep certificates and course descriptions. Practicing while the application is pending is not allowed unless the Board issues a valid license or temporary authorization.
3. What should happen to the Medicare claims and the patient notes she already signed?
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The employer and Priya should correct the claims. Services furnished by an unlicensed person are not billable as physical therapy services; claims should be withdrawn or corrected and any overpayment returned. The notes may remain as a factual record of what happened, but they should not be altered to hide the licensure problem; a late addendum can clarify her status. Self-disclosure to Medicare and the Board is better than waiting for an audit. The compliance officer should be told the truth. Concealing or backdating would turn a licensure problem into a fraud and integrity problem.